Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the ruling of the district court that Whitefish City did not engage in illegal spot zoning and reversed the district court's ruling that Whitefish City Ordinance 18-23, which specified additional conditional uses, violated the uniformity requirement found in Mont. Code Ann. 76-2-302(2), holding that the City acted within its discretion in enacting the ordinance.This case involved an undeveloped parcel in The Lakes neighborhood known as Area 2(c). IO2.5, a series member of IO-3, LLC, filed a request with the City to amend Ordinance 99-9 to allow use of a conditional use permit (CUP) instead of a planned unit development (PUD) to develop Area 2(c). The City Council approved the request and approved Ordinance 18-23, directing amendment of the official zoning map and permitting development of Area 2(c) through a CUP instead of a PUD. Plaintiffs brought this complaint alleging that Ordinance 18-23 violates the statutory uniformity requirement. The district court struck the portion of Ordinance 18-23 that specified additional conditional uses. The Supreme Court held that the district court (1) did not err in ruling that Ordinance 18-23 did not constitute spot zoning; and (2) erred in ruling that Ordinance 18-23 violated section 76-2-302(2)'s uniformity requirement. View "Hartshorne v. Whitefish" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing this action for breach of contract and declaratory judgment and declining to award attorney fees to either party, holding that the district court did not err.The owners of certain condominium units brought this action against the condominium owner after the developer unilaterally amended the condominium declaration to create a new homeowners' association to which new unit owners would belong, thus leaving existing unit owners in the original homeowners' association. The developer subsequently revoked the amendment to the declaration. The district court dismissed the case as moot. The court then refused to award attorney fees, ruling that neither party was a prevailing party. The Supreme Court affirmed, holding that the district court did not err in dismissing the case as moot and did not err in refusing to award attorney fees and costs. View "Heringer v. Barnegat Development Group, LLC" on Justia Law

The Supreme Court affirmed in part and reversed in part the district court's judgment compelling Plaintiffs to survey a roadway easement adjudicated by a previous declaratory judgment in 2016 and denying their motion for clarification, holding that the court erred in failing to clarify the 2016 judgment and subject easement on the motion for clarification.In this long-running dispute over a private roadway, Plaintiffs challenged a district court order compelling them to survey a roadway easement adjudicated in 2016 by declaratory judgment, denying their motion for clarification of a subsequently discovered ambiguity between the metes and bounds description and accompanying map depiction of an easement in the underlying 1987 grant, and rescinding prior awards of attorney fees and costs. The Supreme Court reversed in part, holding that the district court erroneously failed to construe the 1987 stipulation, 2016 judgment, and resulting law of the case and thus erred in failing to clarify the 2016 judgment and subject easement on Plaintiffs' motion for clarification. View "VanBuskirk v. Gehlen" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that a Fergus County road was private because Public Land/Water Access Association, Inc. (PLWA) had not proven the existence of a public road by prescriptive easement or petition, holding that the district court did not err.Specifically, the Supreme Court held (1) the district court applied the correct legal standard for its review, the "record as a whole" standard set forth in Reid v. Park County, 627 P.2d 1210 (Mont. 1981); and (2) the district did not err in concluding that the disputed road was not a public road either by prescriptive easement or statutory methods. View "Public Land & Water Access Ass'n v. Robbins" on Justia Law

The Supreme Court affirmed the post-judgment motions issued by the district court denying Plaintiff's Mont. R. Crim. P. 60(b) motion for relief and Mont. R. Civ. P. 62.1 motion for an indicative ruling, holding that the district court did not abuse its discretion.Plaintiff alleged that Defendant entered Plaintiff's property and shot his boat with a rifle. The district court granted summary judgment in favor of Frost, and the Supreme Court affirmed. While Plaintiff's appeal was pending, Plaintiff filed the two motions at issue, alleging that he had discovered new evidence. The district court denied both motions. The Supreme Court affirmed, holding that the district court (1) correctly determined that it lacked jurisdiction over Plaintiff's Rule 60(b) motion; and (2) did not abuse its discretion by denying Plaintiff's Rule 62.1 motion. View "Moore v. Frost" on Justia Law

