Justia Montana Supreme Court Opinion Summaries

Dr. Stephen D. Behlmer sought declaratory relief to establish his right to access his property in the Scratchgravel Hills via a road that crosses various parcels owned by multiple property owners within the Treasure Canyon Estates subdivision. Behlmer's property is surrounded by land managed by the Bureau of Land Management (BLM) and is accessible by traveling through Treasure Canyon Drive, which runs through the Landowners' properties. Behlmer has a lease from the United States to access his property via BLM land, effective until 2037.The First Judicial District Court, Lewis and Clark County, dismissed Behlmer's petition for failure to join the United States as a required party, as the Landowners argued that the petition would prejudice federal interests. Behlmer amended his petition to clarify that he only sought a declaration of his rights relative to the portion of Treasure Canyon Drive traversing the Landowners' private property, not any BLM land. Despite this, the District Court granted the Landowners' motion to dismiss under M. R. Civ. P. 12(b)(7).The Supreme Court of the State of Montana reviewed the case and reversed the District Court's decision. The Supreme Court held that the United States was not a required party under Rule 19 because its absence would not frustrate complete relief to the parties nor prejudice the United States' interests. The court determined that Behlmer's petition pertained only to the Landowners' interests and did not affect any adjacent property holders, including the United States. Therefore, the District Court abused its discretion in dismissing Behlmer's petition for failure to join a required party. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Behlmer v. Crum" on Justia Law

The plaintiffs, William and Ellen Solem, own property in Flathead County’s “Neighborhood 800.” In 2008, the Montana Department of Revenue (DOR) conducted a mass appraisal of lakefront properties in this neighborhood, significantly increasing the valuation of the Solems' property from $229,500 in 2002 to $1,233,050 in 2008. The Solems challenged the appraisal, arguing that DOR’s methodology was improper and unlawful. They sought approximately $450 in alleged overpaid taxes and filed a class action on behalf of other property owners in the neighborhood.The Eleventh Judicial District Court certified the case as a class action and held a bench trial on liability issues. The court found in favor of the Solems, ruling that DOR’s appraisal methodology was unlawful and unconstitutional. The court criticized DOR for excluding 17 outlier sales from its model and for using only three variables in its appraisal process. The court awarded damages, costs, and fees to the plaintiffs. The Solems also cross-appealed the court’s denial of their motion to amend the class definition.The Supreme Court of the State of Montana reviewed the case. The court held that the District Court erred by substituting its judgment for that of DOR. The Supreme Court found that DOR’s mass appraisal methodology was consistent with accepted practices and that the Solems failed to meet the substantial burden of disproving the accuracy of DOR’s appraisal. The court also noted that the District Court improperly relied on the R squared value as the sole metric for accuracy. Consequently, the Supreme Court reversed the District Court’s ruling and remanded the case for proceedings consistent with its opinion. The court did not address the constitutionality of the payment-under-protest requirement, as it was unnecessary given the resolution of the primary issue. View "Solem v. Department of Revenue" on Justia Law

The City of Shelby operates a municipal water system in Toole County, Montana, supplying water to several service areas. In 2017, the Montana Department of Natural Resources and Conservation (DNRC) approved changes allowing Shelby to temporarily service these areas. In 2019, Shelby applied to expand its service area and increase groundwater production. DNRC issued preliminary approvals for these applications in 2020, which the Town of Kevin objected to, leading to a hearing examiner's review.The hearing examiner denied Kevin's motion for summary judgment and later approved Shelby's applications, concluding that Shelby met the statutory criteria based on service agreements with communities in its service area. Kevin then petitioned the Montana Water Court for judicial review, arguing that DNRC misinterpreted the law and that Shelby's applications did not meet statutory requirements. The Water Court denied Kevin's petition, affirming DNRC's decisions.The Supreme Court of the State of Montana reviewed the case, focusing on whether DNRC erred in approving Shelby's permit and change of use applications. The court found that DNRC's interpretation of the law, which allowed service agreements to satisfy the statutory requirement for written consent, was reasonable. However, the court noted that the record lacked evidence of a service agreement with Galata, one of the proposed new service areas. Consequently, the court affirmed DNRC's decision in part but reversed it regarding the inclusion of Galata.The court remanded the case to DNRC to determine whether all required service agreements exist and to issue an order consistent with this opinion. The main holding was that DNRC's interpretation of the statutory criteria was correct, except for the missing service agreement with Galata. View "Town of Kevin v. Department of Natural Resources and Conservation" on Justia Law

