Justia Montana Supreme Court Opinion Summaries

Plaintiffs worked within the Child Support Enforcement Division of the Department of Public Health and Human Services and constituted the majority of Compliance Specialists, Pay Band 6, employed by the State. Plaintiffs, who belonged to a Union, filed a grievance with the Board of Personnel Appeals (BOPA) alleging that their pay was not “internally equitable” in comparison with Pay Band 6 Compliance Specialists in other state agencies. A Hearing Officer issued a recommended order holding that Plaintiffs were aggrieved and awarded damages. BOPA, however, rejected the recommended order and dismissed the grievance, concluding that Plaintiffs had no independent right to internally equitable pay with other Pay Band 6 Compliance Specialists, but, instead, internal equity was a factor to be considered during the collective bargaining process. The district court vacated and reversed BOPA’s final order, agreeing with the Hearing Officer that Plaintiffs had a right to pay that was internally equitable with other Pay Band 6 Compliance Specialists. The Supreme Court vacated the district court’s order and reinstated BOPA’s final order, holding that the statutory factor of “internal equity” is not a stand-alone right that may be pursued independently and in preemption of the work of the collective bargaining process. View "Mashek v. Dep’t of Pub. Health & Human Servs." on Justia Law

Fellows filed the underlying complaint challenging the Water Commissioner’s administration of water under the Perry v. Beattie decree. The district court dismissed Fellows’s complaint for failure to state a claim. The Supreme Court reversed and remanded, concluding that Fellows’s allegations were sufficient to state a claim. Fellows then requested the district court to certify a question to the Water Court. The district court granted the request. The Water Court entered a final order that tabulated the water rights necessary to address Fellows’s underlying complaint. By the time of its certification order, the water claims had been adjudicated in a temporary preliminary decree, and therefore, the Water Court ordered that the matter be closed and returned to the district court. The Perry Defendants filed a motion to alter or amend the Water Court’s judgment. The Water Court denied the motion. The Supreme Court affirmed, holding (1) the Water Court correctly followed the law of the case; (2) Fellows’s petition for certification was proper; and (3) the Water Court did not err in defining the scope of the controversy, in determining the purpose of the tabulation, and in tabulating the applicable rights involved in the controversy. Remanded. View "Fellows v. Saylor" on Justia Law

In 2014, the Montana Environmental Information Center (MEIC) filed suit challenging the decision of the Montana Department of Environmental Quality (DEQ) to approve the expansion of Golden Sunlight Mines, Inc.’s (GSM) gold mine to include a nearby pit. DEQ and GSM (together, Appellees) asserted that MEIC should be collaterally estopped from relitigating the question of whether the Montana Constitution and the Montana Metal Mine Reclamation Act (MMRA) require lands disturbed by a mining operation to be fully reclaimed because this precise issue had already been litigated, with MEIC receiving an adverse ruling from the district court. The district court agreed and entered judgment in favor of Appellees. The Supreme Court affirmed, holding (1) the district court correctly found that collateral estoppel precluded MEIC from relitigating whether the Montana Constitution or the MMRA requires land disturbed by the taking of natural resources to be fully reclaimed to its previous condition; and (2) the district court did not err by upholding the DEQ’s decision. View "Mont. Envtl. Info. Ctr. v. Mont. Dep’t of Envtl. Quality" on Justia Law

This appeal concerned individual objectors to the Crow Water Compact, an agreement to distribute and manage water rights among the United States, the Crow Tribe, and the State of Montana. The Supreme Court affirmed the Water Court’s order, holding (1) the Water Court applied the proper legal standard of review in approving the Compact in the final order; (2) the Objectors failed to meet their burden of showing that the Compact was unreasonable and materially injured their interest; and (3) the Compact negotiation process did not violate the Objectors’ due process rights. View "In re Crow Tribe Water Compact" on Justia Law

In 1982, Teton Co-Operative Canal Company (Teton Canal) filed a statement of claim for existing water rights for the Eureka Reservoir. Teton Cooperative Reservoir Company (Teton Reservoir) objected to Teton Canal’s claims. The Water Master held a hearing in 2012 and, in 2015, adjudicated Teton Canal’s claims. Teton Reservoir appealed. The Supreme Court reversed the Water Court’s order regarding Teton Canal’s water right claims to the Eureka Reservoir, holding that the Water Court erred in determining that off-stream water storage in the Eureka Reservoir was included as part of Teton Canal’s April 18, 1890 Notice of Appropriation. Remanded to the Water Court to assign a new priority date to Teton Canal’s rights to the Eureka Reservoir and for further proceedings. View "Teton Co-op Canal Co. v. Teton Coop Reservoir Co." on Justia Law

