Justia Montana Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of criminal distribution of dangerous drugs, a felony. Defendant appealed, arguing that the district court erred by instructing the jury on the elements of the offense prior to the delivery of opening statements. The Supreme Court affirmed, holding (1) the district court erred by, before opening statements, reading the jury instructions regarding the elements of the offense of criminal distribution of dangerous drugs without finding good cause; but (2) under the circumstances, Defendant’s substantial rights were not prejudicially affected by the error. View "State v. Otto" on Justia Law

Defendant was charged with one count of burglary and two counts of misdemeanor assault. Defendant pleaded guilty to the assaults but proceeded to a jury trial on the burglary charge. Defendant filed a motion to excuse a certain juror for cause based on the juror’s answers during voir dire to questions as to whether the juror inherently thought a law enforcement officer was more believable than a non-officer. The trial court denied the motion, and Defendant was subsequently convicted of burglary. The Supreme Court affirmed, holding that the district court did not err in denying Defendant’s motion to excuse the juror for cause. View "State v. Johnson" on Justia Law

Defendant pled guilty to one count of felony assault with a weapon. The district court sentenced Defendant to a ten-year term commitment to the Department of Corrections (DOC) with five years suspended. After Defendant’s probation officer filed a report of violation, a petition for revocation was filed in district court. Following a hearing, the district court sentenced Defendant to a five-year commitment to DOC with recommended placement at a prerelease facility. The Supreme Court affirmed, holding (1) the district court did not err when it denied Defendant’s motion to dismiss the petition for revocation; and (2) the district court did not violate Defendant’s due process rights by considering the criminal history information in the presentencing investigation report, nor did it abuse its discretion by requiring Defendant to serve the remainder of his original sentence. View "State v. Edmundson" on Justia Law

Ruby Valley National Bank (RVNB) obtained and recorded a deed of trust (DOT) on certain real property subsequent to a previously recorded DOT. Wells Fargo Delaware Trust Co. (Wells Fargo) claimed to be the beneficiary of the first DOT. RVNB filed for judicial foreclosure of its interest in the property. The district court granted summary judgment for RVNB, holding that RVNB’s DOT was entitled to priority over the earlier DOT held by Wells Fargo because Wells Fargo had not proven the elements necessary for judicial foreclosure and was unable to do so because its trial witness and exhibit list had been stricken. The Supreme Court reversed, holding (1) Wells Fargo was not required to file a counterclaim for foreclosure to protect its interest in the property; and (2) because the undisputed facts established that Wells Fargo was the current beneficiary of the first DOT, the undisputed facts established that Wells Fargo was entitled to judgment as a matter of law that its indenture held priority over RVNB’s indenture. View "Ruby Valley Nat'l Bank v. Wells Fargo Del. Trust Co., N.A." on Justia Law

After the district court adjudicated Child a youth in need of care, the State filed a petition to terminate Mother’s parental rights. Child was placed with Father before the termination hearing. The district court subsequently terminated Mother’s parental rights and denied Mother’s motion to dismiss the termination petition. The Supreme Court affirmed, holding (1) Mother failed to articulate a substantive due process claim that required the State’s petition to terminate be dismissed; (2) the placement of Child with Father did not require that the State’s petition to terminate be dismissed; and (3) the State’s petition to terminate was not filed prematurely. View "In re L.V-B." on Justia Law

Then-owners of real property entered into a “Waiver of Right to Protest” the creation of special improvement districts (SIDs) for the purpose of making road and intersection improvements to Cottonwood Road between Huffine Lane and West Babcock Street. The waiver stated that the parties to the waiver would participate in alternate financing methods for completion of the road improvements if the SIDs were not utilized. No SIDs were implemented, and Covenant Investments, Inc. (Covenant) undertook and paid for all improvements to the intersection of Huffine and Cottonwood. First Security Bank (FSB), a successor to the original covenantor, subsequently constructed a building at the intersection. After FSB refused to reimburse Covenant for the costs of the street improvements, Covenant sued FSB seeking enforcement of the waiver agreement. The district court dismissed Covenant’s complaint, concluding that the waiver did not contain the essential elements of a contract and therefore did not bind FSB. The Supreme Court affirmed the dismissal of the complaint, holding (1) the waiver’s alternative financing provision was void for lack of certainty, (2) by acting unilaterally Covenant waived its right to belatedly demand enforcement of the waiver provision, and (3) Covenant’s complaint was barred by the statute of limitations. View "Covenant Invs., Inc. v. First Sec. Bank" on Justia Law

