Justia Montana Supreme Court Opinion Summaries

Jesse Beck died in a motorcycle accident in Carbon County, Montana. Four days before his death, Jesse sent his brother, Jason Beck, a phone video in which he expressed his wish to leave all his possessions to Jason, explicitly excluding Christina Fontineau. Jesse's only child, Alexia Beck, was appointed as the personal representative of his estate. Jason later sought to probate the video as Jesse's will, arguing it should be considered a valid testamentary document.The Twenty-Second Judicial District Court of Carbon County denied Jason's petition, ruling that the video did not qualify as a "document or writing upon a document" under Montana Code Annotated § 72-2-523. The court reasoned that the statute's language implied a physical or digital document capable of being written upon and signed, which a video recording could not satisfy. The court also noted that even if a video could be considered a document in a general sense, it did not fit within the statutory context requiring a document to be written on.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decision. The court held that the video recording did not meet the statutory requirements for a will under § 72-2-523, MCA. The court emphasized that the statute's language and structure clearly implied that a "document" must be a physical or digital file capable of being signed and witnessed, which a video recording could not fulfill. The court also noted that there was no legislative or judicial precedent for recognizing nonwritten, video wills under the Uniform Probate Code. Consequently, the court affirmed the denial of Jason's petition to probate the video as Jesse's will. View "In re Estate of Beck" on Justia Law

Vernon K. Stensvad, the plaintiff, owns a small cattle herd and entered into a Grazing Lease Contract with Newman Ayers Ranch, Inc. in July 2022. The contract stipulated that Stensvad would graze his cattle on Ayers Ranch's property for a fee, with higher winter rates to be determined. Stensvad paid the fees for July and August but later agreed orally to perform labor in exchange for reduced fees. Disputes arose over the quality of Stensvad's work and the amount owed. In October 2023, Ayers Ranch issued an agister’s lien for $78,662.50, seizing Stensvad’s herd. Stensvad sought a preliminary injunction to prevent the sale of his cattle under the lien.The Seventh Judicial District Court in Prairie County granted Stensvad’s application for a preliminary injunction, ordering the cattle to be moved to a third-party feed lot. Ayers Ranch appealed, arguing that the District Court failed to consider all four factors required for a preliminary injunction under Montana law and that a preliminary injunction was not an appropriate remedy for challenging an agister’s lien.The Montana Supreme Court reviewed the case and held that the District Court manifestly abused its discretion by not addressing all four factors of the preliminary injunction standard. The Supreme Court clarified that under the revised standard, a party must satisfy all four factors: likelihood of success on the merits, likelihood of irreparable harm, balance of equities, and public interest. The Court adopted the "serious questions" test from the Ninth Circuit, allowing for flexibility in evaluating these factors. The case was remanded for the District Court to make supplemental findings consistent with this standard. The Supreme Court also held that a preliminary injunction is an appropriate remedy to challenge an agister’s lien and that Stensvad did not have an adequate remedy at law. View "Stensvad v. Newman Ayers Ranch" on Justia Law

Dr. Stephen D. Behlmer sought declaratory relief to establish his right to access his property in the Scratchgravel Hills via a road that crosses various parcels owned by multiple property owners within the Treasure Canyon Estates subdivision. Behlmer's property is surrounded by land managed by the Bureau of Land Management (BLM) and is accessible by traveling through Treasure Canyon Drive, which runs through the Landowners' properties. Behlmer has a lease from the United States to access his property via BLM land, effective until 2037.The First Judicial District Court, Lewis and Clark County, dismissed Behlmer's petition for failure to join the United States as a required party, as the Landowners argued that the petition would prejudice federal interests. Behlmer amended his petition to clarify that he only sought a declaration of his rights relative to the portion of Treasure Canyon Drive traversing the Landowners' private property, not any BLM land. Despite this, the District Court granted the Landowners' motion to dismiss under M. R. Civ. P. 12(b)(7).The Supreme Court of the State of Montana reviewed the case and reversed the District Court's decision. The Supreme Court held that the United States was not a required party under Rule 19 because its absence would not frustrate complete relief to the parties nor prejudice the United States' interests. The court determined that Behlmer's petition pertained only to the Landowners' interests and did not affect any adjacent property holders, including the United States. Therefore, the District Court abused its discretion in dismissing Behlmer's petition for failure to join a required party. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "Behlmer v. Crum" on Justia Law

