Justia Montana Supreme Court Opinion Summaries

John Miller pled guilty to two counts of deliberate homicide. Miller later filed suit against James Goetz, the attorney that defended him, and arranged for Patrick Begley's limited representation in his claims against Goetz. Begley later withdrew from representing Miller. Miller then filed suit against Begley, alleging breach of contract, breach of the covenant of good faith and fair dealing, and fraudulent deceit. The district court granted summary judgment to Begley, finding that Begley had reasonably assisted Miller with his claims against Goetz and the dismissal of the Goetz claim was based on legal deficiencies unrelated to Begley's legal services. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment to Begley as Miller failed to demonstrate genuine issues of material fact existed regarding his claims.

Jule Roundstone was convicted of assault with a weapon and sentenced to a five-year commitment to the department of corrections (DOC). Roundstone's request for a furlough was granted, and he was released for a ten-day period. Roundstone failed to report after the first day of his furlough and was apprehended about a month later. Roundstone was charged with felony escape pursuant to Mont. Code Ann. 45-7-306. The district court denied Roundstone's motion to dismiss the charge as to the allegation that Roundstone had removed himself from official detention while on furlough and, therefore, could not commit escape. Roundstone entered a plea of guilty to the charge, reserving the right to appeal the denial of his motion to dismiss. Roundstone was sentenced to ten years at the DOC, with five years suspended. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in denying Roundstone's motion to dismiss as Roundstone was not excluded from official detention while on furlough, and (2) the prosecution did not violate Roundstone's due process rights by making certain sentencing recommendations during the sentencing hearing.

Dane Shattuck died from injuries after being hit by an automobile. Dane received medical care at Hospital for his injuries. Dane was enrolled in a children's health insurance program (CHIP), administered by the department of public health and human services (DPHHS). Hospital submitted the bill for Dane's care to Blue Cross and Blue Shield (BCBS), which served as third-party administrator of the CHIP program for DPHHS. Hospital then asserted a lien for the full bill amount against recoveries Gail Shattuck, as personal representative of Dane's estate, may obtain against third parties. Shattuck sued Hospital, BCBS, DPHHS, and the State, asserting that Defendants unlawfully acted to avoid application of "made whole" rules and that Hospital could not foreclose the lien because Shattuck had not been made whole. The district court granted partial summary judgment to Shattuck. The Supreme Court reversed in part and affirmed in part, holding (1) the district court erred by determining that CHIP constitutes insurance and was governed by the made whole doctrine, and (2) the district court did not err by determining that BCBS was not an insurer in its role here and, therefore, was not subject to the made whole statute. Remanded.

Rohnn Lampi's neighbor admitted liability for negligently dumping ashes that caused a wildfire that burned the trees and vegetation on Lampi's property. After the parties failed to agree on a settlement amount, Lampi brought an action in district court against his neighbor and sought a jury trial to determine damages. The jury awarded Lampi $250,000. On appeal, Lampi contended that the district court wrongly denied his motions to establish restoration damages as the appropriate measure of damages in his case. The Supreme Court reversed, holding that the district court erred by not concluding that restoration damages constituted the appropriate measure of damages in this case. Remanded for a new trial to allow the jury to determine what reasonable amount of damages would restore Lampi's property to its pre-fire condition.

Scott Heddings was charged with felony incest in State court. While the incest charge was pending, Heddings was charged in federal court with receipt of child pornography, possession of child pornography, and destruction or removal of property to prevent seizure. Heddings pled guilty to federal court to these charges. Heddings then pled guilty to the incest charge in State court. Heddings subsequently filed a petition for postconviction relief, arguing (1) he was subjected to double jeopardy because he was sentenced in State court for conduct that was used to enhance his federal sentence, and (2) his trial counsel was ineffective because counsel did not challenge the State court charge on double jeopardy grounds. The district court denied the petition, concluding that because the federal and State charges were based on separate conduct, Heddings' double jeopardy claim had no legal merit and, therefore, it would have been frivolous for his counsel to raise that claim. The Supreme Court affirmed, holding that the failure of Heddings' trial counsel to move for the dismissal of the State incest charge on double jeopardy grounds did not constitute ineffective assistance since the motion lacked merit and would not have changed the outcome of the proceedings.

