Justia Montana Supreme Court Opinion Summaries

After Respondent voluntarily admitted herself to the behavioral health unit of a hospital, Respondent requested to be discharged. However, the county attorney's office filed a petition requesting that Respondent be committed for further evaluation and treatment. The district court appointed a public defender to represent Respondent, and following a hearing on the petition for commitment, the court committed Respondent to the Montana State Hospital with a treatment order that included the involuntary administration of medication. The Supreme Court affirmed, holding (1) plaint error review of this issue was not warranted; and (2) Respondent was not denied the effective assistance of counsel during the hearing. View "In re J.S.W." on Justia Law

Plaintiff was driving her vehicle on a public highway when she was struck by a truck owned by Stockton Oil Company (Stockton) and driven by Ronald Gerber. Plaintiff filed a complaint against Stockton and Gerber seeking damages for the injuries she sustained as a result of the accident. Stockton was served but Gerber was not. Stockton did not respond to the complaint, and a default was subsequently entered against it in February 2011. A judgment for damages was entered in April 2011. In October 2011, Stockton moved to set aside the default judgment. Sixty-eight days later, the district court granted Stockton's motion. The Supreme Court reversed, holding that the district court (1) erred in granting Stockton's motion to set aside default judgment, as the court ignored the expiration of the sixty-day deadline in doing so; (2) thus, the motion was deemed denied by operation of law; and (3) the deemed denial did not constitute a slight abuse of discretion. Remanded for reinstatement of the default judgment. View "Green v. Gerber" on Justia Law

Defendant jointly owned real property as tenants in common with her sister, Plaintiff. Plaintiff filed a partition action, seeking equitable partition of the property or, in the alternative, a forced sale of the property and equal division of the net sale proceeds. Three partition referees appointed by the district court submitted a final report recommending that the property be divided into two parcels. Defendant presented offers of proof challenging the referees' final report, but the district court confirmed the proposed partition. Defendant appealed, arguing that the district court erred by denying her request for an evidentiary hearing. The Supreme Court reversed the district court's final partition judgment, holding (1) when a party makes a substantiated claim of factual or legal error in the referees' report, due process and equitable concerns require the district court to hold a hearing to determine whether the referees' report equitably divides the real property prior to confirming, changing, or modifying the report; and (2) in this case, Defendant's objections were sufficient to compel the district court to hold an evidentiary hearing. Remanded for an evidentiary hearing. View "Britton v. Brown" on Justia Law

Defendant pled guilty to one count of felony negligent vehicular assault and one count of felony criminal endangerment. The district court sentenced Defendant to the Department of Corrections for six years with eighteen months suspended on each count, to run concurrently, ordered Defendant to complete 100 hours of community service, and imposed twenty-nine enumerated conditions of probation. The Supreme Court affirmed, holding (1) the district court imposed a legal sentence on Defendant; (2) the district court did not impose unreasonable and unconstitutional probation conditions on Defendant; and (3) Defendant's argument that the sentence review division process was unconstitutional was not ripe for judicial determination. View "State v. Whalen" on Justia Law

Kristy Johnston, Judy Olsen, and their mother, Joyce Johnston, owned real property as tenants in common. Joyce left her one-third interest in the property to Kristy when she died. Kristy sent a letter to Judy in 2009 in which she offered to buy Judy's interest in the property or to sell her interest to Judy. Judy accepted Kristy's offer to sell. Kristy subsequently attempted to reject Judy's acceptance and revoke her offer to sell. Judy filed a complaint against Kristy. The court granted Judy's motion for summary judgment, determining that the letters exchanged between Judy and Kristy had created an enforceable contract that satisfied the statute of frauds. The Supreme Court affirmed, holding that the district court properly concluded that the parties' exchange of letters created an enforceable contract. View "Olsen v. Johnston" on Justia Law

