Justia Montana Supreme Court Opinion Summaries

Articles Posted in Real Estate & Property Law
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The Supreme Court affirmed the judgment of the district court dismissing the final count of Plaintiff's complaint after granting summary judgment in favor of Plaintiff's declaratory judgment and issuing a permanent injunction against Defendants, holding that there was no error or abuse of discretion.Plaintiff filed a complaint seeking a declaration that Defendants had materially breached an agreement regarding a shared water well and requesting injunctive relief barring Defendants from interfering with Plaintiff's use of the well. The district court granted a permanent injunction and declaratory relief and then dismissed Plaintiff's breach of contract claim. The Supreme Court affirmed, holding that the district court (1) properly granted summary judgment to Plaintiff based on the language the agreement limiting water usage; (2) did not abuse its discretion in granting injunctive relief; and (3) did not abuse its discretion in denying Defendants' motion for leave to amend. View "Estate of Mandich v. French" on Justia Law

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The Supreme Court affirmed the order of the district court granting summary judgment on a quiet title action and related counterclaims to Plaintiffs, holding that there was no error.In this case concerning an approximately thirty-acre property Plaintiffs brought a quiet title action against Defendants. Defendants asserted a counterclaim against Plaintiffs for constructive fraud. The district court granted summary judgment in favor of Plaintiffs. The Supreme Court affirmed, holding that the district court (1) did not err in finding that Plaintiffs gained ownership of the disputed property through adverse possession; and (2) did not err in granting summary judgment to Plaintiffs on Defendants' fraud claim. View "Hart v. Hale" on Justia Law

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In this real property dispute, the Supreme Court affirmed the judgment of the district court awarding a total of $360,000 to Corey Rubin and Don Hauth in the lower court proceedings against Brent and Grace Hughes, holding that the district court did not err or abuse its discretion.Rubin and Health filed a complaint against the Hugheses seeking a declaratory judgment as to their respective easements, a temporary restraining order, and injunction, and alleging that the Hugheses' behavior constituted a nuisance, interfered with the use of their easements, and caused them mental distress. The district court entered judgment against the Hugheses. The Supreme Court affirmed, holding that the district court (1) properly denied the Hugheses' motion for a directed verdict; (2) did not err in determining that the Hugheses did not have an easement that entitled them to specific performance; (3) did not err in waiving the statutory cap on punitive damages; and (4) did not abuse its discretion in excluding evidence of Rubin's unenforceable agreement to grant the Hugheses an easement. View "Rubin v. Hughes" on Justia Law

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The Supreme Court affirmed the judgment of the district court in this litigation related to the expansion of an agricultural zoning district through citizen initiative to include the area where Montana Artesian Water Company had been developing a large-scale water bottling plant, holding that there was no error or abuse of discretion.At issue on appeal was whether Montana Artesian's water bottling facility was a valid nonconforming use under the Egan Slough Zoning District Regulations. Montana Artesian raised numerous issues on cross appeal. The Supreme Court affirmed, holding that the district court (1) properly denied Montana Artesian's motion for summary judgment on the validity of the ballot initiative process; (2) did not err in affirming the conclusion that Montana Artesian's facility was a legal nonconforming use; and (3) did not err in concluding that the initiative was not unconstitutional or illegal reverse spot zoning. View "Egan Slough Community, Yes! v. Flathead County Board of County Commissioners" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying relief to Appellant Advocates for School Trust Lands on its claim that House Bill 286 (HB 286), passed by the 2019 Montana Legislature and codified as Mont. Code Ann. 85-2-441, is unconstitutional, holding that there was no error.Appellant brought this action alleging that HB 286 is facially unconstitutional because it violates the State's trust obligations imposed by the 1889 Enabling Act and the Montana Constitution by creating a presumption against State ownership in ground water diverted from private property for use on leased school trust land, thereby reducing the value of those lands. The district court granted summary judgment to the State, concluding that Appellant's claim was unripe and that its proposed amendment was futile. The Supreme Court affirmed, holding that the district court (1) did not err by granting summary judgment to the State; and (2) did not abuse its discretion in denying Appellant's motion to amend its complaint. View "Advocates v. State" on Justia Law

