Justia Montana Supreme Court Opinion Summaries

In 1999, Randall Simms was injured while on the job. Thereafter, Simms became totally disabled and, since 2006, had been receiving total disability benefits. Dr. Michael Schabacker was Simms’ workers’ compensation doctor from 2004 through 2007. In 2010, Simms filed a complaint against Schabacker and his employer, alleging that Schabacker had unlawfully disseminated his private, confidential healthcare information to a law enforcement officer without Simms' permission. The district court granted summary judgment in favor of Schabacker. The Supreme Court affirmed, holding that the district court did not err in concluding (1) Schabacker was statutorily authorized to release relevant healthcare information regarding Simms to the workers’ compensation insurer, and (2) Schabacker did not knowingly assist a law enforcement agency when he discussed Simms’ medical condition with the workers’ compensation insurer. View "Simms v. Schabacker" on Justia Law

After an adjudicatory hearing, the district court granted the State’s petition for the involuntary commitment of S.L., concluding that S.L. suffered from a mental disorder and citing evidence establishing that S.L. posed an imminent threat to herself and that her mental condition would deteriorate if left untreated. The court determined that Montana State Hospital (MSH) was the least restrictive treatment alternative. The court did not hold a separate disposition hearing. The Supreme Court affirmed, holding (1) the district court’s decision to commit S.L. to MSH was not clearly erroneous; and (2) S.L. failed to demonstrate that the court’s decision not to hold a stand-alone disposition hearing deprived her of her due process rights. View "In re S.L." on Justia Law

The State filed a petition for the involuntary commitment of S.M., who suffers from bipolar disorder. After a hearing, the district court concluded that S.M.’s condition required commitment because she was substantially unable to care for her own health and safety and because her condition would predictably deteriorate to the point that she would become a danger to herself if she did not receive treatment. The court then ordered S.M. committed to the Montana State Hospital. The Supreme Court affirmed, holding that the district court (1) did not err in determining that S.M. was, at the time of the hearings, unable to provide for her basic needs, including her health and safety; and (2) did not err in concluding that, under the circumstances of this case, the Montana State Hospital was the least restrictive alternative for S.M.’s treatment. View "In re S.M." on Justia Law

The State filed a petition for the involuntary commitment of N.A. After a hearing on the State’s commitment petition, the district court orally announced its findings that N.A. had a mental disorder requiring a community commitment and ordered that N.A. be committed to a community program for ninety days. N.A. appealed, arguing that the district court failed to follow the requirements of Mont. Code Ann. 53-21-119(1) in obtaining a waiver of his procedural rights. The Supreme Court reversed, holding that the district court violated N.A.’s statutory and due process rights when it issued a commitment order without obtaining from N.A. and intentional and knowing waiver of his procedural rights in accordance with section 53-21-119(1) and supporting case law. View "In re N.A." on Justia Law

The State filed a petition for involuntary commitment of A.M. The district court appointed the Office of the State Public Defender to represent A.M. No friend was appointed. At an initial hearing at which A.M. appeared with counsel via video conferencing, A.M. stipulated that he had a mental disorder from a traumatic brain injury. The district court approved the stipulation. The court then found there was sufficient evidence in the record, together with the parties’ stipulation, that A.M. had a mental disorder requiring commitment. The court entered an order mandating that A.M. be committed to the Montana State Hospital. A.M. appealed, arguing that the district court erred when it issued the commitment order without obtaining from him an intentional and knowing waiver of his procedural rights as required by Mont. Code Ann. 53-21-119(1). The Supreme Court reversed the order of A.M.’s commitment, holding that no evidence was presented and no record was made in this case establishing a knowing and intentional waiver of A.M.’s procedural rights. View "In re A.M." on Justia Law

