Justia Montana Supreme Court Opinion Summaries

The Northland Royalty Corporation purchased mineral rights from the personal representative of two estates and subsequently brought a quiet title action naming certain beneficiaries (“Devisees”) as defendants. The district court quieted title in favor of Devisees, but the Supreme Court remanded to consider the applicability of Mont. Code Ann. 72-3-618. On remand, Northland moved for summary judgment, arguing that section 72-3-618 offered Northland protection against Devisees’ claims to the minerals. The district court denied summary judgment on the basis that Northland failed to act in good faith as required by the statute. The Supreme Court reversed the district court’s order denying summary judgment and remanded for entry of judgment in Northland’s favor, holding that section 72-3-618 protected Northland’s purchase. View "Northland Royalty Corp. v. Engel" on Justia Law

The district court entered a temporary injunction preventing Linda St. Peter, acting in her capacity as the trustee of the Osorio Irrevocable Trust, from selling a property held by the trust. Linda filed a motion for relief from the temporary injunction. After a hearing, the district court dissolved the temporary injunction. The property was then sold to a third party. Karlene Khor, Linda’s sister, appealed, arguing that the district court manifestly abused its discretion when it dissolved the temporary injunction. The Supreme Court did not address the merits of the issue because the property had been sold and the issue was therefore moot. View "Matter of Osorio Irrevocable Trust" on Justia Law

Robert Mead died in 2011, survived by his daughters, Roberta Jean Mead and Bobbi Jo Harr. Roberta initiated intestate proceedings, but Bobbi Jo petitioned for formal probate of Robert’s purported will. Roberta and Bobbi Jo filed cross-motions for summary judgment about the will’s validity and enforceability. The district court concluded that the will was valid and enforceable and granted judgment in favor of Bobbi Jo. Roberta appealed. The Supreme Court affirmed, holding that the district court correctly concluded that the will was valid and enforceable because it was properly executed and not the result of undue influence. View "In re Estate of Mead" on Justia Law

After executing her last will and testament in Montana, Laura Jean Kelly, who neither married nor had children, died at age sixty-two. Laura’s siblings petitioned the district court for a determination that Laura’s interest in a family partnership was not part of her residuary estate. The district court concluded that Laura’s interest in the family partnership was a non-probate asset and did not constitute part of the residue of Laura’s estate. As such, Laura’s partnership interest passed to Laura’s siblings, her “heirs-at-law.” Laura’s niece appealed. The Supreme Court affirmed, holding that the district court did not err in its interpretation of the term “heirs,” its application of Montana law, and its conclusions of law. View "In re Estate of Kelly" on Justia Law

After Norman Benjamin, the father of Delmar and Cecil, passed away, Cecil, who was named personal representative in Norman’s will, filed a petition for determination of testacy, for determination of devisees and for settlement and distribution of a testate estate. After a hearing, the probate court entered a decree approving the petition, which designated Norman’s wife, Joyce, as the sole devisee under the will. Delmar filed an action against Cecil and Joyce, alleging that Cecil violated his fiduciary duty by distributing Norman’s tangible personal property by distributing it among Norman’s other children, but not to Delmar. The district court dismissed the complaint, concluding that it lacked subject matter jurisdiction over Delmar’s claim. Subsequently, Delmar filed a petition to reopen probate, alleging that Cecil misrepresented the extent of Norman’s tangible personal property and engaged in self-dealing with regard to this property and that there was newly discovered tangible personal property that needed to be distributed. The district court sua sponte denied Delmar’s petition under principles of res judicata. The Supreme Court reversed, holding that res judicata did not bar Delmar’s fraud and newly discovered tangible personal property claims in this case. View "In re Estate of Benjamin" on Justia Law

