Justia Montana Supreme Court Opinion Summaries

Randall Simms was injured during his employment. The Montana State Fund (MSF) provided workers compensation to Simms' employer, and later, paid continuing medical benefits for Simms. MSF subsequently utilized the services of a special investigative unit (SIU) to investigate Simms for fraud. The SIU took multiple videos of Simms in public places. The videos were deemed confidential criminal justice information (CCJI) by the district court. The court allowed them to be used in relation to Simms' workers' compensation claim in any manner consistent with the Montana Rules of Civil Procedure and workers' compensation court (WCC) procedures. Simms appealed, arguing that MSF did not having standing to file an action for dissemination under the Montana Criminal Justice Information Act of 1979, and that the district court inadequately balanced the demands of individual privacy against the merits of disclosure, did not follow established rules of statutory construction, and improperly identified and weighed the competing interests at issue. The Supreme Court affirmed, holding that the court did not err when it authorized MSF to disseminate the CCJI under the Act, and the court correctly interpreted the statute and adequately engaged in the statutorily mandated balancing of competing concerns. View "Mont. State Fund v. Simms" on Justia Law

Appellant Wife filed for dissolution of her marriage to Husband. The district court found the marriage to be irretrievably broken, divided property between the parties, ordered Husband to pay child support and Wife's attorney fees, and denied Wife's request for maintenance. The Supreme Court affirmed, holding, inter alia, that the district court (1) was not prevented from properly valuing the properties of the estate; (2) did not err in its division of the marital estate; (3) did not err in calculating the amount of Husband's premarital contribution credit on certain properties; (4) did not err by failing to award maintenance to Wife; and (5) did not err in requiring Husband to pay Wife's attorney fees and in the calculation of those fees. View "In re Marriage of Caras" on Justia Law

The City of Dillon entered an agreement with the McNeills allowing them to connect to a water main for their domestic water supply. Later, the City granted permission to the McNeills to activate an existing water service to their property. The Conners bought the McNeills' subdivided lot, and the City billed and collected for the water that was furnished to the Conners. The water main subsequently froze solid, leaving the Conners without water service for weeks. The Conners sued the City for breach of contract and negligence. The district court entered summary judgment for the City, concluding (1) there was no implied contract between the Conners and the City, and therefore, the Conners' water use was unlawful; and (2) the negligence claim was barred by City Ordinance 13.04.150, which provides that the City is not liable for claims from interruption of water service resulting from shutting off the water in its mains. The Supreme Court reversed, holding (1) the City had a legal obligation to provide water to the Conners under an implied contract; and (2) section 13.04.150 did not bar the Conners' claims because the City did not decide to shut off the water service. View "Conner v. City of Dillon" on Justia Law

The Wagners owned property along a river, which was subject to restrictive covenants. Brian Woodward purchased adjacent property that was subject to the same covenants. Woodward later added onto the deck of the home he purchased and built a split-rail fence along his east and west property lines. The Wagners sued, claiming Woodward's additions violated the restrictive covenants. The district court determined (1) the fences did not violate the covenants, but (2) the deck addition violated the covenants. The court ordered Woodward to remove the deck addition. The Supreme Court reversed in part and vacated the district court's order requiring Woodward to remove the deck addition from his home, holding (1) any violation of the covenant by the deck addition was de minimus, and (2) given Woodward's detrimental reliance of the Wagners' failure to timely enforce the covenants as they pertained to his home and the absolute absence of damages to the Wagners, it would be inequitable to compel removal of the deck addition. View "Wagner v. Woodward" on Justia Law

Appellants and Bank entered a loan agreement in which Bank agreed to lend Appellants $5 million. After Bank refused to disburse further funds under the loan, Appellants sued Bank. Bank was represented by the Crowley Fleck law firm (Crowley). During the ensuing litigation, an attorney that was working with the law firm representing Appellants (Lawyer) joined Crowley as an attorney. Appellants subsequently filed motions to disqualify Crowley from representing Bank in the case and to permanently enjoin Crowley from proceeding in the litigation. The trial court denied Appellants' motion. The Supreme Court reversed, holding that the district court erred in denying Appellants' motions where (1) Lawyer, who was engaged in concrete discussions of future employment with the adversary's law firm, did not promptly inform Appellant, terminate all further discussions concerning the employment, or withdraw from representing Appellant; (2) the conflict was concurrent and thus imputed to Crowley; and (3) the measures Crowley took were inadequate to preserve Appellants' confidences. View "Krutzfeldt Ranch, LLC v. Pinnacle Bank" on Justia Law