A group of residents in the Whitehorse Estates Minor Subdivision filed a complaint against their neighbors, Joseph and Amanda Kleinhans, alleging that the Kleinhans violated the subdivision’s restrictive covenants by converting their garage into an accessory dwelling unit (ADU) and renting it out as an Airbnb. The covenants in question required properties to be used only for single-family dwellings and prohibited the operation of commercial businesses.The District Court of the Twenty-Second Judicial District, Carbon County, granted summary judgment in favor of the Kleinhans. The court interpreted the single-family dwelling covenant as a structural restriction, not a use restriction, meaning it only limited the type and number of buildings but did not restrict the use of the property to single families. The court also found the commercial business covenant to be ambiguous and concluded it did not prohibit short-term rentals like Airbnb. Consequently, the court awarded the Kleinhans their Bill of Costs amounting to $4,594.35.The Supreme Court of the State of Montana reviewed the case and reversed the District Court’s decision. The Supreme Court held that the term "commercial business" was not ambiguous and should be given its plain and ordinary meaning, which includes activities conducted for profit. Therefore, the Kleinhans' operation of an Airbnb constituted a commercial business, violating the subdivision’s covenants. The Supreme Court also reversed the award of the Bill of Costs to the Kleinhans and remanded the case to the District Court to enter summary judgment in favor of the neighbors. View "Myers v. Kleinhans" on Justia Law

This case involves a property dispute in Lincoln County, Montana. Tiffany House sought to sell a property initially conveyed to her former husband, Conrad Coggeshall, by an LLC owned by David E. Orr. After their divorce, House was granted permission by the Superior Court of Arizona to transfer the property into her name. However, Coggeshall, while incarcerated, executed a quitclaim deed transferring his interest in the property to Orr, who recorded it in Lincoln County. House then filed a quiet title action, alleging the transfer was fraudulent.The Nineteenth Judicial District Court reviewed the case. House served Orr with discovery requests, including admissions that Orr failed to respond to. Consequently, House filed a motion for summary judgment, which Orr did not contest. The District Court granted House’s motion, quieting title in her name and ordering Orr to execute a quitclaim deed. Orr filed a notice of appeal and a motion to stay execution, which the District Court denied. Orr’s first appeal was dismissed, and he filed a second notice of appeal.The Supreme Court of the State of Montana reviewed the case de novo. Orr argued that the requests for admission were improperly served, that he did deny them, and that the summary judgment violated his Fifth and Sixth Amendment rights. However, the court noted that these arguments were not raised in the lower court and thus were not preserved for appeal. The court emphasized the importance of procedural rules and fair notice of legal issues. Consequently, the court affirmed the District Court’s decision to grant summary judgment in favor of House. View "House v Orr" on Justia Law

The case involves Montanans Against Irresponsible Densification, LLC (MAID), which challenged two laws passed by the 2023 Montana Legislature aimed at addressing affordable housing. Senate Bill 323 (SB 323) mandates that duplex housing be allowed in cities with at least 5,000 residents where single-family residences are permitted. Senate Bill 528 (SB 528) requires municipalities to allow at least one accessory dwelling unit on lots with single-family dwellings. MAID, consisting of homeowners from various cities, argued that these laws would negatively impact their property values and quality of life, and filed for declaratory and injunctive relief.The Eighteenth Judicial District Court in Gallatin County granted MAID a preliminary injunction, temporarily halting the implementation of the laws. The court found that MAID had standing and had demonstrated the likelihood of irreparable harm, success on the merits, and that the balance of equities and public interest favored the injunction. The court cited concerns about potential impacts on property values and neighborhood character, as well as constitutional issues related to public participation and equal protection.The Supreme Court of the State of Montana reviewed the case and reversed the District Court's decision. The Supreme Court found that MAID did not meet the burden of demonstrating all four factors required for a preliminary injunction. Specifically, the court held that MAID's evidence of potential harm was speculative and did not show a likelihood of irreparable injury. The court also noted that the balance of equities and public interest did not favor the injunction, given the legislative intent to address the housing crisis. The Supreme Court remanded the case for further proceedings. View "Montanans Against Irresponsible Densification, LLC, v. State" on Justia Law

Samuel J. Nelson appealed an order from the Eighteenth Judicial District Court, Gallatin County, which granted summary judgment in favor of Montana Rail Link, Inc. (MRL) and BNSF Railway Co. Nelson sought a prescriptive easement over a railroad right of way (ROW) granted under the Northern Pacific Railroad Company Land Grant Act of 1864. Nelson had been using a dirt road within the ROW to access his property since 1982. Despite MRL's awareness and multiple attempts to formalize Nelson's use through a lease, no agreement was reached, and MRL eventually blocked access, leading to Nelson's criminal trespass citation, which was later dismissed.The District Court ruled that a private party could not acquire a prescriptive easement over a railroad ROW granted under the 1864 Act, as these ROWs were for the exclusive use and control of the railroads, with the United States holding a reversionary interest. Nelson appealed this decision.The Supreme Court of the State of Montana affirmed the District Court's ruling. The Court held that the 1864 Act granted the railroad a limited fee with exclusive possession and control, subject to a reversionary interest by the United States. This exclusivity precludes private parties from acquiring any property interests, including prescriptive easements, within the ROW. The Court also noted that a private prescriptive easement would interfere with the railroad's operations and the federal government's reversionary interest. The Court concluded that Nelson could not obtain a prescriptive easement over the ROW, affirming the lower court's judgment in favor of MRL and BNSF. View "Nelson v. Montana Rail" on Justia Law