James Altenhofen was the trustee of the Gibbs’ family trust and Delwin Nordtvedt was the successor trustee. Nordtvedt filed an action requesting that the court determine whether any restrictions existed in the trust agreement limiting the trustee’s power to sell the real and personal property included in the trust estate. The Gibbs filed cross-claims against Nordtvedt. The district court granted summary judgment for Nordtvedt, concluding that the prudent investor rule called for the sale of certain property. The Gibbs then filed a complaint against Nordtvedt and Altenhofen, alleging breach of fiduciary duty. The trial court concluded (1) the claims against Nordtvedt were barred by the doctrines of issue preclusion, judicial estoppel, and claim preclusion; and (2) the claims against Altenhofen were barred by the statute of limitations. The Supreme Court affirmed in part and reversed and remanded in part, holding that the district court (1) erred in finding that some of the Gibbs’ claims against Nordtvedt were barred by the doctrine of claim preclusion; (2) did not err in finding that some of the Gibbs’ claims were barred by the doctrines of judicial estoppel and issue preclusion; and (3) did not err in concluding that the claims against Altenhofen were time-barred. View "Gibbs v. Altenhofen" on Justia Law

Decedent was the sister of Linda Hyde and the mother of Kelli Martin. Martin petitioned the district court to adjudicate that her mother died intestate and to appoint her as Decedent's personal representative. Hyde opposed the petition, asserting that Decedent had previously executed a will naming Hyde as executrix. The district court concluded that Decedent had revoked the will, and therefore ruled that Harless died intestate and that Martin was entitled to be appointed as personal representative. The Supreme Court reversed, concluding that Decedent's will was a valid will that Decedent did not revoke. Remanded with instructions that Decedent's will be probated. View "In re Estate of Harless" on Justia Law

Dorothy Gopher, an enrolled member of the Blackfeet Tribe, died intestate in 2008. Dorothy was survived by seven children (the siblings), and her estate consisted only of a ceremonial tribal flag. One of the siblings, filed an application for informal probate in the district court. As proceedings commenced in district court, several siblings filed a petition before the Blackfeet tribal court to name two other siblings as personal representatives in their parents' estates. The two siblings then filed consecutive motions to dismiss for lack of subject matter jurisdiction in district court. The district court continued its proceedings and denied the motions to dismiss. The district court concluded that it had jurisdiction over the parties and subject matter jurisdiction and ordered the estate to transfer the flag to co-trustees of a constructive trust on the estate. Meanwhile, the Blackfeet tribal court declined to assert jurisdiction over the estate property. The Supreme Court affirmed, holding that the district court did not err when it assumed jurisdiction over the probate of the estate. View "In re Estate of Gopher" on Justia Law

After John Irvine died, the proceeds from three of his investment accounts were paid to his estate. John's mother, Va Va, sought a declaratory judgment that she was the sole beneficiary of all three accounts. John's stepson, Michael, opposed the action. Both Va Va and Michael filed summary judgment motions. Va Va argued that John intended to benefit his estate under the laws of intestacy, not under the terms of his 1983 will, which included Michael as a beneficiary, and that John intended for her to be the contingent beneficiary for all three accounts. To support her contention, Va Va offered testimony from John's financial planner, who testified that he erroneously believed that John did not have a will when he executed beneficiary designation forms for a number of accounts. Va Va argued that the written contracts should be reformed for mutual mistake. The district court concluded that Michael was entitled to summary judgment under the contract terms and that no legal basis existed to require reformation of the contracts. The Supreme Court affirmed, holding that the district court correctly determined that (1) the contracts could not be reformed; and (2) proceeds from John's investment accounts were properly paid to his estate. View "Estate of Irvine v. Oaas" on Justia Law

Decedent, the mother of Cathie and Marcy, died testate. Decedent's will expressly made no provision for her daughters. Decedent named Kristine Fankell as the personal representative of her estate. After Fankell's application for informal probate was accepted, Marcy filed a petition for supervised administration of the estate and a petition for formal probate of the will. Cathie subsequently filed an objection to the application and appointment of Fankell as personal representative as well as a motion for substitute of judge. The district court (1) denied Cathie's motion for substitution of judge as untimely, and (2) granted Fankell's motion to strike Cathie's pleadings because she failed timely to intervene and her interests were adequately represented by Marcy. The Supreme Court affirmed the district court's denial of Cathie's motion for substitution of judge, holding that the court correctly determined Cathie's motion was untimely. View "In re Estate of Quirin" on Justia Law