The Supreme Court affirmed the judgment of the district court granting various mortgage lenders and trustees summary judgment on Plaintiff's claims for negligence and breach of the implied covenant of good faith and fair dealing, holding that genuine issues of material fact did not preclude summary judgment.Plaintiff filed an action asserting negligent loan supervision/administration, breach of the implied contract covenant of good faith and fair dealing, anticipatory declaratory judgment, and quiet title to mortgaged property. The district court granted summary judgment to Bank of America, N.A. (BOA) on all claims. The Supreme Court affirmed, holding that the district court did not err in granting BOA summary judgment on Plaintiff's asserted negligence and breach of the implied covenant of good faith and fair dealing claims. View "House v. U.S. Bank National Ass'n" on Justia Law

The Supreme Court reversed the judgment of the district court reversing a Department of Natural Resources and Conservation (DNRC) contested case decision granting RC Resources, Inc. (RCR) a beneficial water use permit under pertinent provisions of the Montana Water Use Act (MWUA) - Mont. Code Ann. 85-2-301(1), -302(1), and -311 - holding that the district court erred.The permit at issue would have authorized RCR to annually appropriate 857 acre-feet of groundwater that will flow into the underground adits and works of the proposed Rock Creek Mine. Based on its construction of Mont. Code Ann. 85-2-311(1)(a)(ii)(B), the district court reversed the issuance of the beneficial use permit. The Supreme Court reversed, holding (1) DNRC correctly concluded that, as used in section 85-2-311(1)(a)(ii), "legal demands" does not include consideration of whether the subject use complies with applicable Montana Water Quality Act nondegradation standards; and (2) section 85-2-311(2) does not violate the right to a clean and healthful environment as applied to the objectors' MWQA nondegradation objections to the proposed MWUA beneficial use permit. View "Clark Fork Coalition v. Montana Department of Natural Resources & Conservation" on Justia Law

The Supreme Court affirmed the order of the Montana Water Court establishing the point of diversion for two claims owned by Carolyn Mack and Chriss Mack, holding that the Water Court did not err or abuse its discretion.Specifically, the Supreme Court held that the Water Court (1) did not err when it concluded that it had jurisdiction over the Macks' amended statement of claim; (2) did not abuse its discretion in concluding that the Macks did not make any judicial admissions in previous litigation; (3) did not err in assigning the burden of proof to Appellants - Glenda, Jimmy, John, and Rowdy Anderson; and (4) did not abuse its discretion in excluding the Andersons' expert witness. Lastly, the Supreme Court held that the Water Court's findings of fact were not clearly erroneous and that there was substantial evidence supporting the Water Court's conclusion establishing the point of diversion for the Macks' claims. View "Mack v. Anderson" on Justia Law

The Supreme Court affirmed the ruling of the district court determining that Brown Drake, LLC's operation of the Brown Drake Lodge did not violate the Craig Tracts Homeowners' Association's (HOA) amended covenant's requirement that the property be "used for residential purposes only," holding that the district court did not err.The HOA brought this action for injunctive and declaratory relief, alleging that Brown Drake's operation of the Lodge violated the amended covenants' requirement that property be used for residential purposes only. The district court ruled in favor of Brown Drake. The Supreme Court affirmed, holding that Brown Drake's operation of the Lodge did not violate the amendment covenants under the HOA. View "Craig Tracts Homeowners' Ass'n v. Brown Drake, LLC" on Justia Law

The Supreme Court reversed the judgment of the district court interpreting and modifying a prior 2014 judgment that previously adjudicated that Plaintiffs had established various prescriptive easement rights over certain land before Defendants acquired it in the 1980s, holding that the court misinterpreted the 2014 judgment.Specifically, the Supreme Court held (1) the district court did not err when it concluded that Mont. R. Civ. P. 59-60 did not apply to Defendants' motions for subsequent interpretation and clarification of the 2014 judgment; (2) the district court erred when it construed the 2014 judgment as ambiguous on its face or in effect; and (3) the district court erroneously altered and amended the substance of the 2014 judgment inconsistent with its manifestly intended original meaning and effect. View "Meine v. Hren Ranches, Inc." on Justia Law