Justia Montana Supreme Court Opinion Summaries

The town of Opportunity is a rural community east of a former copper smelter operated by the Anaconda Company. Between 1884 and 1980, the smelter emitted smoke and fumes containing arsenic and other toxic materials, and particles of these materials settled on the surrounding lands. In 2008, Appellants, property owners in and around the town, filed this action seeking damages for the cost of restoring their properties to their original state. Atlantic Richfield Company (ARCO), the successor in interest to the Anaconda Company, moved for summary judgment on statute of limitations grounds. The district court granted summary judgment for ARCO on all claims. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) application of the continuing tort doctrine based on environmental contamination does not require evidence of that the contamination is migrating; (2) Appellants’ claims of continuing nuisance and trespass are not time-barred if a finder of fact determines that the contamination is reasonably abatable; (3) the district court properly granted summary judgment to ARCO on Appellants’ claims of unjust enrichment and constructive fraud; and (4) the district court applied the incorrect statute of limitations to Appellants’ claim of wrongful occupation. View "Christian v. Atlantic Richfield Co." on Justia Law

At dispute in this case was a home inspection Don Hall performed of a home purchased by Gregory Hall. Gregory brought this action against Don, the seller of the home, and two real estate brokers, alleging that Defendants failed to disclose material defects in the property. The district court entered summary judgment in favor of all defendants with the exception of Don on the grounds that Gregory received a disclosure statement and had imputed knowledge of the defects. The district court entered default judgment against Don after determining that Don had not filed a sufficient answer to the complaint. After a writ of execution was issued, Don requested that the default judgment be set aside and later sought to claim exemptions. The district court denied the requests. The Supreme Court reversed the order of the district court striking Don’s motion to set aside default judgment, holding that, under the circumstances of this case and in the interests of justice, Don was entitled to relief from judgment. Remanded. View "Hall v. Hall" on Justia Law

At dispute in this case was the Crow Water Compact - an agreement among the United States, the Crow Tribe, and the State - which recognizes a Tribal Water Right of the Crow Tribe and its members in a number of sources of water that abut or cross the Crow Indian Reservation in Montana. Here, a group of Crow tribal member Allottees - persons who hold interests in parcels of former Tribal land mostly created by the General Allotment Act - objected to the Compact in the Water Court, claiming that the United States breached its fiduciary duties to the Allottees by failing to protect their water rights in the Compact and failing to adequately represent them in Compact proceedings. The Water Court dismissed the Allottees’ objections. The Supreme Court affirmed, holding that the Water Court (1) applied the proper legal standard of review in dismissing the Allottees’ objections; (2) did not exceed its jurisdiction by dismissing the Allottees’ action rather than staying consideration of the Compact pending resolution of the Allottees’ action in federal district court; and (3) did not err in determining that the Allottees have rights to a share of the Crow Tribal Water Right and that the United States adequately represented the Allottees during the Compact negotiations. View "In re Crow Water Compact" on Justia Law

Farmers Cooperative Canal Company (FCCC) was incorporated in 1897 for the purpose of appropriating, transporting, and using irrigation water from the Teton River. FCCC acquired two water rights with priority dates of 1895 and 1897. FCCC constructed two reservoirs, Harvey Lake Reservoir in 1913 and Farmers Reservoir in 1942. Using its reservoirs, FCCC began to store portions of the water diverted to it during the year, which allowed it to release water as needed throughout the year. Based on its rights and these practices, FCCC filed statements of claim for its 1895 and 1897 rights, claiming use of the two reservoirs as part of those rights. Teton Cooperative Reservoir Company (TCRC) objected to FCCC’s claims, arguing that FCCC’s reservoirs were not part of its 1895 or 1897 rights and, instead, were new, independent appropriations not entitled to the priority dates of either claim. The Water Court concluded that the reservoirs could be used as part of the 1895 and 1897 rights because they did not expand the period of diversion, volume, or flow rate of those rights. The Supreme Court affirmed, holding that the Water Court correctly concluded that FCCC’s reservoirs did not expand FCCC’s water rights and that the reservoirs could be included in FCCC’s 1895 and 1897 rights. View "Teton Coop. Reservoir Co. v. Farmer Coop. Canal Co." on Justia Law

When Donna Anderson failed to pay taxes assessed for her property, the Carbon County Treasurer (Treasurer) conducted a tax lien sale for the property. The County acquired the property when the tax lien failed to sell. Following Anderson’s failure to pay the taxes with a two-week period, Zinvest, LLC paid the taxes and costs to purchase the lien from the County. The Treasurer issued an assignment of tax sale certificate to Zinvest and notified Anderson of the transaction. Zinvest subsequently obtained a property title guarantee. After the redemption period ended and Anderson had failed to pay the delinquent taxes, Zinvest applied for a tax deed, which the Treasurer issued. Zinvest recorded the deed and initiated a quiet title action. Zinvest and Anderson both moved for summary judgment contesting whether the Treasurer had complied with the requirements of the tax deed statutes. After originally granting Zinvest’s motion, the district court vacated its judgment and granted Anderson’s motion for summary judgment. The Supreme Court affirmed, holding that the district court correctly entered judgment in favor of Anderson because the documents used in this transaction contained a number of errors that violated the tax deed statutes and created confusion in the property titling process. View "Zinvest, LLC v. Anderson" on Justia Law