When Mary Stewart failed to pay real property taxes on her property, the Flathead County Treasurer held a tax lien sale for the delinquent taxes. The County was listed as the purchaser of the tax lien. In 2013, RN & DB, LLC paid the delinquent taxes, penalties, interests, and costs for the property and applied for a tax deed. The County issued a tax deed to RN & DB, after which RN & DB filed an action to quiet title in the property. The district court granted RN & DB’s motion for summary judgment and entered a decree quieting title in favor of RN & DB. The Supreme Court affirmed, holding (1) the district court did not err in not applying the statutory homestead exemption to the tax lien sale on Stewart’s property; (2) Stewart’s claim that the district court should have considered the tax assessor’s failure to investigate Stewart’s complaints regarding irregular tax assessments on Stewart’s property was barred; and (3) the district court did not abuse its discretion in granting summary judgment without holding a hearing. View "RN & DB, LLC v. Stewart" on Justia Law

After Jon Cruson resigned from his position with Missoula Electric Cooperative, Inc., he filed a claim for unemployment benefits with the Montana Department of Labor and Industry’s Unemployment Insurance Division (Department). The Department ultimately granted Cruson unemployment insurance benefits beginning on the date of his resignation. The Hearings Bureau reversed, concluding that Cruson was disqualified from receiving benefits because the reason he offered for quitting did not constitute good cause attributable to his employment. The Board of Labor Appeals affirmed. The district court denied Cruson’s appeal, determining that the Board correctly applied the law to the facts when it determined that Cruson did not voluntarily leave his employment with good cause attributable to his employer. The Supreme Court affirmed, holding that the Board’s factual findings were supported by substantial evidence, and its legal conclusion that “good cause attributable to the employer” had not been shown was correct. View "Cruson v. Missoula Elec. Coop." on Justia Law

The Gallatin Gateway County Water & Sewer District sought a permit for a proposed wastewater treatment system. The Montana Department of Environmental Quality (DEQ) granted a wastewater discharge permit. Gateway Village, LLC, which owns land adjacent to and down-gradient from the proposed activities, requested judicial review of DEQ’s issuance of the permit and alleged that the discharge of wastewater into groundwater extending under its surface property would constitute a common law trespass. The district court determined that further environmental analysis was necessary and remanded the case to DEQ. The court also denied DEQ’s and the District’s motions for summary judgment or dismissal of Gateway Village’s trespass claim and denied Gateway Village’s request for attorneys’ fees. The Supreme Court (1) vacated the portion of the district court’s order addressing the trespass claim, holding that, having remanded the case, the district court should have declined to address the trespass claim; and (2) affirmed the district court’s decision to deny Gateway Village’s request for attorney’s fees. View "Gateway Village, LLC v. Mont. Dep’t of Envtl. Quality" on Justia Law

In 2013, Froid Elementary School District No. 65 petitioned the Roosevelt County Superintendent of Schools to transfer territory from the Poplar Elementary School District No. 9 to the Froid School District. Poplar opposed the transfer. The deputy superintendent appointed for the purpose of hearing and deciding the petition approved the territory transfer. Poplar appealed. The district court awarded summary judgment to Poplar and vacated the order transferring territory to Froid on the basis that the territory transfer statute required statements to be made under oath and that the deputy superintendent’s failure to administrator oaths was an abuse of discretion. The Supreme Court reversed, holding that Poplar failed to preserve its statutory issue concerning the necessity of sworn testimony and it was error for the district court to reach the merits of the question. Remanded. View "In re Petition to Transfer Territory from Poplar Elementary Sch. to Froid Elementary Sch." on Justia Law

Plaintiff filed a complaint against Lincoln County and several Lincoln County Commissioners, alleging certain errors committed in the resignations and appointments of the Commissioners. The district court granted summary judgment in favor of the County. The County subsequently asked the court to award it attorney fees. The district court ultimately awarded the County a total of $11,281 in attorney fees. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err by issuing an order prepared by the county’s counsel; (2) did not abuse its discretion by considering rates charged by practicing attorneys outside the Lincoln County legal market when deciding whether the County’s attorney fees were reasonable; but (3) did abuse its discretion when it awarded supplemental attorney fees to the County. View "Swapinski v. Lincoln County" on Justia Law