Justia Montana Supreme Court Opinion Summaries

Defendant's vehicle hit Brian Beaver from behind, and Beaver died from severe blunt force trauma to his head. Defendant was assigned a public defender for his criminal case. Eight days before his trial, Defendant provided the district court with a pro se motion for appointment of different counsel, claiming that appointed counsel's representation was deficient. Defendant also filed a request for a continuance so that he could retain private counsel. The court denied Defendant's request for substitution of counsel, determining that counsel was providing adequate representation. The court also denied Defendant's motion to continue, determining that Defendant had lacked diligence in seeking private counsel. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by finding that Defendant's counsel was providing effective assistance of counsel; and (2) did not abuse its discretion in determining that Defendant had not made a good faith, diligent effort to retain substitute counsel. View "State v. Holm" on Justia Law

After a jury trial, Defendant was found guilty of felony aggravated assault and misdemeanor unlawful restraint. Defendant subsequently filed a petition for postconviction relief, raising twelve issues. The district court determined that Defendant's petition did not demonstrate any kind of error, cumulative or otherwise, and dismissed the petition. Defendant appealed pro se to the Supreme Court. The Supreme Court affirmed, holding that the district court did not err in finding that Defendant did not meet his burden of establishing that any error of his pre-trial and trial counsel prejudiced his right to a fair trial. View "Rukes v. State" on Justia Law

In 2012, the Yellowstone County Attorney's Office filed a petition for involuntary commitment of Appellant. After an evidentiary hearing, the district court determined that Appellant met the statutory criteria for involuntary commitment and involuntarily committed Appellant to the Montana State Hospital. The Supreme Court affirmed, holding (1) there was sufficient evidence presented for the district court to determine that Appellant required commitment because he was unable to care for his basic needs and presented an imminent threat of injury to himself or others; and (2) Appellant failed to make a substantial showing that his trial counsel was ineffective. View "In re R.F." on Justia Law

Child was born with numerous medical issues and hospitalized for the first three months of his life. The suspected cause of Child's medical problems was maternal drug use. The Department of Public Health and Human Services filed a petition to adjudicate Child as a youth in need of care. After an adjudicatory hearing, the district court found, based upon a preponderance of the evidence, that Child was a youth in need of care. The district court then awarded custody of Child to Father. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in finding that Child was a youth in need of care; and (2) did not err when it granted custody of Child to Father. View "In re M.J." on Justia Law

Plaintiff filed a complaint against Judge Deborah Christopher (Judge), alleging that Judge violated a number of his constitutional rights. The district court granted Judge's motion for summary judgment, concluding that Judge was entitled to judicial immunity from Plaintiff's claims. The district court also determined that Plaintiff's claims were barred by the doctrine of res judicata and collateral estoppel after taking judicial notice of a U.S. district court complaint filed by Plaintiff against Judge, among other defendants. The Supreme Court affirmed, holding (1) the district court properly granted Judge judicial immunity from Plaintiff's claims; and (2) the doctrine of res judicata barred Plaintiff from relitigating his claims. View "Hartsoe v. Christopher" on Justia Law

Wife petitioned the district court for dissolution of her marriage to Husband, who was incarcerated. Husband proceeded as a self-represented litigant, and the district court allowed Husband to appear telephonically at all hearings. When the final pretrial conference was held, Husband did not appear telephonically. Unbeknownst to the district court, Husband was experiencing medical problems that required surgery and hospitalization. After Husband was released from the prison infirmary, he mailed a motion to the district court requesting a sixty-day continuance. The district court received the motion, but after Husband failed to appear at a hearing to consider the motion, the court entered a default decree and declared the parties' marriage dissolved. The Supreme Court reversed, holding that under these extraordinary circumstances, the district court abused its discretion in refusing to grant Husband's motion for a continuance. Remanded to allow Husband to appear at a final pretrial conference and trial. View "Eslick v. Eslick" on Justia Law

Plaintiff and her minor daughter were injured when their vehicle was involved in a collision with a pickup truck driven by Michael Morris, Jr. (Son), a Glacier County resident. The pickup truck was owned by Michael Morris, Sr. (Father), a Teton County resident. The collision occurred in Teton County but Plaintiff's vehicle was propelled across the county line and came to rest in Cascade County. Plaintiff filed a complaint in Cascade County against both men, claiming Son was negligent in his operation of the vehicle and Father negligently entrusted Son with the pickup truck. Son moved to change the venue to either Glacier or Teton county. The district court granted the motion and moved the proceeding to Glacier County. The Supreme Court affirmed, holding that the district court did not err in finding that Cascade County was an improper place for trial, as the tort was not committed in Cascade County and Defendants lived in Teton and Glacier counties. View "Yeager v. Morris" on Justia Law

Plaintiffs were a group of landowners who owned properties abutting South Avenue in the City of Missoula. This lawsuit arose out of dispute between Plaintiffs and the City concerning the width of a public right-of-way constituting South Avenue. Following a bench trial, the district court determined that the right-of-way was sixty feet wide. Because the City's recent improvements to South Avenue extended beyond this sixty-foot parameter, the district court concluded that the City had effected a taking of property and awarded Plaintiffs compensation for the taking as well as their requested costs and attorney's fees. The Supreme Court affirmed the district court on all but two issues, holding that the district court (1) applied an incorrect measure of compensation; and (2) erroneously barred Plaintiffs' counsel from passing on to his clients the costs and fees incurred in proving underlying litigation expenses other than attorney's fees. Remanded. View "Wohl v. City of Missoula" on Justia Law

This case stemmed from a gun fight between Defendant and Michael Peters. Defendant was convicted of attempted deliberate homicide with a weapon. The Supreme Court reversed and remanded for a new trial upon finding that prosecutorial comments regarding Defendant's post-Miranda silence constituted plain error. After the Court remanded the case, the district court held several pre-trial hearings and ruled on various motions. After a jury trial, Defendant was convicted of attempted deliberate homicide. The Supreme Court affirmed, holding that the district court (1) did not err by denying Defendant's motion to dismiss for negligent destruction of exculpatory evidence; and (2) did not err in limiting Defendant's cross-examination of a State's witness. View "State v. Wagner" on Justia Law

A peace officer stopped a vehicle Defendant was driving due to the vehicle's excessive speed and a report of drug trafficking. During the stop, the officer had Defendant exit the vehicle so the officer could detect whether the odor of marijuana was present. A large quantity of marijuana was ultimately discovered in the vehicle. The State charged Defendant with felony criminal possession of dangerous drugs. Defendant unsuccessfully filed a motion to suppress the evidence, arguing that the officer had unlawfully extended the scope of the stop by requiring Defendant to exit the vehicle. Defendant pled guilty to the charge, reserving the right to appeal the denial of his motion. The Supreme Court affirmed, holding that the district court correctly denied Defendant's motion to suppress, as the officer's requirement that Defendant exit the vehicle during the traffic stop did not violate Defendant's constitutional right against unreasonable searches and seizures. View "State v. Roy" on Justia Law