In the 1990s, Defendants (Employers) created a sick-leave policy allowing employees to bank their sick leave in a continued illness bank (CIB). In 2002, Employers modified the terms of the CIB to create the CIB pay-out benefit, which allowed a capped amount of unused CIB hours to be paid to departing employees who completed twenty-five years or more of service. In 2008, Employers terminated the CIB pay-out benefit, and only employees who had reached twenty-five years of employment with Employers were entitled to their earned but unused CIB hours upon termination. Plaintiffs in this case represented employees who had not reached twenty-five years of service before the benefit ended. Plaintiffs brought a class action complaint against Employers. The district court granted summary judgment for Employers. The Supreme Court affirmed, holding that the district court did not err in determining that (1) Employers’ policies did not constitute a standardized group employment contract; (2) the CIB pay-out benefit was not deferred compensation or wages under the Montana Wage and Wage Protection Act; and (3) the covenant of good faith and fair dealing did not apply to Plaintiffs’ claims. View "Chipman v. Northwest Healthcare Corp." on Justia Law

Public Lands Access Association, Inc. (PLAA) sought a declaration that the public may use certain roads and bridges to access Ruby River. In 2008, the district court granted PLAA summary judgment on the issue of public access to the Ruby River from Lewis Lane. In 2012, the district court denied the public access to Ruby River at Seyler Lane and Seyler Bridge. PLAA appealed, and James Kennedy, who intervened as a defendant, cross-appealed. The Supreme Court consolidated the appeal and cross-appeal. The Supreme Court reversed in part and remanded, holding (1) the district court erred in deciding that the County had a secondary easement that was independent and separate from the public road right-of-way at the intersection of Seyler Lane and Ruby River; (2) in determining the width of the public right-of-way at the intersection of Seyler Lane and Ruby River, the trial court’s blanket exclusion of recreation use evidence was improper; (3) the scope of use of the public road right-of-way was not limited to the adverse usage; and (4) the district court did not effectuate an unconstitutional taking of Kennedy’s property when it ruled that the public may access Ruby River at Lewis Lane. View "Pub. Lands Access Ass'n, Inc. v. Bd. of County Comm'rs of Madison County" on Justia Law

Defendant pleaded guilty to felony theft pursuant to a plea agreement. Although both parties recommended that the district court follow the plea agreement in sentencing Defendant, the district court rejected the plea agreement and sentenced Defendant to the Department of Corrections (DOC) for ten years, with five years suspended. Defendant appealed, arguing, among other things, that the district court committed plain error and violated his due process rights by rejecting the plea agreement and failing to afford him the opportunity to withdraw his guilty plea. The Supreme Court affirmed, holding (1) the district court did not err when it rejected the plea agreement’s sentencing recommendation without giving Defendant the opportunity to withdraw his plea; and (2) Defendant’s trial attorney did not provide ineffective assistance. View "State v. Olson" on Justia Law

Rober Spoja represented Duste White regarding White’s probation revocation. The sentencing court sentenced White but did not mention whether the sentence was to be served concurrently with other sentences. White petitioned to correct his sentence. The court entered an amended re-sentencing order allowing him to serve his term concurrently with other sentences, resulting in an earlier discharge date. Believing he was incarcerated for fourteen months longer than his actual sentence, White retained Bryan Tipp to represent him in a civil action against Spoja and Spoja’s law firm. After Tipp discovered the sentencing court had not ordered concurrent sentences, Tipp moved successfully to dismiss the case without informing Spoja. Spoja subsequently filed a civil action against White, Tipp, and Tipp’s law firm. The district court dismissed Spoja’s claims. The Supreme Court (1) reversed the entry of summary judgment against Spoja’s attorney deceit claim, and the award of costs, as a trier of fact could find Tipp acted deceitfully and intended to do so; and (2) affirmed the dismissal of Spoja’s malicious prosecution claim and the award of summary judgment against his abuse of process claim. View "Spoja v. White" on Justia Law