Phil and Valerie married in 2003 and commenced dissolution proceedings in 2005. After five years of litigation, the district court held bifurcated bench trials to address three separate aspects of the dissolution: the parenting plan, child support obligations, and division of the marital estate. The Supreme Court affirmed the judgment of the district court in all respects, holding (1) the district court did not abuse its discretion in determining and distributing the marital estate; (2) the district court did not abuse its discretion in determining that the couple's children would reside primarily with Valerie under the final parenting plan; and (3) the district court did not err in calculating Phil's child support payments. View "In re Marriage of Tummarello" on Justia Law

Kevin and June Funk were married in 1990. In 1996, Kevin inherited several acres of lakefront and non-lakefront property, several vehicles, and an undisclosed amount of cash. June filed for dissolution in 2009. In distributing the marital assets upon dissolution, the district court included Kevin's inherited real property in the marital assets and awarded a portion to June. The Supreme Court (1) affirmed the district court's award of one of the vehicles to June and its valuation of Kevin's lakefront property; and (2) remanded for the district court to assess the factors set forth in Mont. Code Ann. 202(1) in determining the legal basis for an award to June of a portion of the value of the lakefront property. View "In re Marriage of Funk" on Justia Law

Following a jury trial, Rhonda Hall was sentenced on her conviction of charges of obstructing a peace officer, disorderly conduct, and assault with a bodily fluid. At the conclusion of the City's case, the district court judge expressed her concern that the City had not presented sufficient evidence to meet its burden of proof. Defense counsel subsequently filed a motion that the case be dismissed for insufficient evidence, which the trial court granted. The Supreme Court affirmed the district court's judgment, finding that inasmuch as the court dismissed the City's case against Hall for insufficient evidence, Hall stood acquitted and could not be retried, and the City had no appeal from the district court's decision. View "City of Cut Bank v. Hall" on Justia Law

The City of Dillon filed a civil action against George Warner seeking to recover the costs of installation of a water meter. Judge Gregory Mohr ruled on several motions filed by the city and conducted a scheduling conference. Warner subsequently filed an affidavit of disqualification against Mohr. The judge that presided over the disqualification proceeding (1) found Warner's affidavit of disqualification was insufficient as a matter of law and was therefore void; and (2) ordered that Mohr would maintain jurisdiction. The district court dismissed Warner's appeal, finding that the city court order concerning Warner's attempt to disqualify Mohr was an interim order and was therefore not appealable. The Supreme Court affirmed, holding (1) the district court properly dismissed Warner's appeal, as it was from an interim order and not a final judgment; and (2) the district court's orders dismissing the appeal were interim orders and thus not appealable to the Court. View "City of Dillon v. Warner" on Justia Law

James Whealon was employed by the Anaconda School District pursuant to a series of employment contracts. Upon retirement, Whealon filed a formal grievance, asserting that, under the terms of his contract, he was entitled to payment of his health insurance premiums by the District until he reached the age of sixty-five. The District denied his claim. The County Superintendent granted summary judgment to the District, holding that the language of the contract was unambiguous and that Whealon was not entitled to the claimed benefits beyond the date of his retirement. The State Superintendent of Public Instruction reversed and remanded for an evidentiary hearing, holding that the language of the contract was ambiguous. The district court reversed and reinstated the County Superintendent's ruling. The Supreme Court affirmed the district court, holding (1) the district court did not err in holding that a county superintendent has authority to grant summary judgment; and (2) the district court did not err in reinstating summary judgment in favor of the district where the language of the agreement was unambiguous and the District was entitled to judgment. View "Anaconda Public Schools v. Whealon" on Justia Law