Heather Weber filed suit under the Federal Employers' Liability Act (FELA) to recover for personal injuries allegedly received during the course and scope of her employment with BNSF Railway Company, alleging BNSF breached its duty under FELA, violated the Locomotive Inspection Act (LIA), and violated the Safety Appliance Act (SAA), federal regulations, and other standards. The district court found BNSF not negligent. On appeal, the Supreme Court reversed in part and affirmed in part, holding (1) the district court erred in granting BNSF's motion for judgment as a matter of law on Weber's LIA claim because Weber presented sufficient evidence that presented a factual issue whether the LIA had been violated and whether that violation played a part in causing Weber's injuries; and (2) the district court did not err in granting BNSF's motion to exclude testimony from Weber's treating physician about the results of a positron emission tomography (PET) scan performed on Weber. Remanded.

Plaintiff Carter Boehm, Trustee, sued Defendants Cokedale, L.L.C. and Allen Carter for property damages when, during construction of a road to reach Defendants' land, rocks of various sizes rolled downhill onto Plaintiff's property. Plaintiff subsequently added claims for assault and battery, intentional infliction of emotional distress, and negligent infliction of emotional distress. The district court granted summary judgment in favor of Defendants, concluding that Boehm was not the trustee of any trust validly established under Montana law, and therefore Boehm was perpetuating the lawsuit on behalf of a non-existent trust. The district court also awarded Defendants attorneys' fees and costs. The Supreme Court affirmed in part and reversed in part, holding (1) the district court properly granted summary judgment to Defendants pursuant to Mont. R. Civ. P. 17(a), which requires that every action shall be prosecuted in the name of the real party in interest; and (2) the district court abused its discretion in awarding attorneys' fees to Defendants. The award of fees was reversed.

Pursuant to a plea agreement, Joshua McCaslin pled guilty to one count of failure to register as a sexual or violent offender. In accordance with the agreement, the district court committed McCaslin to the Department of Corrections (DOC) for five years, all suspended. Applicable to this appeal, the court applied credit for pretrial incarceration time served to any future revocation of McCaslin's suspended sentence rather than to his current fully suspended sentence. McCaslin appealed. The Supreme Court reversed, holding that McCaslin's suspended sentence constituted a statutory judgment of imprisonment, and therefore, must be credited with the days of pretrial incarceration he served. Remanded.

Defendant John Finley's wife pleaded guilty to felony theft, and later, her probation officer conducted a valid search of her home. During a search of a safe in the couple's bedroom, the officer discovered drugs and drug paraphernalia. Defendant later entered conditional plea agreements to felony criminal possession of dangerous drugs and misdemeanor criminal possession of drug paraphernalia while reserving his right to appeal the district court's denial of his suppression motion. On appeal, Defendant challenged the district court's denial of his motion to suppress the evidence found in the safe, arguing that the probation officer exceeded the scope of the probationary search. The Supreme Court affirmed, holding that the probation officer legally searched the unlocked and open safe pursuant to the valid probationary search.

Mother consented to the adoption of her two biological children, after which the children were placed in the legal care of Guardians. Guardians later arranged for the adoption of the children by Adoptive Parents and relinquished the children. After six months of living with Adoptive Parents, Guardians moved to have their relinquishment and consent to adoption set aside, claiming their consent was fraudulently obtained by their reliance on a deficient pre-placement evaluation provided to them by Adoptive Parents. The district court denied the motion. The Supreme Court affirmed, holding that because Guardians failed to establish the existence of actual or constructive fraud by clear and convincing evidence, there was no statutory basis to set aside the relinquishments and consents given by Guardians.