Justia Montana Supreme Court Opinion Summaries

The case involves Protect the Gallatin River (PTGR) appealing a decision by the Gallatin County Floodplain Administrator to issue a floodplain permit for the Riverbend Glamping Getaway project proposed by Jeff and Jirina Pfeil. The project includes developing a campground with non-permanent structures on an island in the Gallatin River. PTGR argued that the public's right to participate was violated and that the Floodplain Administrator's decision was erroneous.The Eighteenth Judicial District Court of Gallatin County reviewed the case and issued an order on November 13, 2023, resolving competing summary judgment motions. The court denied PTGR's motions for partial summary judgment, granted summary judgment in favor of Gallatin County and the Pfeils regarding PTGR's complaint, and addressed other related claims. PTGR then appealed to the Supreme Court of the State of Montana.The Supreme Court of Montana reviewed the case and affirmed the lower court's decision. The court held that the Floodplain Administrator did not violate PTGR's right to participate, as the public was given a reasonable opportunity to comment, and the decision not to re-open public comment was not arbitrary or capricious. The court also found that the Floodplain Administrator's participation in the appeal process before the Commission was appropriate and lawful, as it did not involve post hoc rationalizations. Finally, the court held that the Floodplain Administrator's decision complied with the Gallatin County Floodplain Regulations and was not an abuse of discretion. The Supreme Court affirmed the District Court's summary judgment orders. View "Protect the Gallatin v. Gallatin Co." on Justia Law

GBSB Holding, LLC (GBSB) is the developer of Baker 80, a proposed subdivision adjacent to Whitefish Hills Village (WHV) in Flathead County. GBSB sought to use WHV roads as the primary access to Baker 80, which was opposed by Flathead County, Whitefish Village, LLC, and the WHV Homeowners Association. GBSB also challenged the abandonment of a portion of Brady Way, a county road within WHV, by Flathead County.The Montana Eleventh Judicial District Court prohibited GBSB from using WHV roads as the primary access to Baker 80. The court concluded that the public access easements on WHV roads did not include primary access for Baker 80 residents. Additionally, the court found that Flathead County did not exceed its jurisdiction in abandoning a portion of Brady Way.The Supreme Court of the State of Montana reviewed the case. The court affirmed the District Court's decision, holding that the public access easements on WHV roads were easements in gross, benefiting the public at large and not specifically Baker 80 residents. The court determined that the scope of the public access easements did not extend to primary access for Baker 80. The court also upheld the District Court's conclusion that Flathead County did not exceed its jurisdiction in abandoning a portion of Brady Way, as the abandonment process complied with statutory requirements and substantial evidence supported the Board's decision. View "GBSB Holding v. Flathead County" on Justia Law

A Montana State Representative, William W. Mercer, requested access to certain child abuse and neglect case records from the Montana Department of Public Health and Human Services (DPHHS) under a statute that allows legislators to review such records. The DPHHS provided some records but withheld others, including emails, text messages, and attorney-client privileged materials. Mercer filed a petition for a writ of mandamus and for declaratory and injunctive relief to compel the DPHHS to release the additional records.The First Judicial District Court of Lewis and Clark County granted a mandatory preliminary injunction requiring the DPHHS to provide the requested records, including those claimed to be attorney-client privileged, but imposed additional confidentiality protections. The DPHHS appealed, arguing that the District Court misinterpreted the statute and that the attorney-client privilege should exempt certain records from disclosure.The Supreme Court of the State of Montana reviewed the case. The court affirmed the District Court's decision, holding that the plain language of the statute required the disclosure of the records to the legislator, subject to confidentiality protections. The court found that the District Court did not abuse its discretion in granting the preliminary injunction, as Mercer demonstrated a clear likelihood of success on the merits, irreparable harm without the injunction, that the balance of equities tipped in his favor, and that the injunction was in the public interest. The court emphasized that the preliminary injunction did not resolve the ultimate merits of the case, which would be determined in further proceedings. View "Mercer v. Department of Public Health and Human Services" on Justia Law