Defendants in this suit included the St. Labre Indian Education Association, Inc. and the St. Labre Home for Indian Children and Youth (collectively, St. Labre). After St. Labre experienced a decrease in government funding, St. Labor began a fundraising campaign that NCT asserted resulted in millions of dollars donated to St. Labre through efforts that marketed the plight and need of NCT. NCT filed suit against Defendants alleging (1) St. Labre's fundraising system created a constructive trust on behalf of NCT and St. Labre wrongfully converted those funds to its own use, thus unjustly enriching itself; (2) contract and fraud type issues; and (3) St. Labre unconstitutionally committed cultural genocide against NCT. The district court dismissed all of NCT's motions. The Supreme Court (1) reversed the district court's grant of summary judgment on NCT's claim for unjust enrichment and the imposition of a constructive trust that may arise from St. Labre's fundraising activities after 2002; (2) reversed the district court's grant of summary judgment regarding St. Labre's fundraising activities before 2002; and (3) affirmed the court's grant of summary judgment on all of NCT's remaining claims. View "N. Cheyenne Tribe v. Roman Catholic Church" on Justia Law

Larissa Simpson filed a petition for dissolution of her marriage to Dennis, citing serious marital discord. As part of the dissolution, Dennis and Larissa entered into a property settlement agreement and a stipulated final parenting plan. The combined operation of the plan and the agreement entitled Larissa to a $10,000 per month payment from Dennis for the rest of her life, first in child support and later in the form of a property settlement. Later, Dennis and Larissa agreed to amend the court's final decree. The stipulation did not decrease Dennis's total month child support obligation. Dennis subsequently filed a motion to modify child support, alleging that the child support amount was unconscionable in light of changed circumstances. Larissa also filed a motion to invalidate the parties' stipulation amending the final decree. Both motions were denied. The Supreme Court affirmed, holding that the district court did not err in denying Dennis's motion to modify child support and Larissa's motion to invalidate the stipulation. View "Simpson v. Simpson" on Justia Law

Plaintiff worked as the manager of Defendant's automotive services and repair facility for more than one year. During his tenure, Plaintiff worked 819 hours in overtime but did not receive overtime pay under his employment contract. After Plaintiff resigned his employment, he filed a claim for overtime pay with the Department of Labor and Industry. The Department denied the claim. The district court affirmed. The Supreme Court affirmed, holding that the district court (1) did not err by concluding that Defendant did not waive its argument that Plaintiff was exempt from overtime pay as a "salesman" under 29 U.S.C. 213(b)(10); and (2) did not err by concluding that Plaintiff was not entitled to overtime pay under the Fair Labor Standards Act and the Montana Wage Protection Act. View "Thompson v. J.C. Billion, Inc." on Justia Law

The State charged Defendant with felony driving under the influence of alcohol and careless driving. The State filed notice that it intended to seek persistent felony offender status for Defendant due to Defendant's previous conviction for felony DUI. Defendant's attorney objected to the proposed designation, and the district court denied the objection. Defendant subsequently pled guilty to the felony DUI charge. After a bench trial, Defendant was convicted on the careless driving charge. The district court sentenced Defendant to ten years in prison as a persistent felony offender based on the felony DUI and to thirty days in jail on the careless driving conviction. The Supreme Court (1) affirmed the sentence for felony DUI as a persistent felony offender, holding that the sentence was lawful; but (2) reversed the jail time sentence for the careless driving conviction and remanded with instructions to strike the jail time because the district court exceeded its authority when it imposed the sentence. View "State v. Kime" on Justia Law

Tamara Lucas and her husband James brought a legal malpractice claim against attorney Mat Stevenson after they hired Stevenson to defend James against criminal charges and to represent them in a civil suit against the city police department, the city, and individual police officers that arrested James for disturbing the peace and felony assault on a peace officer. However, Stevenson later learned that the Lucases had previously filed for bankruptcy. The civil suit was determined to an asset of the bankruptcy estate, and Stevenson was reassigned to pursue the case on behalf of the bankruptcy estate. After a settlement agreement was reached, the Lucases brought this action against Stevenson. The district court granted summary judgment in favor of Stevenson. The Supreme Court affirmed, holding that the district court correctly determined (1) the Lucases' civil claims were properly determined to be an asset of the bankruptcy estate; and (2) Stevenson did not represent the Lucases at the time the claims were settled, and therefore, the Lucases had no standing to bring a legal malpractice claim against him. View "Lucas v. Stevenson" on Justia Law