The case involves a dispute over a bridge constructed by John Dimar over the Clearwater River to provide better access to a subdivision where all parties reside. Dimar built the bridge at his own expense and later sought to restrict access to it, prompting neighboring lot owners to file a lawsuit for declaratory relief to access the bridge and to avoid sharing in the construction costs. The plaintiffs argued that the 1994 Easement Agreement granted them access rights without the obligation to share in the construction costs.The Fourth Judicial District Court of Missoula County granted summary judgment in favor of the plaintiffs, ruling that the 1994 Easement Agreement allowed them access to the bridge and that they were not responsible for the construction costs. The court also issued a preliminary injunction requiring Dimar to provide keys to the bridge to the plaintiffs and emergency responders. Dimar appealed, arguing that the easement did not cover the bridge and that the plaintiffs should share in the construction costs.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decision. The court held that the 1994 Easement Agreement was clear and unambiguous in granting the plaintiffs access to the bridge. The court also found that Dimar was estopped from contesting the validity of the easement due to his previous litigation in the River Watch case, where he had argued for the easement's validity. Additionally, the court ruled that the plaintiffs were not unjustly enriched by using the bridge without sharing in the construction costs, as the 1994 Easement Agreement explicitly stated that any improvements made without a prior written agreement would be at the expense of the improver. View "Beck v. Dimar" on Justia Law

Frank Hallberg rented an apartment from Steve Schmitz in Helena. Schmitz sent Hallberg a 30-day notice to vacate, and upon inspecting the apartment on July 12, 2021, Schmitz found 20-30 holes in the walls. Schmitz took photos and called the police, who also documented the damage. Hallberg was charged with Criminal Mischief Damage to Rental Property.The Municipal Court scheduled an omnibus hearing, which Hallberg attended without his attorney. The hearing was rescheduled multiple times, and neither Hallberg nor his attorney appeared at the final rescheduled hearing. Consequently, the court set a bench trial for April 15, 2022, which was held on December 14, 2022. The court found Hallberg guilty and ordered him to pay $1,226.45 in restitution. Hallberg appealed to the District Court, arguing he was denied a jury trial, the evidence was insufficient, and the restitution amount was incorrect. The District Court affirmed the Municipal Court's decision, stating Hallberg waived his right to a jury trial by not objecting and that the restitution amount was supported by Schmitz’s testimony.The Supreme Court of the State of Montana reviewed the case. It held that Hallberg waived his right to a jury trial by failing to object to the bench trial. The court found sufficient evidence to support Hallberg’s conviction based on the testimonies and photographic evidence presented. The court also upheld the restitution amount, finding it was not clearly erroneous as it was supported by Schmitz’s testimony regarding repair costs. The Supreme Court affirmed the District Court’s decision. View "City of Helena v. Hallberg" on Justia Law

A group of Bozeman residents challenged a zoning provision within the City’s Unified Development Code (UDC), claiming they were not given sufficient notice regarding the City’s consideration of an amendment. The amendment, part of a general replacement of the UDC adopted in 2018, reclassified Greek housing into a new “group living” category, allowing fraternities and sororities in certain residential zones. The residents, who began experiencing disturbances from a nearby fraternity house in early 2022, filed a complaint against the City in October 2022, asserting that the notice provided for the zoning change was insufficient.The Eighteenth Judicial District Court of Gallatin County granted summary judgment in favor of the residents, declaring the Greek housing reclassification void ab initio due to insufficient notice. The court reasoned that the City’s notice did not adequately inform the public about the specific change and its impact on the community. The court also held that the residents’ claims were not time-barred under § 2-3-114(1), MCA, because the provision was void from the beginning, and thus the statute of limitations did not apply.The Supreme Court of the State of Montana reversed the District Court’s decision. The Supreme Court held that § 2-3-114(1), MCA, which requires challenges to agency decisions to be filed within 30 days of when the person learns or reasonably should have learned of the decision, applied to this case. The Court concluded that the residents’ action was untimely because they filed their complaint more than 30 days after they became aware of the zoning change in April 2022. The Supreme Court remanded the case for entry of judgment in favor of the City. View "Johnson v. City of Bozeman" on Justia Law