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The Supreme Court affirmed the order of the Water Court that adjudicated the priority dates for certain of its water rights in Basin 40B in Petroleum County, holding that the Water Court did not err.Specifically, the Supreme Court held that the Water Court (1) did not err in concluding that the water rights to much of the irrigated acreage owned by Twin Creeks Farm & Ranch had been abandoned been the initial claimed priority date of 1903 and later irrigation development around 1968; and (2) was correct to grant Twin Creeks an implied claim with a 1968 priority date rather than tying the later irrigated acreage to the original 1903 claim. View "Twin Creeks Farm & Ranch, LLC v. Petrolia Irrigation District" on Justia Law

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The Supreme Court affirmed the order of the district court confirming the division of property owned by Cynthia, Kenneth, and Daniel Morley, as set forth in a referees report to the court, holding that the district court did not err.Daniel brought a complaint for partition of real and personal property seeking to partition real property in which he inherited an undivided one-third interest. The other two tenants in common were Cynthia and Kenneth. Appointed referees determined how the property should be divided, and the district court entered an order confirming the referees' division of property. The Supreme Court affirmed, holding that the district court (1) did not err by adopting the referees' report without holding an evidentiary hearing on Cynthia and Kenneth's objections; and (2) did not err by accepting the referees' division of costs. View "Morley v. Morley" on Justia Law

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The Supreme Court affirmed the decision of the district court denying Plaintiffs' motions for default judgment and for summary judgment and granting the summary judgment of Defendants, holding that there was no error.In the midst of a dispute over real property, Plaintiffs filed an action to quiet title. The district court denied Plaintiffs' motion for summary judgment and granted Defendants' motion for summary judgment on Plaintiffs' quiet title claim. The Supreme Court affirmed, holding that the district court (1) did not manifestly abuse its discretion by declining to enter a default judgment in favor of Plaintiffs after Defendants did not complete service of their answer until one day after the deadline of Mont. R. Civ. P. 12; and (2) did not err when it determined that Plaintiffs' claims were barred by the doctrine of laches. View "Carter v. Badrock Rural Fire District" on Justia Law

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The Supreme Court affirmed the order of the district court granting Lease Option Solution, LLC's (LOS) motion for summary judgment on lien property and entering judgment in favor of ACI Construction, LLC on its unjust enrichment claim, holding that the district court did not err.ACI filed this action for lien foreclosure, naming as defendants all parties with liens or interest in the property and alleging, as relevant to this appeal, unjust enrichment against LOS. LOS sought summary judgment regarding priority of liens on certain property. The district court granted summary judgment to LOS on the issue of lien priority and entered judgment for ACI on its unjust enrichment claim. The Supreme Court affirmed, holding that the district court (1) did not err in its determination of lien priority; and (2) did not err by determining that ACI was entitled to recover under the theory that LOS was unjustly enriched. View "A.C.I. Construction, LLC v. Elevated Property Investments, LLC" on Justia Law

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The Supreme Court affirmed the decision of the district court upholding the Broadwater Conservation District's (BCD) declaratory ruling determining that Montana Gulch is a "stream" subject to the regulatory provisions of The Natural Streambed and Land Preservation Act of 1975, Mont. Code Ann. 75-7-103, holding that there was no error.Specifically, the Supreme Court held (1) the BCD and the district court did not err in determining that Montana Gulch could be classified as a "natural, perennial-flowing stream" under the jurisdiction of the Streambed Act upon a finding that it would have flowed perennially without human activity; (2) the BCD properly examined historical evidence when determining whether Montana Gulch would have flowed perennially in the absence of human activity; (3) the BCD's determination that Montana Gulch was under the Streambed Act's jurisdiction was not arbitrary and capricious; and (4) the BCD and the district court did not err in considering subsurface flows in Montana Gulch. View "Fortner v. Broadwater Conservation District" on Justia Law