Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the orders of the district court denying the motion for judgment on the pleadings filed by the Associated Press and other news reporting outlets (collectively, the AP) and granting a motion to dismiss filed by Barry Usher, holding that the district court did not err.During the state's biennial legislative session in 2021, Usher, who was the Chair of the Judiciary Committee of the Montana House of Representatives, and other Republican members of the Committee met privately to discuss pending legislation. Because Usher denied the AP access to the gathering, the AP brought this lawsuit, seeking a declaratory judgment that this denial of access was a constitutional violation. The district court granted Usher's motion to dismiss, concluding that the gathering was controlled by the open meeting statute, Mont. Code Ann. 2-3-202, and that applying the statute in this case did not violate the AP's Mont. Const. art. II, 9 right to access a gathering of Judiciary Committee members. The Supreme Court affirmed, holding that the district court did not err in applying the statutory definition of a "meeting" to the AP's constitutional right to access a gathering of Judiciary Committee members. View "Associated Press v. Usher" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Yellowstone Disposal, LLC's petition for writ of mandamus, holding that the district court did not err.Yellowstone Disposal filed a petition for writ of mandamus to compel the Montana Department of Environmental Quality (DEQ) to issue a license or, in the alternative, issue a final decision approving or denying its application for a class II solid waste management systems (SWMS) license to operate a SWMS in Richland County. The district court granted DEQ's motion to dismiss the petition for failure to state a claim. The Supreme Court affirmed, holding that Yellowstone Disposal did not satisfy the requirements for issuance of a writ of mandamus. View "Yellowstone Disposal, LLC v. State, Department of Environmental Quality" on Justia Law

The Supreme Court reversed the judgment of the district court finding two officials with the Montana Department of Public Health and Human Services (hereinafter, MDPHHS) in indirect contempt of referenced orders in the underlying matter and imposing a sanction pending subsequent compliance with the subject orders, holding that the district court erred.The referenced orders at issue directed the Montana State Hospital to accept custody and care of the underlying criminal defendant for fitness rehabilitation pursuant to Mont. Code Ann. 46-14-221(2)-(3) and thus imposing a $500 per-day coercive civil sanction pending future compliance with the orders. The district court adjudicated MDPHHS in indirect contempt for failing to transport the defendant as required and imposed a $500 per-day coercive civil sanction. The Supreme Court reversed, holding (1) the district court's threshold contempt finding and resulting imposition of a coercive civil sanction were both erroneously based on a clearly erroneous finding of material fact; and (2) the court's imposition of a continuing or cascading per-day fine was further erroneous in excess of the limiting language of Mont. Code Ann. 3-1-501(3). View "Fouts v. Eighth Judicial District Court" on Justia Law

The Supreme Court affirmed the order of the district court denying the Ekalaka Volunteer Fire Department, Inc.'s (Department) motion for summary judgment, holding that the district court did not err in finding that the Town of Ekalaka's fire department was municipally owned as a matter of law.The Department claimed it had always been a private fire company that existed as an unincorporated association until 2016, when it filed its incorporation paperwork following the town attorney's advice. The Town, in response, filed for a declaratory judgment that the Department was municipally owned. The district court granted summary judgment for the Town. The Supreme Court affirmed, holding that the evidence overwhelmingly weighed toward declaratory judgment affirming the duly established municipal department. View "Ekalaka v. Ekalaka Volunteer Fire Department, Inc." on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment to the Montana Department of Revenue and dismissing Appellants' claims that the Department tortiously, unconstitutionally, and in breach of contract interfered with B.Y.O.B., Inc.'s (BYOB) attempts to transfer its ownership of an agency franchise agreement (AFA) for liquor sales, holding that the district court did not err.After the Department took action to terminate the AFA at issue for alleged violations of the Montana liquor laws, BYOB attempted to sell its interest and transfer ownership of the AFA it held with the Department. When the effort was unsuccessful, Appellants brought this suit. The district court granted summary judgment to the Department, finding that Appellants' AFA transfer-related claims were barred by quasi-judicial immunity or, alternatively, by the parties' settlement agreement. The Supreme Court affirmed, holding that the district court did not err in its rulings related to BYOB's attempts to assign the AFA to third parties. View "B.Y.O.B., Inc. v. Montana Department of Revenue" on Justia Law

