Justia Montana Supreme Court Opinion Summaries

Mother was an enrolled member of the Chippewa Cree Tribe. Her two minor children both qualified as Indian children under the Indian Child Welfare Act (ICWA). After the Department of Public Health and Human Services was granted temporary legal custody of the children, the county attorney filed a petition requesting termination of Mother's parental rights due to failure to comply with a court-ordered treatment plan. At the conclusion of the hearing, the district court terminated Mother's parental rights. Mother appealed, alleging that the court terminated her parental rights without following the requirements of the ICWA. The Supreme Court reversed and remanded for a new termination hearing, holding that the termination proceedings did not comply with the mandates of ICWA and its parallel state provisions. View "In re K.B." on Justia Law

Following a jury trial, Defendant was convicted of felony DUI. The trial was held after several delays. Defendant was sentenced as a persistent felony offender to twenty years imprisonment with ten years suspended and ordered to pay restitution. Defendant appealed the district court's denial of his motion to dismiss based on an alleged violation of his speedy trial rights. The Supreme Court affirmed, holding that the district court (1) provided sufficient findings of fact and conclusions of law to enable appellate review of Defendant's speedy trial arguments; and (2) did not err in concluding that Defendant's speedy trial rights had not been violated under the circumstances. View "State v. Stops" on Justia Law

After a jury trial in 1984, Defendant was convicted of deliberate homicide and sentenced to 100 years imprisonment without the possibility of parole. In 2008, Defendant filed a second petition for postconviction relief, alleging that newly discovered evidence proved his actual innocence. The district court held a three-day hearing and took testimony from witnesses that suggested a group of teenage girls had killed the victim. The district court subsequently concluded that Defendant had presented sufficient evidence of his "actual innocence" to warrant a new trial. The Supreme Court reversed and dismissed Defendant's petition for postconviction relief, holding that the district court erred by concluding that Defendant was entitled to a new trial, as, applying the proper standard of review to the new evidence offered by Defendant, Defendant failed to sustain his burden of demonstrating either a freestanding claim or a gateway claim of "actual innocence." View "State v. Beach" on Justia Law

Mother and Father were divorced pursuant to a decree of dissolution entered in 1995. The decree required Father to pay child support until the parties' daughter "reaches majority, graduates from high school or is otherwise emancipated." Father paid child support of $6,977 per month for over ten years, until the daughter's eighteenth birthday. In 2012, Mother filed a petition seeking additional child support payments for the period between their daughter's eighteenth birthday in November 2006 and her graduation in July 2007. The district court granted the petition, concluding that Father's child support obligation did not terminate until the daughter graduated from high school. The Supreme Court affirmed, holding (1) since the decree of dissolution did not expressly provide the termination date for child support payments, Mont. Code Ann. 40-4-208(5) controlled and provided for a termination date upon the daughter's graduation from high school; and (2) the doctrine of equitable estoppel did not apply to preclude Mother's claim for back child support. View "In re Marriage of Pfeifer" on Justia Law

Plaintiff law firm filed a complaint alleging that Defendants and Plaintiff had previously entered into a contract for legal services and that Defendants breached this contract by failing to fully pay for the legal services performed by Plaintiff. Defendants failed to file an answer or otherwise appear within the required time period, and the district court subsequently entered an order of default judgment against Defendants. Defendants filed a motion to vacate the entry of default some nine months later. The district court denied the motion as untimely. The Supreme Court affirmed, holding (1) the district court did not slightly abuse its discretion in denying Defendants' motion to vacate its entry of default judgment; (2) the district court did not err by awarding attorney fees and costs to Plaintiff; and (3) consideration of Defendants' appeal of the court's denial of Defendants' motions seeking to alter or set aside the court's earlier denial of Defendants' motion to vacate the entry of default judgment was barred. View "Wittich v. O'Connell " on Justia Law

Margaret Howard was driving south and John Bradford was driving north on a two-lane highway when the two vehicles collided. Neither Margaret nor John survived. The Howards, the co-personal representatives of Margaret's estate, filed a wrongful death and survivorship action against the Bradfords, the co-personal representatives of John's estate, alleging negligence. A jury found that John was not liable in negligence for the death of Margaret. The Supreme Court affirmed, holding (1) the district court did not err ruling that a defense expert's testimony was supported by an adequate factual foundation and by determining that the scientific method used by the expert to reconstruct the accident was reliable and admissible; (2) the Bradfords did not violate the Montana Rules of Civil Procedure by failing to supplement the disclosure of the defense expert; and (3) the district court did not err by denying the Howards' motion for a new trial View "Wheaton v. Bradford" on Justia Law

This matter arose from the suicide of a sixteen-year-old girl, who was residing at the Spring Creek Lodge Academy at the time of her death. Following the girl's death, her mother, Plaintiff, brought an action against the owner of the school, its on-site directors, including Teen Help, and various related entities. Claims against Teen Help were settled before trial, and the settlement was later reduced to a judgment. While Newman I proceeded to trial, Newman filed this declaratory judgment and breach of contract action against Teen Help's two insurers to collect on the settlement and judgment, arguing that the insurers breached their obligation to defend and indemnify Teen Help in Newman I. The district court determined the insurers were severally liable for the underlying judgment and awarded attorney's fees and interest on the underlying judgment. The Supreme Court (1) affirmed the district court's judgment as it pertained to the insurers, its award of interest on the underlying judgment, and its application of Montana law; and (2) reversed the court's ruling on attorney's fees. Remanded for recalculation of reasonable attorney's fees. View "Newman v. Scottsdale Ins. Co." on Justia Law

Mother and Father divorced in 2002 when their children were approximately fifteen, twelve, and two years old. Afterward, the children resided at different times with either Mother or Father. Therefore, both Mother and Father were at times obligated to the other for child support. Since their divorce, the parties were engaged in years of litigation against each other. This appeal challenged the legal conclusions set forth in the district court's 2012 order regarding child support arrearage. The parties had failed to timely pay their child support obligations each other, which resulted in an arrearage on the part of both parents. The district court determined that Father's child support arrearage was to be offset against Mother's larger child support arrearage and that the remaining marital debt owed by Father had been discharged in bankruptcy court in 2011. The Supreme Court (1) reversed the district court's calculations of the interest on both parties' arrearages; and (2) otherwise affirmed. Remanded. View "In re Marriage of Steab" on Justia Law

The district court granted temporary legal custody of two young children to the Department of Public Health and Human Services after Mother was arrested on criminal charges. The Department subsequently filed a petition to terminate Mother's parental rights. After adjudicating the children as neglected and youths in need of care, the district court terminated Mother's parental rights without requiring reunification efforts or a treatment plan. The Supreme Court affirmed, holding that the district court did not abuse its discretion in concluding that reunification efforts and another treatment plan were not in the children's best interests and terminating Mother's parental rights. View "In re E.Z.C." on Justia Law

Wife filed a petition for dissolution of her marriage to Husband in the district court. The matter subsequently came before a standing master. After a hearing, the standing master issued her findings of fact, conclusions of law, and final decree of dissolution, which incorporated by reference a final parenting plan. After the final decree was entered, Husband appealed. However, Husband did not file any objections in the district court to the standing master's findings and conclusions within the ten-day period prescribed by Mont. Code Ann. 3-5-126(2). The Supreme Court dismissed Husband's appeal without prejudice, holding that section 3-5-126(2) and the district court's standing order required that Husband, as a prerequisite for perfecting his appeal to the Court, first file specific objections in the district court to the standing master's findings of fact, conclusions of law, and final decree of dissolution. View "Beals v. Beals" on Justia Law