Justia Montana Supreme Court Opinion Summaries

Plaintiff purchased property from Defendants in 1993. The warranty deed for the property contained no express mention of water rights, ditch easements, or appurtenances. Plaintiff nevertheless believed that a water right came with the property and that a ditch easement existed to transport the water to his property. Defendants later purchased real property which historically contained a ditch. It was subsequently discovered the property did have a ditch that traversed from a creek, across Defendants' property, to a 20-acre "place of use" on the properly now owned by Plaintiff. Plaintiff subsequently attempted to reopen use of the ditch and filed an action against Defendants seeking a declaration that he had a ditch easement across Defendants' property. The district court ruled in favor of Defendants. The Supreme Court affirmed, holding that the district court properly determined that Plaintiff had no ditch easement across property owned by Defendants. View "Roland v. Davis" on Justia Law

Three individuals (collectively, "Pallister") were unnamed members in a class action suit against insurers Blue Cross and Blue Shield of Montana, Inc. (BCBSMT) and Montana Comprehensive Health Association (MCHA). The suit generally sought damages from the insurers for the companies' delayed payments of benefits and for benefits improperly withheld. BCBSMT, MCHA, and the named class members subsequently entered into a proposed settlement. Pallister objected to the settlement agreement and filed a motion to conduct discovery into the fairness of the proposed settlement. The district court denied the motion. The Supreme Court reversed and vacated the district court's approval of the settlement agreement. The Court remanded to the district court with instructions to allow discovery into the settlement negotiations. Pallister then filed a motion for substitution of the district court judge. The judge denied the motion. The Supreme Court affirmed, holding (1) Pallister was not a party for purposes of substitution; and (2) Mont. Code Ann. 1-804(12) did not provide for substitution on remand in this case. View "Pallister v. Blue Cross & Blue Shield of Mont., Inc." on Justia Law

After Sarah West was involved in a motor vehicle accident, West made a claim against her insurer, State Farm, for underinsured motorist benefits of $75,000. State Farm paid only $20,000 in benefits. Attorney Tracey Morin subsequently filed a complaint against State Farm on behalf of Sarah and her parents, Ausra and James West, for breach of contract, violation of the Montana Unfair Trade Practices Act, and breach of the implied covenant of good faith and fair dealing. At the conclusion of the action, the district court imposed sanctions on Morin individually under Mont. R. Civ. P. 11. Morin appealed, contending that the depth and breadth of the sanctions constituted an abuse of discretion. The Supreme Court affirmed, holding that the district court did not abuse its discretion in imposing the level of sanctions imposed in this case. View "Morin v. State Farm Mut. Auto. Ins. Co." on Justia Law

In 2012, Plaintiff sought and obtained a temporary order of protection against Defendant in a civil action. Subsequently, Plaintiff obtained a no contact order against Defendant in a criminal action. Defendant moved to have the civil action dismissed with prejudice as a discovery sanction. Plaintiff moved to have the civil action dismissed without prejudice in the event she needed a future civil order of protection. The district court granted Plaintiff's motion and dismissed the civil action without prejudice. The Supreme Court affirmed, holding (1) under the circumstances, it made sense to dismiss the action without prejudice so that, if necessary, Plaintiff could resurrect her action quickly; and (2) Defendant failed to establish that Plaintiff should be sanctioned with a dismissal of her proceeding with prejudice for her failure to appear for a deposition. View "Lear v. Jamrogowicz" on Justia Law

By decree of the district court, the marriage of Husband and Wife was dissolved. The decree also divided the marital estate. Husband appealed, challenging various aspects of the property division. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court (1) did not err in valuing the estate as of 2009 instead of 2002, when the parties separated; (2) did not err in its valuation of businesses owned or partly owned by Husband; (3) erred by failing to award Husband an offset credit for thousands of dollars paid to Wife between 2002 and 2009; and (4) erred by ordering that Husband pay $1.259 million equalization payment to Wife without providing a method of payment. Remanded for adoption of a reasonable payment plan for payment of the large equalization payment. View "Schwartz v. Harris" on Justia Law

