Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed judgments issued by the district court in these consolidated appeals concerning the interpretation of the Montana Residential Mobile Home Lot Rental Act as it related to mobile home owners who had been evicted from their lots, holding that the Act does not allow for a no-cause termination of a periodic tenancy.David and Doreen Lockhart appealed the order issued by the district court upholding the order for possession issued by the justice court and ordering them to vacate and remove all personal property from a mobile home lot owned by Westview Mobile Home Park, LLC. Hydi Cunningham appealed the district court orders following the justice court's judgment and order for possession of property and writ of issuance ordering Cunningham to vacate the mobile home lot she had been renting from Greener Montana Property Management, LLC. The Supreme Court reversed in both causes, holding (1) the Act does not allow a lot-only landlord to terminate a homeowner tenant's month-to-month lease without cause; and (2) therefore, the no-cause terminations of both leases in this case were illegal and invalid. View "Greener Montana Property Management LLC v. Cunningham" on Justia Law

The Supreme Court affirmed the judgment of the district court granting a Partnership's motion for summary judgment and concluding that Tract 3, one of three individual tracts that were carved out from Owners' land for separate ownership by each of the Partnership's owners, was burdened by a thirty-foot easement and could not benefit from it, holding that there was no error.In 1990, Owners conveyed the property at issue to the Partnership and conveyed Tract 3 to R.A. Roehder. The warranty deed conveying the property provided that the property was given together with thirty-foot-wide easements for ingress and egress. Roehder later sold his interest in the Partnership. After Roehder's death, Tract 3 was acquired by Zinvest, LLC by tax deed, and Zinvest conveyed the property to Lee Lou. The Partnership later filed a complaint to quiet title with a declaratory judgment that Lee Lou owned no interest in the easement and only the partnership had an interest in the easement. The court granted summary judgment in favor of the Partnership. The Supreme Court affirmed, holding that the district court did not err in determining that Tract 3 did not benefit from the thirty-foot easement and that tracts 1 and 2 did benefit from the easement. View "Duke Trust v. Lee Lou, LLC" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of the City of Whitefish and affirming the Whitefish City Council's decisions to deny a conditional use permit (CUP) and grant Resolution 21-43, which denied the permit, holding that there was no error in the proceedings below.Whitefish 57 Commercial, LLC and Rimrock Companies, LLC (collectively, Appellants) applied for a CUP to develop a hotel on a lot of their subdivision. After a public hearing on the development project the Council adopted Resolution 21-43 that denied the permit. Appellants appealed, claiming that the Council abused its discretion in denying their CUP. The district court granted summary judgment against Appellants. View "Whitefish 57 Commercial, LLC v. City of Whitefish" on Justia Law

The Supreme Court affirmed the judgment of the district court enforcing a settlement agreement between Duane Bender and Rebecca Estates, LLC (collectively, Bender) and Stacey Rosman providing for Bender's purchase of Rosman's property near Shepherd, holding that the district court did not err.Bender filed suit against Rosman alleging trespass and tortious interference with contract and seeking to quiet title. Prior to trial, the parties reached a settlement agreement providing for the purchase of Rosman's property by Bender. The district court issued an order enforcing the settlement agreement for the price of $202,000. Bender appealed. The Supreme Court affirmed, holding that the district court did not err by concluding that Rosman was entitled to specific performance of the settlement agreement. View "Bender v. Rosman" on Justia Law

The Supreme Court affirmed the order of the district court granting a summary judgment motion filed by Petitioners and two insurers, Farmers Insurance Exchange and Truck Insurance Exchange (collectively, Insurers), and denying Respondent's cross-motion for summary judgment, holding that the district court did not err by finding that Insurers had no duty to defend Respondent under the terms of the relevant insurance policies.After a complaint in the underlying lawsuit alleging slander, malicious prosecution, and bodily injury was amended to add Respondent as a defendant Respondent tendered the complaint to Farmers seeking defense and indemnity under a series of homeowners insurance policies and commercial general liability policies. Later, the Insurers filed a declaratory judgment action seeking a judicial determination that they were not obligated to defend and indemnity Respondent. The district court found that Insurers had no duty to defend Respondent under any of the policies. The Supreme Court affirmed, holding that Respondent failed to meet his burden of demonstrating that the claims fell within the scope of coverage of any of the policies at issue. View "Farmers Insurance Exchange v. Minemyer" on Justia Law

