Justia Montana Supreme Court Opinion Summaries

In 2006, Plaintiffs sustained serious injuries in an automobile accident and incurred medical expenses in excess of $1,000,000. Plaintiffs subsequently learned that they had only $5,000 in medical payments coverage and did not have any underinsured motorist (UIM) coverage after a transfer of their Oregon State Farm policy to Montana by the Mark Olson State Farm Agency. The driver who caused the accident carried the statutory minimum automobile liability insurance limits. Plaintiffs sued State Farm and Mark Olson, requesting declaratory relief and a reformation of the contract and alleging negligence, breach of fiduciary duty, and conduct sufficient to support an award of punitive damages. The district court entered summary judgment in favor of Defendants. The Supreme Court reversed, holding that the district court erred in entered summary judgment in favor of State Farm and Olson on Plaintiffs' negligence claims. Remanded for trial. View "Bailey v. State Farm Auto. Ins. Co." on Justia Law

Defendant pleaded guilty to unlawful possession of an open alcoholic beverage container in a motor vehicle, failure to drive on the right side of a roadway, and driving under the influence of alcohol. The district court subsequently granted Defendant's motion to suppress evidence. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) incorrectly concluded that, because the arresting officer did not follow Mont. Code Ann. 46-6-312, all evidence gathered after Defendant's arrest should be suppressed because the arrest was lawful; (2) incorrectly concluded that the arresting officer's failure to advise Defendant of her Miranda rights at the time of arrest required suppression of all evidence obtained after her arrest with the exception of two self-incriminating statements Defendant made in response to the officer's questions after he placed her in the patrol vehicle; and (3) incorrectly concluded that evidence seized from Defendant's vehicle must be suppressed, as the plain view doctrine permitted seizure of the evidence. View "State v. Kelm" on Justia Law

After a jury trial, Defendant was convicted and sentenced for sexual assault. The Supreme Court affirmed the conviction, holding (1) the district court did not err by admitting into evidence a recored interview with the victim in violation of Defendant's confrontation rights or in contravention of Mont. R. Evid. 613(b); (2) there was sufficient evidence to support the conviction under the criteria set forth in State v. Yuhas; (3) the district court did not err in denying Defendant's motion for a new trial; and (4) Defendant's argument that his attorney provided ineffective assistance at trial should be raised in a petition for postconviction relief. View "State v. Baker" on Justia Law

The State petitioned for permanent legal custody and termination of Father's parental rights to his two children after the court held that the Indian Child Welfare Act (ICWA) applied and approved treatment plans for Father prepared by the State. The district court subsequently terminated Father's parental rights to the children. The Supreme Court affirmed, holding (1) Father's argument that the district court improperly concluded that Father's treatment plans were appropriate was not preserved for appellate review; and (2) the State presented sufficient evidence to terminate Father's parental rights under the ICWA where (i) a rational trier of fact could have concluded that the State made "active efforts" to provide services and programs designed to prevent the breakup of the Indian family and that those efforts were unsuccessful, and (ii) the State proved that the children would likely suffer serious emotional or physical harm if Father was to retain custody. View "In re D.S.B." on Justia Law

Appellant, the personal representative of the estate of Decedent, appealed from a final distribution order of the district court, which interpreted Decedent's last will and testament to devise the entirety of Decedent's real property to Appellee, Appellant's brother. The Supreme Court affirmed, holding that the district court did not err in (1) interpreting Decedent's will to determine that Decedent intended to devise to Appellee 528 acres subject to special farm property valuation; and (2) allowing Appellee to object to the personal representative's proposed distribution of income from the property subject to special farm property valuation more than thirty days after the proposed distribution was submitted for approval. View "Ecton v. Ecton" on Justia Law