At issue in this case was an easement created by a 1977 real estate Easement Agreement (Agreement). Pursuant to the Agreement, the Grantees installed a pipeline on the Grantor’s property. A new ditch was dug to connect the pipeline to an irrigation ditch known as “Enterprise Ditch.” Defendants eventually acquired the Grantor’s property, and Plaintiff acquired the Grantee’s property. Plaintiff asserted that it was a successor in interest and therefore enjoyed the benefits of the Agreement. Defendants contended that Plaintiff was an assignee under the Agreement and, therefore, that consent was needed for assignment of any rights. The district court granted partial summary judgment to Defendants. The Supreme Court affirmed, holding that the district court (1) was correct in concluding that the easement was in gross, rather than appurtenant; (2) did not err in determining that the Agreement required grantor’s consent to assignment and that Plaintiff had no rights under the Agreement absent a valid consent to assignment from Defendants; and (3) correctly found that Plaintiff did not establish a prescriptive easement in Enterprise Ditch. View "Bos Terra, LP v. Beers" on Justia Law

This dispute arose out of the interpretation of the covenants and bylaws of the Bridger Creek Subdivision Community Association. Bill Beebe, as co-trustee of his wife’s trust, which owned a home in the subdivision, filed a petition for declaratory relief against the Board of Directors of the Association. The Board counterclaimed for unpaid homeowner assessments and dues. Beebe then filed a motion requesting a declaratory judgment supporting his interpretation of certain provisions in the covenants and bylaws that concerned the Association’s collection of assessments from its members. The district court granted Beebe’s motion for declaratory judgment and granted the Board’s motion for summary judgment on its counterclaim for dues and assessments. The court awarded both parties attorney fees and costs. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in granting declaratory judgment in favor of Beebe, as the court’s interpretation of the covenants and bylaws was correct; but (2) erred in awarding attorney fees and costs to Beebe, as equitable considerations did not support such an award in this case. View "Beebe v. Bridger Creek Subdivision Cmty. Ass’n" on Justia Law

Mark Runkle and TAGS Realty, LLC were the locators of several adjacent and overlapping mining claims. This case concerned a pile of mining waste that was located on both Runkle’s and TAGS’s claims. The mining waste contained gold deposits that were not economically viable at the time they were removed from an historic mine. By 2011, however, the deposits became valuable, and Runkle removed and sold all of the waste that year. Runkle also removed the waste located within TAGS’s claim. TAGS filed a complaint asserting trespass and conversion causes of action, alleging that Runkle was not entitled to remove the waste material located on TAGS’s claim. The district court granted summary judgment in favor of Runkle. The Supreme Court reversed, holding that the district court (1) erred in concluding that TAGS’s mining claim was not a property interest sufficient to support TAGS’s causes of action; and (2) erred by granting summary judgment on an issue never raised, addressed, or conceded by the parties. View "TAGS Realty, LLC v. Runkle" on Justia Law

Catherine E.W. Hansen Trust (Hansen Trust), which was issued a tax lien and a tax deed on certain property, filed a complaint to quiet title to the tax deed. The district court granted summary judgment for Hansen Trust and declared the tax deed void as a matter of law, finding that Hansen Trust had not obtained the required property title guarantee and had not provided notice to parties listed in the title guarantee. The court subsequently directed payment of the tax lien and entered final judgment. The district court denied Hansen Trust’s post-judgment motions. The Supreme Court affirmed, holding that the district court (1) correctly granted summary judgment and declared the tax deed void after determining that Hansen Trust failed to provide adequate notice or obtain a property title guarantee; (2) did not err when it directed payment of Hansen Trust’s tax lien; and (3) did not err when it denied Hansen Trust’s post-judgment motions. View "Catherine E.W. Hansen Trust v. Ward" on Justia Law

In 2009, the Montana Department of Revenue (Department) began the process of reappraising Montana agricultural properties. In 2010, Petitioners filed a petition for declaratory judgment and writ of mandate seeking a declaration that the Department improperly assessed their agricultural property for tax uses. The district court granted the Department’s motion for summary judgment. The Supreme Court affirmed, holding (1) the district court correctly interpreted the plain language of section 15-7-111 and complied with the rules of statutory construction; and (2) the Department followed the rule-making mandate of section 15-7-111(2), the Department’s application of section 15-7-111 was not unlawful, and the Department is capable of implementing the district court’s interpretations of section 15-7-111. View "Lucas Ranch, Inc. v. Mont. Dep’t of Revenue" on Justia Law