Tintina Montana, Inc. sought to operate an underground copper mine in Meagher County, Montana, which required the removal of substantial quantities of groundwater. Tintina planned to use part of this water for mining operations and return the rest to the aquifer. Montana Trout Unlimited and other environmental groups (collectively "MTU") challenged the issuance of a water use permit by the Montana Department of Natural Resources and Conservation (DNRC) for the mine's operations, arguing that the removal and discharge of water should be considered a beneficial use requiring a permit under the Montana Water Use Act (MWUA).The Fourteenth Judicial District Court denied MTU's petition for judicial review and affirmed DNRC's decision. The court held that DNRC correctly categorized the removal and discharge of water as neither a beneficial use nor waste, thus falling outside the permitting process of the MWUA. The court also found that DNRC's interpretation of the MWUA did not contravene the Montana Constitution.The Montana Supreme Court reviewed the case and affirmed the lower court's decision. The court held that DNRC's longstanding interpretation of the MWUA, which categorizes mine dewatering as neither a beneficial use nor waste, was reasonable and consistent with legislative intent. The court also concluded that the MWUA's exclusion of mine dewatering from the permitting process did not render the Act unconstitutional, as the primary purpose of the MWUA is to regulate water rights, not the water resource itself. The court noted that other statutory frameworks, such as the Montana Water Quality Act and the Metal Mine Reclamation Act, provide for the regulation of water quality and environmental impacts. View "Trout Unlimited v. DNRC" on Justia Law

A disabled woman, T.M.B., was sexually assaulted by an employee of West Mont, a nonprofit organization contracted by the State of Montana to provide community-based services for developmentally disabled individuals. T.M.B. sued both the State and West Mont, alleging they owed her a nondelegable duty of care. The District Court granted summary judgment in favor of both defendants, concluding neither owed a nondelegable duty of care for the employee’s criminal acts. T.M.B. appealed.The District Court of the First Judicial District, Lewis and Clark County, found that the State had satisfied its statutory obligations by contracting with West Mont to provide services and did not owe a nondelegable duty to T.M.B. because she was not under state custody or control. The court also found that West Mont did not owe a nondelegable duty, as there was no statute or rule explicitly stating such a duty existed for state contractors operating community homes.The Supreme Court of the State of Montana reviewed the case. It affirmed the District Court’s decision regarding the State, agreeing that the State did not have a close, continuing relationship with T.M.B. that would impose a nondelegable duty. However, the Supreme Court reversed the decision regarding West Mont, finding that the relationship between West Mont and T.M.B. was sufficiently close and continuing to impose a nondelegable duty under Restatement (Second) of Agency § 214. The court held that West Mont had a duty to protect T.M.B. from harm due to her dependence on their care and supervision. The case was remanded for further proceedings consistent with this opinion. View "T.M.B v. West Mont" on Justia Law

In 2021, the Montana Legislature passed House Bill 407 (HB 407), which preempted local ordinances, resolutions, initiatives, or referendums regulating the use, sale, or taxation of certain containers, including single-use plastics. Bozeman, which adopted a self-government charter in 2000, was affected by this bill. In 2023, a member of the Cottonwood Environmental Law Center submitted a local ballot initiative to regulate single-use plastics in Bozeman. The Gallatin County Election Administrator rejected the petition, citing the prohibition under § 7-5-131(2)(f), MCA. Cottonwood and other plaintiffs filed a complaint challenging the constitutionality of HB 407.The First Judicial District Court granted Cottonwood's motion for partial summary judgment, finding § 7-5-131(2)(f), MCA, unconstitutional under Article XI, Section 8, of the Montana Constitution. The court certified its order as final, allowing the initiative to be placed on the 2024 general election ballot, where it passed.The Supreme Court of the State of Montana reviewed the case. The court held that the Legislature may place limits on the powers of local government, including the power of local initiatives, as long as these limits do not infringe on other constitutional rights. The court found that § 7-1-111(21), MCA, which prohibits local government units with self-government powers from regulating auxiliary containers, is constitutional. Consequently, the court reversed the District Court's decision, holding that § 7-5-131(2)(f), MCA, is not facially unconstitutional under Article XI, Section 8, of the Montana Constitution. View "Cottonwood v. State" on Justia Law

The City of Great Falls unilaterally revised its drug and alcohol policy in 2019, expanding the scope of employees subject to random testing and imposing stricter penalties without negotiating with the affected labor unions. The unions filed unfair labor practice complaints, alleging that the City's actions violated the Montana Public Employees Collective Bargaining Act (MPECBA). The Montana Board of Personnel Appeals (MBPA) consolidated the complaints and referred them to a hearing examiner, who ruled in favor of the unions, concluding that the City's unilateral policy changes constituted unfair labor practices.The City did not file exceptions to the hearing examiner's proposed decision, which became the final agency decision by default. Instead, the City petitioned for judicial review, arguing that the hearing examiner's decision involved purely legal questions that should be reviewed by the court. The District Court of the Eighth Judicial District, Cascade County, dismissed the petition, citing the City's failure to exhaust administrative remedies by not seeking final agency review.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The Court held that the City's failure to exhaust the final agency review remedy provided by MPECBA and the Montana Administrative Procedure Act (MAPA) precluded judicial review. The Court clarified that there is no jurisprudential exception to the exhaustion requirement for purely legal or constitutional questions in the context of MAPA contested case proceedings. The City's petition for judicial review was thus correctly denied and dismissed. View "Great Falls v. Assoc. of Firefighters" on Justia Law

