Justia Montana Supreme Court Opinion Summaries

This was the fourth appeal involving public access across Appellee's Teton County property. In previous litigation, Public Land/Water Access Association established public prescriptive easements over two roads and a bridge connecting the roads, which together formed a route across the property. In this appeal, the Association challenged a decision of the district court denying its petition for supplemental relief and dismissing its complaint against Appellee for damages resulting from his removal of the bridge. The Supreme Court reversed, holding that the district court erred by dismissing the Association's claims and denying its petition for supplemental relief after Appellee removed the bridge, as (1) the district court's dismissal of the Association's complaint was based on an incorrect legal interpretation; and (2) given the scope of the prescriptive easement, the Association was entitled to consideration of its petition for supplemental relief. View "Pub. Land/Water Access Ass'n, Inc. v. Jones" on Justia Law

Defendant jointly owned real property as tenants in common with her sister, Plaintiff. Plaintiff filed a partition action, seeking equitable partition of the property or, in the alternative, a forced sale of the property and equal division of the net sale proceeds. Three partition referees appointed by the district court submitted a final report recommending that the property be divided into two parcels. Defendant presented offers of proof challenging the referees' final report, but the district court confirmed the proposed partition. Defendant appealed, arguing that the district court erred by denying her request for an evidentiary hearing. The Supreme Court reversed the district court's final partition judgment, holding (1) when a party makes a substantiated claim of factual or legal error in the referees' report, due process and equitable concerns require the district court to hold a hearing to determine whether the referees' report equitably divides the real property prior to confirming, changing, or modifying the report; and (2) in this case, Defendant's objections were sufficient to compel the district court to hold an evidentiary hearing. Remanded for an evidentiary hearing. View "Britton v. Brown" on Justia Law

Kristy Johnston, Judy Olsen, and their mother, Joyce Johnston, owned real property as tenants in common. Joyce left her one-third interest in the property to Kristy when she died. Kristy sent a letter to Judy in 2009 in which she offered to buy Judy's interest in the property or to sell her interest to Judy. Judy accepted Kristy's offer to sell. Kristy subsequently attempted to reject Judy's acceptance and revoke her offer to sell. Judy filed a complaint against Kristy. The court granted Judy's motion for summary judgment, determining that the letters exchanged between Judy and Kristy had created an enforceable contract that satisfied the statute of frauds. The Supreme Court affirmed, holding that the district court properly concluded that the parties' exchange of letters created an enforceable contract. View "Olsen v. Johnston" on Justia Law

Defendant owned a building and leased spaced in the building to Company. Plaintiff worked as an independent contractor for Company, providing cleaning services. After Plaintiff injured himself while working in Defendant's building, Plaintiff sued Defendant. The district court granted summary judgment to Defendant. The Supreme Court reversed, holding (1) the district court erred in applying construction industry liability standards to this case and in determining that Defendant owed no duty that Defendant as a property owner had a duty of care to Plaintiff because Plaintiff was an independent contractor working for Company; and (2) the court further erred in granting summary judgment to Defendant based upon the determination that "no reasonable jury" could find that Defendant had breached the duty of ordinary care under the facts of the case. View "Steichen v. Talcott Props., LLC " on Justia Law

MCR, LLC filed an action for condemnation of a compressor station site on property owned by Appellees. Appellees counterclaimed against MCR for damage to their property and claimed punitive damages. Appellees sought restoration costs as the measure of damages for their contract, trespass, and nuisance claims. The parties stipulated to the substitution of MCR Transmission, LLC (MCR-T) for MCR on the condemnation claim. The district court dismissed MCR-T's condemnation claim and granted Appellees' summary judgment motion allowing Appellees to seek restoration costs. The jury awarded restoration costs and punitive damages to Appellees. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court (1) erred in dismissing MCR-T's motion to condemn Appellees' property for a compressor station, as genuine issues of material fact existed as to whether Appellees' property was necessary for the compressor station; (2) properly determined that Appellees were entitled to seek restoration costs as the measure of their damages; and (3) properly admitted evidence at trial that MCR had jumped Appellees' bid on state trust land leases. View "McEwen v. MCR, LLC" on Justia Law