This case involved L.A., who suffered from schizophrenia. Following her release from her previous commitment, the State filed a petition for involuntary commitment of L.A. After a trial, the jury concluded by special verdict that L.A. was suffering from a mental disorder, was unable to provide for her basic needs, and was a threat of injury to herself or others. The jury also found that if L.A.'s condition were left untreated, it would deteriorate. Following the verdict, the district court adopted an order of commitment and transport order prepared by the State that committed L.A. to the state hospital and approved involuntary medication if it was deemed necessary. The Supreme Court affirmed, holding that the district court did not err by (1) failing to make a detailed statement of facts in its post-trial disposition order; and (2) failing to detail the particular evidence upon which its findings and conclusions were based in authorizing L.A's involuntary medication. View "In re L.A." on Justia Law

After a hearing, the district court determined that S.C. should be committed involuntarily to Montana State Hospital (MSH). The State later conditionally released S.C. from MSH. The State then filed an untimely petition to extend S.C.'s conditional release, which the district court granted. The State subsequently filed a second untimely petition to extend S.C.'s conditional release, which the district court also granted. Thereafter, the State filed a third untimely petition to extend S.C.'s conditional release. S.C. objected, arguing that the State's third petition to extend his commitment period failed to comply with the timeliness requirements of Mont. Code Ann. 53-21-198. The district court granted the State's petition. The Supreme Court reversed, holding (1) the expiration of S.C.'s commitment period before the State's first petition to extend S.C.'s conditional release left the district court without jurisdiction; and (2) consequently, the district court was without authority to extend the period of S.C.'s conditions of release when the State filed the second and third petitions. View "In re S.C." on Justia Law

The State petitioned the district court to involuntarily commit Appellant to the Montana State Hospital (MSH) for ninety days. The district court appointed counsel to represent Appellant and informed her of her right to be present at the commitment hearing. Appellant did not appear at the commitment hearing. The district court proceeded with the hearing and committed Appellant to MSH for a period not exceeding ninety days. Appellant appealed, contending that the district court erred and violated her due process rights by proceeding with the commitment hearing without first "obtaining a valid waiver" of her right to be present under Mont. Code Ann. 53-21-119. The Supreme Court reversed, holding that, while Appellant's attorney could inform the district court of Appellant's desire to waive her right to be present, the district court should have made further inquiry to determine whether Appellant was capable of making an intentional and knowing waiver decision. View "In re P.A.C." on Justia Law

Appellant was a fifty-five-year-old male with a history of schizoaffective disorder. The State filed a petition to involuntarily commit Appellant, alleging that Appellant was unable to care for his basic needs and appeared to pose a danger to himself and others. After a hearing, the district court granted the State's petition and involuntarily committed Appellant to the Montana State Hospital (MSH), authorizing MSH to administer appropriate medication involuntarily. The Supreme Court affirmed, holding (1) the district court did not violate Appellant's statutory and due process rights when it failed to obtain a personal waiver of rights under Mont. Code Ann. 53-21-119(1), as Appellant effectively waived his rights by allowing his counsel to inform the judge of his desire to do so; and (2) the district court complied with the statutory requirements in ordering Appellant to take medications as prescribed by his doctors, and this directive was sufficient to authorize involuntary medication. View "In re R.W.K." on Justia Law

Edythe Rice, who was in her late eighties, owned a cattle ranch. Edythe's son, Clark Rice, assisted Edythe in performing ranch duties. In 2006, Clark was driving a tractor in "advanced twilight" without illuminated lights. Juanita Stands struck the tractor's left rear tire. The impact caused Juanita's vehicle to spin into the neighboring lane, where it collided with Vianna Stewart's vehicle. Juanita and Vianna sustained injuries from the accident. The tractor and automobiles were total losses. After five years in litigation, the district court (1) concluded that Clark was negligent per se for violating three traffic statutes; (2) determined Edythe was vicariously liable for the injuries; and (3) concluded that Clark and Edythe were jointly and severally liable for eighty percent of Juanita's claimed damages and one hundred percent of Vianna's claimed damages. The Supreme Court (1) reversed the district court's judgment against Edythe, holding that the district court erred by proceeding to trial without addressing Edythe's competency or ensuring the parties met statutory notice requirements; and (2) otherwise affirmed. Remanded the case for an evaluation of Edythe's need for a conservator and new trial as to Edythe's vicarious liability only. View "Stewart v. Rice" on Justia Law