Lake County sought reimbursement from the State of Montana for costs incurred in enforcing state criminal jurisdiction on the Flathead Indian Reservation under Public Law 280 (P.L. 280). The County argued that the State was obligated to cover these costs, citing financial strain and the diversion of resources from other services.The District Court of the Twentieth Judicial District dismissed Lake County’s claims for unfunded mandate and unjust enrichment, ruling that the statutes of limitations had expired. The court determined that the claims accrued in January 2017, when the County expressed its inability to continue bearing the financial burden of P.L. 280. The court also ruled that the continuing tort and equitable tolling doctrines did not apply to toll the statutes of limitations. The court denied the State’s motion to dismiss the declaratory judgment claim but later granted summary judgment in favor of the State, ruling that the State was not obligated to appropriate any specific amount to reimburse the County.The Supreme Court of the State of Montana affirmed the District Court’s rulings. It held that Lake County’s claims were justiciable but that the continuing tort doctrine did not apply because the County sought monetary damages, not abatement. The Court also ruled that the equitable tolling doctrine did not apply as the County did not pursue a legal remedy within the doctrine’s scope. Finally, the Court held that § 2-1-301(2), MCA, only required the State to reimburse the County to the extent funds were appropriated by the Legislature, which retained discretion over such appropriations. The Court affirmed the dismissal of the unfunded mandate and unjust enrichment claims and the summary judgment on the declaratory judgment claim. View "Lake County v. State" on Justia Law

Adrianne Cotton filed a charge of discrimination against the Montana Department of Corrections (DOC), alleging retaliation for protected activity when her position was eliminated. Cotton had been employed by DOC since 2011 and held the position of government relations director. She reported concerns about the conduct of DOC Director Reginald Michael in 2017, which led to an investigation. Subsequently, an organizational assessment recommended eliminating Cotton's position, among others, due to budgetary and structural issues.The case was first reviewed by Hearing Officer Holien, who held a contested case hearing and found that DOC had legitimate, non-discriminatory reasons for eliminating Cotton's position and did not retaliate against her. Cotton appealed to the Human Rights Commission, which rejected Holien's conclusions of law, citing the temporal proximity between Cotton's protected activity and the adverse employment action as sufficient evidence of retaliation. The Commission did not find that Holien's findings of fact were unsupported by substantial evidence.The case was then reviewed by the District Court of the First Judicial District, which found that the Commission exceeded its statutory authority by reweighing the evidence and substituting its judgment for that of the hearing officer. The District Court reversed the Commission's order and reinstated Holien's decision as the final agency decision.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The Court held that the Commission had abused its discretion by not adhering to the proper standard of review and by reweighing evidence that supported Holien's findings. The Supreme Court concluded that the District Court did not err in reinstating Holien's findings as the final agency decision, as they were supported by substantial evidence in the record. View "Cotton v. Dept. of Corrections" on Justia Law

Laura Marie Obert, a former Broadwater County Commissioner, was investigated by the Montana Department of Justice Division of Criminal Investigation (DCI) in 2015 for allegedly receiving unlawful overtime pay and potential ethics violations. In 2016, Obert entered a deferred prosecution agreement with the Assistant Attorney General, agreeing to repay the excess wages and abstain from voting on matters where she had a conflict of interest. In 2019, based on new allegations of violating the agreement, Obert was charged with felony theft and misdemeanor official misconduct. The district court dismissed these charges in 2021, finding Obert had complied with the agreement and there was insufficient evidence for the misconduct charge.Obert then sued the State of Montana and Broadwater County Attorney Cory Swanson, alleging breach of contract, bad faith, due process violations, and malicious prosecution. The First Judicial District Court dismissed her claims, leading to this appeal.The Montana Supreme Court reviewed the case and made several determinations. It reversed the lower court's dismissal of Obert's breach of contract and good faith and fair dealing claims, holding that these claims were not time-barred and did not accrue until the criminal charges were dismissed. However, the court affirmed the dismissal of Obert's bad faith claim, finding no special relationship existed between Obert and the State that would support such a claim. The court also upheld the dismissal of the malicious prosecution claim, ruling that Swanson was protected by prosecutorial immunity as he acted within his statutory duties. Lastly, the court affirmed the dismissal of the due process claim, concluding that Obert's procedural due process rights were not violated as the State followed proper procedures in charging her and the district court provided an appropriate forum to address the alleged breach of the agreement. View "Obert v State" on Justia Law