Boyne USA, Inc. filed an action for breach of contract against Blixseth Group, Inc. that covered a land sale for fifteen acres of property, seeking specific performance. Boyne joined Yellowstone Mountain Club, LLC (Yellowstone) as a party due to Yellowstone's acquisition of the contested property. Meanwhile, Yellowstone conveyed the property to Spanish Peaks Development, LLC (SPD). SPD, in turn, conveyed the property to Lone Mountain Holdings, LLC (LMH). Boyne joined SPD and LMH as parties. Boyne further alleged abuse of the legal process and deceit. The district court dismissed Blixeth Group and Yellowstone due to Yellowstone's bankruptcy. After a jury trial, (1) the jury awarded Boyne $300,000 from each SPD and LMH based on its determination that Defendants had deceived Boyne and had abused the legal process, (2) the district court awarded Boyne specific performance on the agreement; and (3) the court awarded attorney fees to Boyne. The Supreme Court affirmed subject to one minor modification, holding that the district court did not err in its judgment, and that Boyne was entitled to legal fees on appeal. View "Boyne USA, Inc. v. Spanish Peaks Dev., LLC" on Justia Law

This appeal was the third in the course of this litigation. Plaintiffs were a group of landowners with properties on the shores of Flathead Lake and a portion of the upper Flathead River. Plaintiffs commenced this action in 1999 against Montana Power Company (MPC) and MPC's successor, PPL Montana, LLC, asserting claims of trespass, nuisance, a taking of property, and breach of easements. In Mattson II, Plaintiffs filed motions to certify the lawsuit as a class action. The district court granted the motions as to both Defendants. The Supreme Court vacated the district court's orders concerning class certification. On remand, the district court denied Plaintiffs' renewed motion for class certification. The Supreme Court reversed, holding (1) the district court erred in its application of Mattson II to the class-certification question under Mont. R. Civ. P. 23; and (2) the six criteria for certification of a class action under Rule 23 were satisfied in this case. Remanded with instructions to certify the class. View "Mattson v. Mont. Power Co." on Justia Law

Decedent's will divided his estate among his wife (Wife) and his sons and left to Wife all of their jointly-owned vehicles and other property. At the time of Decedent's death he and Wife owned a motor home as joint tenants with the right of survivorship. There was an outstanding purchase money security interest on the motor home, and both Decedent and Wife signed the loan document, which specifically provided that each of them was independently obligated for the full amount of the debt. Wife filed a claim against Decedent's Estate for one half the debt on the motor home. The Estate's Personal Representative denied Wife's claim. The district court (1) applied a majority common-law rule from other states providing that Decedent's estate has an equitable duty to pay its aliquot share of debts on such jointly-held property, and (2) held the equitable outcome was to allow Wife's claim against the Estate. The Supreme Court reversed, holding that the district court erred in concluding that Montana law would, as a matter of equity under common law, require Decedent's Estate to pay half of the outstanding security interest in the motor home that became Wife's sole property upon Decedent's death. View "In re Estate of Afrank" on Justia Law

In this dispute over real property, Roslyn Shephard, in her capacity as personal representative of the estates of real property owners (Lessors), terminated the third lease of Lessees based on an alleged violation of the terms of the lease. Shephard then sued Lessees, seeking to invalidate Lessees' third lease due to the fact that she had not signed it on Lessors' behalf. Shephard alternatively sought an order declaring that Lessees had breached the terms of the lease. Lessees counterclaimed, alleging that Shephard had breached the terms of the lease by wrongfully terminating the lease and by failing to provide notice to them of the alleged breach. The district court found in favor of Lessees. The Supreme Court affirmed, holding (1) the district court correctly determined that the lease was valid without Shephard's signature; (2) substantial evidence supported the district court's finding that Lessees had not violated the lease; and (3) the district court correctly determined that the terms of the lease entitled Lessees to notice of their alleged breach and an opportunity to cure. View "Shephard v. Widhalm" on Justia Law

Helena Sand and Gravel, Inc. (HSG) challenged Lewis and Clark County's decision to adopt a citizen-initiated proposal to configure a zoning district that favored residential uses and prohibited mining. The district court entered summary judgment in favor of the County, concluding that the County had properly adopted the zoning pattern and regulations creating the district, and the County's zoning decision did not constitute a taking of HSG's property. The Supreme Court affirmed in part and remanded, holding (1) the County's decision to adopt the zoning pattern and regulations for the district was not clearly unreasonable or an abuse of discretion; (2) the County's adoption of zoning regulations prohibiting sand and gravel mining did not constitute illegal reverse spot zoning; and (3) because HSG had a constitutionally protected property interest in property within the district, the Court granted HSG's request for remand to the district court for the parties to brief the Penn Central takings test, narrowly limited to whether the County's adoption of the zoning pattern and regulations in the district constituted a taking of HSG's real property interest without just compensation. View "Helena Sand & Gravel, Inc. v. Planning & Zoning Comm'n" on Justia Law