The Supreme Court affirmed the decision of the district court denying Hamilton Southside Historic Preservation Association's (HSHPA) petition for a writ of certiorari challenging four decisions of the Hamilton Zoning Board of Adjustment (ZBA), holding that the district court did not err.Specifically, the Supreme Court held that the district court did not err in determining that the ZBA did not abuse its discretion when it (1) issued a conditional use permit to the Roman Catholic Bishop of Helena to construct and use a new church structure after demolition of the St. Francis Catholic Church; (2) approved a rear-yard setback variance; (3) approved a steeple height variance; and (4) upheld the zoning administrator's approval of a joint use parking agreement for the new structure. View "Hamilton Historic Preservation Ass'n v. Zoning Bd. of Adjustment" on Justia Law

The Supreme Court affirmed the decision and orders entered by the district court in this property dispute, holding that substantial credible evidence supported the district court's finding that Cremer Rodeo Land and Livestock Company obtained a prescriptive easement over two roads across Linda McMullen's property.In 2016, Cremer Rodeo filed this lawsuit seeking a prescriptive easement over the Lien Road and the Medley Roads. After denying McMullen's motion for summary judgment the district court held a bench trial and concluded that Cremer Rodeo had a prescriptive easement over the Lien and Medley Roads. The Supreme Court affirmed, holding that the district court (1) did not err by denying McMullen's motion for summary judgment; (2) did not abuse its discretion by granting Cremer Rodeo leave to amend its complaint; (3) did not err when it concluded that Cremer Rodeo's amended complaint related back to its original complaint; and (4) properly found that Cremer Rodeo obtained a prescriptive easement over the Lien and Medley Roads. View "Cremer Rodeo Land v. McMullen" on Justia Law

The Supreme Court affirmed the order issued by the district court denying Montana Opticom, LLC's motion to disqualify counsel for Scott Rysewyk, holding that the district court did not abuse its discretion by denying the motion to disqualify Rysewyk's counsel.Rysewyk, represented by Rabb Law Firm (RLF), filed a complaint alleging trespass, ejectment, negligent civil conspiracy, and inverse condemnation by Opticom and Jim Dolan, Jr., a partial owner of Opticom. Opticom filed a motion to disqualify Rysewyk's counsel, arguing that Rysewyk's counsel of record was disqualified from representing him because of the firm's earlier representation of Dolan. The district court denied the motion on the grounds that Opticom offered "no proof of any actual prejudice flowing from the alleged conflict of interest." The Supreme Court affirmed, holding that because the district court was presented with no evidence that Opticom was actually prejudiced, the court did not act arbitrarily or exceed the bounds of reason by denying Opticom's motion to disqualify. View "Rysewyk v. Mont. Opticom, LLC" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court determining that the Montana Department of Natural Resources and Conservation (DNRC) erred in granting Montana Artesian Water Company's application for a beneficial use permit and denying Objectors' motion for attorney fees, holding that the district court erred in denying Objectors' motion for attorney fees.The district court vacated the DNRC's order granting Artesian's application for the permit and remanded the case on the grounds that the DNRC improperly relied on an internal agency memorandum in analyzing availability. Artesian appealed, and the Objectors in this case - Flathead Lakers Inc. and Water for Flathead's Future - cross appealed from the deemed denial of their motion for attorney fees. The Supreme Court held that the district court (1) erred by determining that DNRC erroneously granted Artesian's application for a beneficial use permit; and (2) abused its discretion by denying Objectors' fee motion by operation of law. View "Flathead Lakers Inc. v. Mont. Dep't of Natural Resources & Conservation" on Justia Law

The Supreme Court reversed the decision of the district court granting summary judgment to Water for Flathead's Future (WFF) and vacating the Montana Pollutant Discharge Elimination System (MPDES) permit issued by the Montana Department of Environmental Quality (DEQ) to Artesian Water Company, holding that the district court erred.In granting summary judgment, the district court determined that the DEQ had erred by (1) submitting inadequate responses to the comments from the Environmental Protection Agency (EPA) and the United States Fish and Wildlife Services (WSFWS), and (2) DEQ's analysis of the permit's environmental impact was inadequate. The Supreme Court reversed, holding (1) this matter has not been mooted; (2) the district court improperly substituted its own judgment for the agency's in concluding that DEQ, in issuing the permit, had failed to give a "hard look" at relevant concerns; (3) the district court erred by holding that DEQ improperly considered only the volume of water that would be discharged under MPDES permit rather than the full volume of water authorized for use under the DNRC's water use permit; and (4) the district court erred by vacating the permit. View "State v. Noli" on Justia Law