Plaintiff worked for Employer as a construction site supervisor. When Plaintiff left Montana for a vacation, a group of employees complained about Plaintiff as their supervisor. After an investigation, Employer terminated Plaintiff's employment. Plaintiff filed an action alleging that Employer violated the Montana Wrongful Discharge from Employment Act. The district court granted summary judgment for Employer. The Supreme Court affirmed, holding (1) the district court properly concluded that Employer had good cause to terminate Plaintiff's employment; (2) Employer properly considered hearsay evidence in deciding to terminate Plaintiff's employment; (3) the district court properly considered employee statements contained in reports in concluding that Employer had good cause to terminate Plaintiff's employment; and (4) the district court properly concluded that Employer did not violate the provisions of its employee handbook when it terminated Plaintiff's employment. View "Sullivan v. Continental Constr. of Mont., LLC " on Justia Law

Plaintiff suffered an injury in the course and scope of her employment with Employer. Employer's insurer (Insurer) accepted liability for Plaintiff's injury and paid wage loss and medical benefits. Plaintiff was later informed that Insurer would no longer approve or cover the expense of the pain patches she had been using for several years. Plaintiff filed a petition for expedited declaratory relief to reinstate medical benefits, seeking reinstatement of medical benefits for the pain patches as well as attorneys' fees and penalties. The Workers Compensation Court (WCC) determined that Plaintiff was entitled to continued payment of benefits for the pain patches but denied Plaintiff's request for attorneys' fees and for payment of the statutory penalty. The Supreme Court affirmed, holding that the WCC did not err (1) in determining Plaintiff was entitled to continued payment for the pain patches; (2) in determining Plaintiff was not entitled to reimbursement for her attorneys' fees; and (3) when it failed to impose the statutory penalty on Insurer. View "Stewart v. Liberty Northwest Ins. Corp." on Justia Law

Defendant brought her seven-week-old son, John Doe, to a medical center for injuries. A jury later convicted Defendant of assault on a minor and aggravated assault. The district court ordered a change in parenting arrangements for John Doe as part of the criminal sentence despite pending dependency and neglect proceedings. As part of Defendant's sentence, the district court ordered Defendant to pay fees, costs, and surcharges without recording findings regarding Defendant's financial situation. The Supreme Court affirmed, holding (1) because Defendant had regained custody of John Doe through the civil proceeding, her claim regarding the imposition of a condition concerning the temporary custody of John Doe was moot; however, the statement in the court's written judgment that the father should be presumed to have custody of John Doe should not have been included in the criminal sentence; and (2) the district court acted within its discretion in imposing fees. View "State v. MacDonald" on Justia Law

After Maxine's family contributed financially to help her keep her house, Maxine transferred title of the property to the Maxine Lane Irrevocable Trust. The Trust Agreement provided that if the property was sold during Maxine's lifetime, $50,000 was to be paid to each of Maxine's brothers. Later, Maxine consented to the sale of the property, and the Trust received $176,469 in net proceeds. The Trustee indicated she was obligated to make $50,000 distributions to Maxine's brothers as stated in the Trust and then use the remaining proceeds for Maxine's support. Maxine filed a declaratory judgment action against the Trustee, asking the district court to determine whether the Trust required the sale proceeds to be used to purchase another residence for Maxine, or whether the Trust required the $50,000 distributions be made. The district court granted summary judgment to Linda, concluding that the Trust mandated the Trustee to make the distributions. The Supreme Court affirmed, holding that the district court correctly concluded the Trust Agreement required the Trust to make the $50,000 distributions upon the sale of the property. View "Lane v. Caler" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault, burglary, criminal endangerment, and assault on a peace officer, all felonies. Defendant appealed, arguing, among other things, that the Supreme Court should exercise plain error review of his argument that the convictions for aggravated assault and criminal endangerment violated statutory and constitutional double jeopardy protections. The Supreme Court affirmed, holding (1) sufficient evidence supported the aggravated assault conviction; (2) sufficient evidence supported the burglary conviction; and (3) charging both crimes of criminal endangerment and aggravated assault was not plain error under the facts of this case since different victims were involved. View "State v. Torres" on Justia Law