Justia Montana Supreme Court Opinion Summaries

The district court granted a permanent injunction against the enforcement of certain provisions of the 2011 Montana Marijuana Act. The State appealed the grant of the injunction, and Plaintiffs cross-appealed the district court’s refusal to enjoin other provisions of the Act. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) erred in determining that the Act’s provision requiring the Department of Public Health and Human Services to notify the Board of Medical Examiners of any physician who certifies twenty-five or more patients in a year for medical marijuana fails rational review; (2) did not err in determining that the Act’s commercial prohibitions fail rational basis review; (3) erred in applying strict scrutiny review to the Act’s provision prohibiting advertising by providers of medical marijuana; (4) did not err in determining that the Act’s provision prohibiting probationers from becoming registered cardholders for medical marijuana use withstands a facial challenge under rational basis scrutiny; and (5) did not err in determining that the Act’s provision allowing warrantless inspections of medical marijuana providers’ businesses comports with constitutional guarantees against unreasonable searches. View "Mont. Cannabis Indus. Ass’n v. State" on Justia Law

After a hearing, the district court entered an order for Appellant's involuntary commitment, not to exceed ninety days, initially to Montana State Hospital. Appellant appealed, arguing, inter alia, that the district court’s verbal and written order lacked sufficient factual detail to satisfy statutory requirements for an order of commitment. The Supreme Court affirmed, holding (1) the district court’s findings were sufficient to satisfy Mont. Code Ann. 53-21-127(8)(a); and (2) there was sufficient evidence to support a finding that, as a result of his mental disorder, Appellant required an order of involuntary commitment. View "In re B.D." on Justia Law

While institutionalized at the Montana State Hospital, Defendant assaulted and injured a nurse. Defendant was charged with felony aggravated assault and was transferred to Montana State Prison, where he remained until the district court ordered that he be transferred back to the Hospital. The Hospital was statutorily required to submit a fitness-to-proceed evaluation report to the district court within ninety days of commitment but untimely submitted its report. Defendant moved to dismiss his assault charge on the grounds that the fitness evaluation report had not been timely submitted. The district court granted the motion. The Supreme Court reversed, holding that by agreeing to a continuing course of treatment at the Hospital after the initial report was submitted to the district court, Defendant waived his objection to the timeliness of that report. Remanded. View "State v. Robertson" on Justia Law

In 2014, the district court found Respondent to be suffering from a mental disorder requiring commitment. The court involuntarily committed Respondent to the Montana State Hospital (MSH). On June 2, 2014, the district court issued an order of commitment summarizing the commitment. On June 5, 2014, the district court filed findings of fact, conclusions of law, and an order supporting the June 2 order. The Supreme Court affirmed, holding (1) the district court’s June 2 order of commitment was deficient due and failed to comply with Mont. Code Ann. 53-21-127(8)(a) because it did not contain a detailed statement of the facts as required by section 53-21-127(8)(a); (2) the district court’s June 5 order was not procedurally invalid; and (3) the district court’s findings in the June 5 order were supported by substantial evidence, sufficient to support the decision to commit Respondent to the MSH. View "In re M.P.-L." on Justia Law

Todd Kiser initiated this action by filing a form complaint against Noel Kiser and Marie McDowell alleging that Noel and Marie owed him a sum of money arising out of an asserted agreement among them regarding their father’s nursing care and cremation costs. The small claims court entered judgment in favor of Todd. Noel and Marie appealed the judgment to the district court. The district court dismissed the appeal, reasoning that the brief filed by Noel and Marie had been untimely filed. The Supreme Court reversed, holding that the district court erred in dismissing the appeal on the basis of the briefing deadline imposed in the inapplicable Municipal Court Appellate Rules. Remanded to the district court for reinstatement of Noel and Marie’s appeal and for further proceedings. View "Kiser v. Kiser" on Justia Law

A.M.M. was the mother of eight adult children, including Timothy McCann. Timothy filed a petition requesting that he be appointed A.M.M’s sole guardian and conservator. After a trial, the district court found that A.M.M. was an incapacitated person, appointed attorney Casey Emerson as guardian and appointed Timothy, Timothy’s brother, and attorney Douglas Wold as joint conservators. The district court later awarded attorney fees to Wold and Emerson. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by denying Timothy’s motion to vacate, nor did the court err in its ruling on any of the issues therein; (2) did not abuse its discretion by striking Timothy’s reply brief for untimely service; (3) did not abuse its discretion when it limited the powers of the conservators to act on behalf of A.M.M. in her role as a corporate director or signatory; and (4) did not abuse its discretion by ordering payment of attorney fees to either Wold or Emerson. Lastly, Timothy’s allegations of attorney misconduct were not properly before the Court. View "In re Guardianship of A.M.M." on Justia Law

After a hearing, the district court committed E.A.L., who had been diagnosed with schizophrenia and antisocial personality traits, to the Montana State Hospital for ninety days. The Supreme Court affirmed, holding (1) the district court’s finding that E.A.L. posed an imminent threat of harm to himself or others was not clearly erroneous; (2) even if the district court erred by basing findings of fact on statements made in the State’s petition for commitment, the error was harmless; and (3) there was a sufficient basis for the district court to commit E.A.L. View "In re E.A.L." on Justia Law

M.K.S., who had a long history of treatment for schizophrenia and other mental health illnesses, was regularly subject to community commitments and hospitalizations. In 2013, M.K.S. stipulated to a six-month community commitment. Before the commitment was set to expire, the State filed a renewed petition for commitment. After a commitment hearing, the district court found that M.K.S. posed a danger to herself based on her recent suicidal threats and that a commitment to the Montana State Hospital was necessary to guarantee her safety. The Supreme Court affirmed based on the plain error doctrine, holding that because of a professional person’s failure to file a statutorily-required written report in M.K.S.’s civil commitment proceeding, M.K.S.’s right of due process was implicated in the proceedings. However, M.K.S. failed to demonstrate that the absence of a written report substantially impacted this right in a manner that would leave unsettled the fundamental fairness of the proceedings, compromise the integrity of the judicial process, or create a manifest miscarriage of justice. View "In re M.K.S." on Justia Law

On December 24, 2013, the State filed a petition for commitment against B.O.T. After a hearing, the district court ordered B.O.T. committed to the Montana State Hospital for ninety days and that medication could be involuntarily administered, concluding that B.O.T. was unable to care for his basic needs, admitted to having a serious mental illness, and was unable to demonstrate how he would care himself to protect himself from harm if released from inpatient treatment. The Supreme Court affirmed, holding that substantial evidence supported the judgment and order of the district court finding that B.O.T. suffered from a mental disorder that prevented him from taking care of his basic needs was supported by substantial evidence, and the findings of the district court were not clearly erroneous. View "In re B.O.T." on Justia Law

Twelve days after Justin Schiller was involuntarily committed to the Montana State Hospital (MSH), Schiller was released. A few months later, Schiller killed his former girlfriend, Catherine Woods, and then himself. Catherine’s parents filed a complaint alleging that MSH had a statutory duty to warn Catherine of the risk of violent behavior by Schiller. The district court granted summary judgment in favor of the State and MSH, concluding that MSH had no duty to warn Catherine or take precautions for her protection because Schiller never communicated any specific threat of violence against Catherine during his commitment. The Supreme Court affirmed, holding that because no actual, specific threat was communicated in this case, the duty to warn was not triggered. View "Woods v. Mont. State Hosp." on Justia Law