Justia Montana Supreme Court Opinion Summaries

In 2011, Amber Crowley filed a petition for dissolution of her marriage to Dennis Crowley. In 2012, the district court entered a final decree of dissolution and a final parenting plan. Dennis appealed, challenging many of the trial court’s determinations. The Supreme Court (1) reversed the district court’s apportionment of property and remanded for further findings of fact, holding that the district court’s findings were insufficient for the Court to determine whether all of the parties’ assets and liabilities were properly considered; (2) affirmed the court’s award of arrears for past due family support; (3) reversed the court’s maintenance order and remanded for further findings, holding that the court’s brief findings did not sufficiently address the statutory factors; (4) affirmed the court’s determination to award primary residential custody of the parties’ child to Amber; and (5) reversed the court’s order requiring Dennis to pay costs and attorney’s fees, holding that the evidence was not sufficient to support a determination that the requested fees were reasonable. View "In re Marriage of Crowley" on Justia Law

In 2012, Mother and Father divorced. The decree of dissolution provided that the couple’s two children would reside permanently with Mother. In 2013, Mother died in a fire. The children’s maternal grandmother (Grandmother) immediately took control of the children. Father subsequently filed a petition for exclusive parental control, and Grandmother requested that she be awarded a parental interest in the children. The district court entered an order granting Father exclusive parental control and authority over the children, concluding that Grandmother had not established a parent-child relationship between her and the children. The Supreme Court affirmed, holding that the district court’s decision was supported by substantial, credible evidence. View "Hansen v. Moats" on Justia Law

In 2007 and 2008, Defendant was convicted of four felonies. In 2010, Defendant absconded from a pre-release center. Several months later, Defendant was extradited from Idaho to Montana. Defendant pled guilty to escape. Defendant was sentenced to ten years imprisonment and ordered to pay restitution to the State for the costs incurred in extraditing him back to Montana from Idaho. On appeal, Defendant challenged the restitution requirement. The Supreme Court reversed, holding that the district court erred when it ordered Defendant to pay restitution to the State for expenses incurred in extraditing him from Idaho to Montana, as the court lacked the statutory authority to impose restitution for extradition costs. View "State v. Macy" on Justia Law

Plaintiff, a self-represented litigant, filed a complaint against Defendant for defamation. Defendant filed a motion for summary judgment, and Plaintiff did not file a brief in response. The district court granted Defendant’s motion for summary judgment due to Plaintiff’s failure to respond. Plaintiff sought relief under Mont. R. Civ. P. 60(b)(1) for excusable neglect because she “simply forgot to file the brief.” The court denied Plaintiff’s motion, concluding that all litigants should adhere to procedural rules and that Plaintiff was familiar with the rules of the court. The Supreme Court affirmed, holding that the district court did not err in granting Defendant summary judgment, and therefore, the Court need not reach the second issue raised by Plaintiff of whether the district court abused its discretion in denying her Rule 60(b) motion. View "Chapman v. Maxwell" on Justia Law

At issue in this case was a petition challenging the legal sufficiency of LR-126, a referendum passed by the Legislature that would eliminate election-day voter registration and require all electors to register or to change their voter registration information by 5 p.m. on the last Friday preceding election day. The Legislature directed that the measure be placed on the ballot at the November 2014 general election. Petitioners contended that the title of the bill, which will appear on the ballot, was inaccurate and misleading. The Supreme Court (1) denied Petitioners’ request to declare LR-126 legally deficient and void and order its removal from the ballot; but (2) ordered the Attorney General to clarify the bill title’s reference to the National Voter Registration Act. View "MEA-MFT v. Fox" on Justia Law

After K.L. was removed from her parents’ custody, K.L. was adjudicated a youth in need of care, and the Department of Public Health and Human Services (Department) petitioned to terminate the parental rights of both parents. After a hearing, the district court terminated the parents’ rights to K.L. Both parents appealed the order of termination. The Supreme Court affirmed, holding that the district court did not abuse its discretion in (1) granting the Department’s motion for an extension of temporary legal custody over K.L; (2) terminating Father’s parental rights after finding that the condition rendering Father unfit to parent was unlikely to change within a reasonable time; and (3) terminating Mother’s parental rights. View "In re K.L." on Justia Law

Between December 11, 2011 and January 1, 2012, the Billings Police Department responded to more than 200 reports of vandalism. B.W., a youth, admitted to having committed acts of vandalism on December 22, 2011 and December 29, 2011. The youth court adjudicated B.W. a delinquent youth for having committed criminal mischief, common scheme and ordered B.W. to pay $78,702 in restitution, which represented the total damages sustained over the eleven-day vandalism spree. The Supreme Court reversed, holding that the youth court erred in concluding that B.W. was jointly and severally liable for the full amount of restitution for damages where the State did not establish that B.W. was accountable for the crimes of others in which Defendant did not participate. Remanded for a new restitution hearing. View "In re B.W." on Justia Law

After a jury trial, Defendant was convicted of accountability to burglary and theft. The Supreme Court affirmed Defendant’s conviction and sentence for accountability to burglary and reversed Defendant’s conviction for theft, holding (1) the district court did not err by instructing the jury on the theory of accountability when the State had not directly charged an accountability based offense, as the circumstances surrounding the trial put Defendant on notice that the State would pursue an accountability theory; (2) defense counsel’s submission of a jury instruction defining “purposely” in Montana’s accountability statute as a conduct-based rather than result-based mental state resulted in no prejudice to Defendant’s position at trial; and (3) defense counsel rendered ineffective assistance by failing to object to Defendant’s theft conviction on the grounds that it violated Montana’s statutory restriction on multiple charges. View "State v. Tellegen" on Justia Law

On November 26, 2011, the State charged Defendant with five misdemeanor offenses. On June 13, 2012, Defendant moved to dismiss the case on the ground that trial was being held beyond the six-month deadline imposed by Mont. Code Ann. 46-13-4013(2). The justice court denied Defendant’s motion, reasoning that good cause existed for holding Defendant’s trial past the deadline. The district court affirmed. The Supreme Court affirmed, holding that the lower courts did not err in finding that good cause existed for holding Defendant’s trial eight days past the six-month deadline. View "State v. Luke" on Justia Law

Morrison-Maierle, Inc. (MMI) was hired by two counties to provide engineering services and supervision on a road improvement contract. The counties retained JEM Contracting, Inc. (JEM) to provide the construction services on the project. JEM filed suit against MMI alleging detrimental reliance and fraudulent inducement for promises MMI allegedly made during the job that JEM would be paid for unanticipated costs incurred during pulverization of the old road. The district court granted summary judgment for MMI, concluding that JEM could not prove it had been harmed by MMI’s alleged representations. The Supreme Court affirmed, holding that the district court did not err by (1) concluding that JEM was required to continue performance pending approval of a change order under a certain contract provision, as the provision was not void as against public policy; and (2) granting summary judgment to MMI on the ground that JEM failed to show it was harmed by the representations made by MMI. View "JEM Contracting, Inc. v. Morrison-Maierle, Inc." on Justia Law