After a jury trial, Defendant was found guilty of one count of deliberate homicide and one count of aggravated assault. The Supreme Court affirmed, holding (1) the district court did not err by excluding evidence of justifiable use of force as a defense to the charge of deliberate homicide; and (2) the Court declined to exercise plain error review of Defendant's claims that the district court erred by excluding evidence of the victim's prior mental health history, suicide attempts, and cutting behavior, and that this exclusion violated Defendant's Sixth Amendment right to compulsory process and confrontation and Fourteenth Amendment right to due process. View "State v. King" on Justia Law

Plaintiffs leased an apartment from Defendant for thirteen months. Before the lease term expired, a dispute arose between the parties. Plaintiffs subsequently filed a complaint against Defendant, alleging breach of the terms of the lease, negligence, and negligence per se. The justice court found in favor of Plaintiffs. Defendant appealed, seeing a trial de novo. After a bench trial, the district court ruled in Plaintiffs' favor on their breach of lease claim and awarded them damages, costs, and attorney's fees. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it allowed Plaintiffs to amend their complaint to add a claim that had not been pled during the justice court proceedings; (2) the district court did not abuse its discretion when it denied Defendant's motion in limine to prohibit any reference to the testimony and evidence presented during the justice court proceedings; and (3) because the district court's references to the prior proceedings did not suggest that the district court was unduly influenced by the justice court proceedings, Defendant was not denied her right to a trial de novo. View "McDunn v. Arnold" 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

Paula Ehrmantraut-Kiosee sought tax deductions for educational expenses incurred in pursuit of a doctoral degree in psychology. The Montana Department of Revenue disallowed the deductions sought by Paula individually in 2007, and jointly with Randy Myrup in 2008 and 2009. The Office of Dispute Resolution affirmed the disallowance, and the State Tax Appeal Board (STAB) upheld the disallowance. The district court denied Taxpayers' petition for judicial review. After noting that educational expenses will be deemed nondeductible as qualification for a new trade or business if the education is a step towards obtaining a certification that, once obtained, would qualify the taxpayer to perform tasks significantly different from those the taxpayer performed before receiving the education, the Supreme Court affirmed, holding (1) the findings of STAB and the district court that Paula pursued her education in an effort to become a clinical psychologist, rather than simply to improve her skills as a counselor, were supported by substantial evidence; and (2) therefore, Taxpayers failed to demonstrate that the educational expenses were deductible under either 26 C.F.R. 1.162-5(a)(1) or (2). View "Myrup v. State, Dep't of Revenue" on Justia Law

Petitioner served two terms as a Public Service Commissioner (PSC). While serving his first term at the PSC, Respondent, campaign manager for Petitioner's opponent in the upcoming election, filed four complaints against Petitioner with the Commissioner of Political Practices (Commissioner), alleging that Petitioner had violated the statutory Code of Ethics by accepting gifts of substantial value from two corporations with which the PSC regularly dealt and by using state resources to aid his reelection campaign and for personal business. Following a three-day hearing on Respondent's complaints, a hearing examiner determined that Petitioner violated Mont. Code Ann. 2-2-104 two times by receiving "gifts of substantial value" and violated Mont. Code Ann. 2-2-121 five times by using state facilities and equipment for election purposes. The Commissioner affirmed, ordering Petitioner to pay $5,750 in fines and $14,945 for the costs of the hearing. The district court affirmed. The Supreme Court affirmed, holding that the district court did not err by concluding (1) Respondent had legal standing to file ethics complaints against Petitioner; (2) Petitioner received unlawful gifts; (3) Petitioner improperly used State facilities for political purposes; and (4) the penalty statute for ethics violations was not unconstitutionally vague. View "Molnar v. Fox" on Justia Law