Justia Montana Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of attempted theft and sentenced to ten years imprisonment. Defendant appealed, arguing that the district court abused its discretion in finding a sufficient chain of custody for the admission of latent fingerprint evidence and forensic analysis. At issue was two fingerprint cards used to take the prints. In specific, in contention was discrepancies between dates written on the back of the cards and their storage in a law enforcement officer's patrol car and office. The Supreme Court affirmed, holding that because the State adequately established the chain of custody of the prints cards, the district court did not abuse its discretion by admitting the latent print evidence. View "State v. McCoy" on Justia Law

In December 2004, Plaintiff, an on-duty law enforcement officer with the Federal Reserve Bank, was injured in an altercation on the bank premises with Defendant, who had trespassed onto the Federal Reserve property while intoxicated. In March 2009, Plaintiff sued for negligence. Defendant moved for summary judgment, arguing that the three-year statute of limitations expired by the time the complaint was filed. The district court granted Defendant's motion. The Supreme Court reversed, holding that the district court erred in granting summary judgment in favor of Defendant, as the evidence of when the statute of limitations began to run on Plaintiff's claim against Defendant was conflicting. Remanded for trial. View "Siebken v. Voderberg" on Justia Law

An underground mine with surface facilities located in Musselshell County (Musselshell) extended underground into Yellowstone County (Yellowstone) and produced coal mined from both Musselshell and Yellowstone. Based upon a report of the counties from which the coal was mined, the Department of Revenue allocated approximately two-thirds of the mine's taxable coal gross proceeds to Musselshell, for a tax of $328,617, and the remainder to Yellowstone, for a tax of $126,909. Musselshell sued Yellowstone and the Department seeking a declaratory judgment that the Department wrongfully allocated a portion of the tax to Yellowstone. The district court upheld the Department's apportionment of the tax between the two counties, holding that Montana law contemplates taxation of the gross proceeds of coal in the county where the coal is mined and that the Department was not required to adopt administrative rules prior to apportioning the tax. The Supreme Court affirmed, holding that the Department correctly apportioned the coal gross proceeds tax from the mine between Musselshell and Yellowstone and was not required by law to create an administrative rule before making that apportionment. View "Musselshell County v. Yellowstone County" on Justia Law

After the district court awarded the Department of Health and Human Services temporary legal custody of Mother's two children, the court adjudicated the children as youths in need of care. The State subsequently petitioned to terminate Mother's parental rights. After a termination hearing, the district court concluded it was in the children's best interests to terminate Mother's parental rights and issued an order to that effect. The Supreme Court affirmed the district court's order, holding that the court did not abuse its discretion in concluding that the State established by clear and convincing evidence that the best interests of the children would be served by termination of the parent-child legal relationship. View "In re H.R." on Justia Law

Decedent's will divided his estate among his wife (Wife) and his sons and left to Wife all of their jointly-owned vehicles and other property. At the time of Decedent's death he and Wife owned a motor home as joint tenants with the right of survivorship. There was an outstanding purchase money security interest on the motor home, and both Decedent and Wife signed the loan document, which specifically provided that each of them was independently obligated for the full amount of the debt. Wife filed a claim against Decedent's Estate for one half the debt on the motor home. The Estate's Personal Representative denied Wife's claim. The district court (1) applied a majority common-law rule from other states providing that Decedent's estate has an equitable duty to pay its aliquot share of debts on such jointly-held property, and (2) held the equitable outcome was to allow Wife's claim against the Estate. The Supreme Court reversed, holding that the district court erred in concluding that Montana law would, as a matter of equity under common law, require Decedent's Estate to pay half of the outstanding security interest in the motor home that became Wife's sole property upon Decedent's death. View "In re Estate of Afrank" on Justia Law

Plaintiffs in this case were individuals who were in committed same-sex relationships. Plaintiffs sued the State, contending that there was a statutory structure in Montana law that prohibited them from enjoying significant relationships and family protections and obligations provided to similarly-situated different-sex couples who marry. Plaintiffs expressly did not challenge Montana law's restriction of marriage to heterosexual couples and did not seek the opportunity to marry. Instead, Plaintiffs sought a declaration that the State's failure to provide them access to the statutory scheme available to different-sex couples denied them the rights guaranteed by Mont. Const. art II. The district court granted the State's motion to dismiss, noting that Plaintiffs did not seek the declaration of the unconstitutionality of a specific statute but rather a direction to the legislature to enact a statutory arrangement, which was unprecedented in Montana law. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the district court did not err in finding Plaintiffs' requested relief exceeded the bounds of a justiciable controversy; but (2) Plaintiffs should be afforded the opportunity to amend their complaint. View "Donaldson v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual intercourse without consent and one count of sexual assault. Defendant appealed. The Supreme Court affirmed, holding (1) under the circumstances presented here, the district court's application of Montana's rape shield statute did not violate Defendant's right to a fair trial under the Montana and United States Constitutions; and (2) the district court did not err in refusing to dismiss Counts I and IV on grounds that the State failed to prove venue, as the State showed that the only rational conclusion to be drawn from the facts and testimony was that the crime was committed in the county alleged. View "State v. Patterson" on Justia Law

Defendant pled guilty to the felony offense of criminal possession with intent to distribute. The district court sentenced him to a three-year deferred imposition of sentence. Defendant appealed his conviction and sentence, contending that the district court erred in denying his motion to suppress and dismiss because a drug task force agent did not have probable cause to believe a crime was occurring in his residence, and thus there was no basis for the agent to contact Defendant and request to search his residence. The Supreme Court affirmed, holding that the district court properly denied Defendant's motion to suppress and dismiss, as (1) the information Defendant's neighbor provided to law enforcement officers was reliable; and (2) the court's findings regarding Defendant's consent to the initial search of his home and the court's findings regarding the validity of the search warrant were supported by substantial credible evidence and were not clearly erroneous. View "State v. Deshaw" on Justia Law

Plaintiff gave birth to Child at Hospital. Complications arose prior to and after Child's delivery, leading to problems with Child's brain development. Plaintiff, individually and on behalf of Child, later sued the doctor who delivered Child and Hospital. Plaintiff subsequently settled her claims with the doctor. The district court granted summary judgment to Hospital on all of Plaintiff's claims. This appeal arose out of pre-trial rulings made by the district court in Plaintiff's litigation with Hospital. The Supreme Court affirmed, holding that the district court did not err in (1) extending discovery deadlines; (2) granting summary judgment to Hospital on Plaintiff's agency claims; (3) granting summary judgment to Hospital on Plaintiff's Consumer Protection Act Claim; (4) granting summary judgment to Hospital on Plaintiff's joint venture claim; and (5) granting summary judgment to Hospital on Plaintiff's negligent credentialing claim. View "Brookins v. Mote" on Justia Law

After a youth violated the terms of his initial probation agreement, the judicial district youth court revoked that agreement and entered a dispositional order that extended the youth's probationary period for an additional three years. The youth appealed. The Supreme Court affirmed, holding (1) the youth court did not exceed its statutory authority and correctly and interpreted and applied the Youth Court Act by imposing on revocation an additional three-year probationary term that lasted until the youth's twenty-first birthday; and (2) the imposition of an additional three-year term of probation did not violate the youth's constitutional right to equal protection of the laws. View "In re S.M.K." on Justia Law