In this original proceeding, the Supreme Court held that a subpoena issued by the Chair of the Senate Judiciary Committee to Director Misty Ann Giles and the subpoena issued by the Senate president and Speaker of the House to Court Administrator Beth McLaughlin did not serve a valid legislative purpose, were permissibly overbroad and were therefore invalid.McLaughlin brought this proceeding seeking to quash and permanently enjoin the enforcement of successive subpoenas the Legislature issued first to the Director of the State Department of Administration and later to McLaughlin for the production of McLaughlin's emails between certain dates. The second subpoena also ordered production of McLaughlin's stated-owned telephones and computers used to facilitate polling of state judges. The Supreme Court granted the request, holding (1) the subpoenas in question were impermissibly overboard and exceeded the scope of legislative authority; and (2) if the Legislature subpoenas records from a state officer like the Court Administrator auxiliary to its legislative function, whether those records be in electronic or other form, a Montana court and not the Legislature must conduct any needed in camera review and balance competing security and privacy interests to determine whether records should be redacted prior to disclosure. View "McLaughlin v. Montana State Legislature" on Justia Law

The Supreme Court affirmed the order of the district court affirming the decision of the Stillwater Board of County Commissioners to abandon a portion of Eerie Drive, holding that the district court did not err in concluding that substantial evidence supported the Board's decision.Specifically, the Supreme Court held (1) the district court did not err in limiting its review of the record to whether there was sufficient evidence that the Board exceeded its jurisdiction to justify intruding on the Board's inherent discretion regarding road abandonment decisions; and (2) the district court did not err in concluding that the Board adequately documented its decision, as required by the statutes governing county road abandonment and caselaw. View "Williams v. Stillwater Board of County Commissioners" on Justia Law

The Supreme Court reversed an order of the district court affirming an administrative law judge's proposed order that trust principal consisting of a jointly owned home constituted a countable asset for the purpose of the Medicaid eligibility of Marilyn Scheidecker, holding that there were no circumstances under which payment from the trust's corpus could be made for Marilyn's benefit.The Montana Department of Public Health and Human Services denied Marilyn's application for Medicaid, concluding that Marilyn's one-half interest in the trust's principal was a countable resource placing her over Medicaid's resource limit. The ALJ upheld the denial. The district court affirmed the ALJ's ultimate conclusion that the trust was a countable asset pursuant to 42 U.S.C. 1396p(d)(3), holding that circumstances existed by which payments form the trust's corpus could be made to or for Marilyn's benefit. The Supreme Court reversed, holding that the district court was incorrect in its application of the federal statute. View "Estate of Scheidecker v. Montana Department of Public Health & Human Services" on Justia Law

The Supreme Court affirmed the order of the district court affirming the order of the Department of Fish, Wildlife, and Parks (PWF) revoking Animals of Montana, Inc.'s (AMI) roadside menagerie permit, holding that the district court did not err.AMI, which owned a large number of animals, operated under a roadside meager permit from FWP. After conducting an inspection of AMI's premises, FWP found numerous violations. FWP then issued AMI notice of revocation of its operating permit. The hearing officer determined that FWP established twenty-two violations and issued a final order revoking AMI's permit. The district court affirmed. The Supreme Court affirmed, holding that the affirmative defense of entrapment by estoppel did not prevent FWP from revoking AMI's roadside menagerie permit. View "Animals of Montana, Inc. v. State, Department of Fish, Wildlife, & Parks" on Justia Law

The Supreme Court reversed in part and affirmed in part the order of the Montana Water Court reversing the order of the Montana Department of Natural Resources and Conservation (DNRC) denying Daniel and Sandra DeBuff's amended application for a beneficial water use permit, holding that the application satisfied the statutory criteria for a preliminary determination and may move forward to face objections.Specifically, the Supreme Court held (1) DNRC did not improperly relied upon either a geologic map or a 1987 final order in making its determination; (2) the Water Court erred by holding that DNRC's determination that the source aquifer was not discontinuous was clearly erroneous; (3) the Water Court correctly determined that DNRC's failure to consider evapotranspiration evidence provided by DeBuff was arbitrary and capricious; and (4) DNRC's determination that the water was not legally available and would have an adverse effect on senior appropriators was arbitrary and capricious. View "Debuff v. Montana Department of Natural Resources & Conservation" on Justia Law