Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the district court denying Appellants' motion for partial summary judgment and dismissing their inverse condemnation claim against the City of Billings, holding that the district court did not err.Appellants, who owned and resided in a home within the City limits, brought this action seeking to recover damages when 1,000 gallons of raw sewage backed up into their basement. The district court dismissed Appellants' sole claim of inverse condemnation because they did not establish that their damage was caused by the deliberate actions of the City. The Supreme Court affirmed, holding that Appellants failed to establish that the sewer backup was a constitutional damages of their basement for public use, and thus, a condemnation. View "Wittman v. City of Billings" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment to the Department of Environmental Quality (DEQ) and dismissing a complaint alleging that DEQ violated the Montana Environmental Policy Act (MEPA), holding that DEQ was entitled to summary judgment as a matter of law.Montana Rivers, the Gallatin Wildlife Association, and Cottonwood Environmental Law Center (collectively, Plaintiffs) brought this lawsuit alleging that DEQ violated MEPA by failing to supplement a 2007 environmental impact statement (EIS) that DEQ had prepared for a proposed rulemaking by the Board of Environmental Review (Board). In 2013, the Board declined to proceed with that rulemaking by ending its notice and comment period and letting the process expire. The district court ruled that Plaintiffs had no viable MEPA cause of action because there was no longer any contemplated state action for which to supplement the EIS. The Supreme Court affirmed, holding that the district court did not err in concluding that there was no proposed state action pending that would obligate DEQ to prepare or supplement a MEPA analysis. View "Montana Rivers v. Montana Dep't of Environmental Quality" on Justia Law

The Supreme Court affirmed the order of the water court denying Robert and Carol Hurds' motion to amend the water right for a groundwater well on the grounds that the untimeliness of the motion meant the water court lacked jurisdiction to adjudicate the requested modification, holding that there was no error.In 2017, the Montana legislature established a June 30, 2019 deadline for exempt water rights holders to file a statement of claim. The deadline passed without the Hurds filing a statement of claim for their exempt water right. In 2021, the Hurds filed a motion to amend a statement of claim under Mont. Code Ann. 85-2-233(6). The water court concluded that it had no jurisdiction to modify a statement of claim for the Hurds because they hadn't properly filed a claim to amend. The Supreme Court affirmed, holding that the water court correctly denied the Hurds' motion for lack of jurisdiction. View "In re Hurd" on Justia Law

The Supreme Court affirmed the order of the district court granting a motion to approve a settlement agreement reached in mediation involving siblings Lily Smith and Sam, Dan, and Vernon Lindemulder, holding that Petitioners were not entitled to relief on their claims of error.The agreement at issue resolved claims involving the Alice M. Lindemulder Trust, established by the parties' mother, which held more than 2,000 acres of land in Stillwater County. Sam appealed the district court's decision to approve the settlement agreement, arguing that the agreement was unenforceable because he lacked the capacity to enter it and had been subjected to undue influence. The Supreme Court affirmed, holding that the district court (1) did not err in concluding that Sam validly consented to the agreement; and (2) did not err in holding that the agreement was valid and enforceable. View "Smith v. Lindemulder" on Justia Law

The Supreme Court reversed the order of the district court granting summary judgment to J&L Lands, LP and awarding J&L a portion of the proceeds from the sale of Jerry Nezat's homestead property, holding that the homestead exemption statutes disposed of this matter.J&L filed this action against Nezat to foreclose a judgment lien on the property at issue but agreed to lift its lien to allow Nezat to sell the property. After Nezat sold the property the district court granted summary judgment to J&L and awarded J&L up to twenty-five percent of the proceeds from the sale of the home despite Nezat's homestead declaration on the property. The Supreme Court reversed, holding that the district court erred in satisfying J&L's judgment lien before Nezat received the full value of the homestead exemption from the proceeds of the sale. View "J&L Lands, LP v. Nezat" on Justia Law

The Supreme Court reversed in part and affirmed in part the order of the district court granting summary judgment in favor of Lewis and Clark County (County) and Bridge Creek Estates Homeowners Association (HOA) on the County's claim for declaratory judgment and on Philip Wirth's counterclaim against the County, holding that the district court erred in part.Specifically, the Supreme Court held that the district court (1) erred in its interpretation of the covenants by concluding that Wirth was unambiguously prevented from further subdividing the lots retained by him within the subject subdivision, in failing to consider extrinsic evidence, and by resolving the issue at summary judgment; (2) erred by granting summary judgment to the County and dismissing Wirth's counterclaim for statutory damages; (3) did not err in granting summary judgment to the HOA; and (4) prematurely granted attorney fees to the HOA. View "Wirth v. Lewis & Clark County" on Justia Law

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

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

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

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