On December 12, 2022, Joseph Benton Flynn was convicted of misdemeanor Driving Under the Influence (DUI) in Helena Municipal Court after pleading no contest. Prior to his plea, Flynn's motions to suppress evidence due to lack of particularized suspicion for the initial stop and to dismiss for lack of a speedy trial were denied. Flynn appealed these denials to the First Judicial District Court, which affirmed the Municipal Court's decisions.Flynn's appeal to the Montana Supreme Court raised two issues: whether there was particularized suspicion to stop him for speeding and whether his right to a speedy trial was violated. The Montana Supreme Court reviewed the case de novo.The court found that Officer Jessica Cornell had particularized suspicion to stop Flynn based on her training, experience, and the RADAR sign indicating Flynn was speeding. The court also held that the RADAR sign did not constitute an automated enforcement system prohibited by Montana law. Therefore, the initial stop and subsequent DUI investigation were justified, and the motion to suppress was correctly denied.Regarding the speedy trial claim, the court applied the four-factor balancing test from State v. Ariegwe. The total delay was 742 days, with 480 days attributed to Flynn due to his motions for continuances and waivers of his right to a speedy trial. The court found Flynn's responses to the delays did not demonstrate a desire for a speedy trial, and he failed to show prejudice from the delay. Consequently, the court concluded that Flynn's right to a speedy trial was not violated.The Montana Supreme Court affirmed the District Court's decision, upholding Flynn's conviction. View "State v. Flynn" on Justia Law

Philadelphia Indemnity Insurance Company (Philadelphia), a Pennsylvania-based insurer, brought claims of malpractice, indemnity, and contribution against Martin O’Leary, Kimberly Forrester, and the Sedgwick LLP Liquidating Trust (Sedgwick Defendants). The Sedgwick Defendants, former employees of the now-bankrupt Sedgwick LLP, had provided legal services to Philadelphia. The claims arose from a Montana class action lawsuit involving Gateway Hospitality, Inc. (Gateway), which Philadelphia had insured. Sedgwick advised Philadelphia to deny coverage to Gateway, leading to a settlement where Gateway paid approximately four million dollars to class members.The Fourth Judicial District Court in Missoula County granted the Sedgwick Defendants' Motion to Dismiss for Lack of Personal Jurisdiction. The court found that Philadelphia failed to establish that the Sedgwick Defendants had sufficient contacts with Montana to warrant jurisdiction. Philadelphia appealed this decision, arguing that the Sedgwick Defendants' actions related to the Montana lawsuit should subject them to Montana's jurisdiction.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The court held that the Sedgwick Defendants did not have sufficient contacts with Montana to establish personal jurisdiction. The Sedgwick Defendants' actions, including providing legal advice and sending a denial letter from California to Ohio, did not constitute transacting business or committing a tort in Montana. The court concluded that the Sedgwick Defendants' conduct did not create a substantial connection with Montana, and thus, the exercise of personal jurisdiction was not appropriate. View "Philadelphia Indemnity Insurance Co. v O'Leary" on Justia Law

Dennis Schaub and Louise Schaub were married in 1980, divorced in 2010, and reunited in 2014, establishing a common law marriage. They separated again in 2017, and Louise filed for dissolution in 2018. During their first divorce, they had a property settlement agreement that heavily favored Dennis. After their second separation, the District Court awarded Dennis most of the marital assets, citing the short reconciliation period and Louise's lack of contribution to the marital estate.The Twelfth Judicial District Court initially awarded Dennis his bank accounts, real property, vehicles, and other personal property, while Louise received only her personal items. Louise appealed, and the Montana Supreme Court remanded the case, instructing the District Court to reconsider the equitable distribution of the marital estate, taking into account the factors in § 40-4-202, MCA, and the couple's long marital history.On remand, the District Court held a hearing and found that Dennis's estate was valued at $569,341.08, while Louise's was valued at $0. The court ordered Dennis to make equalization payments to Louise totaling $242,400 over fifteen years to achieve a more equitable distribution of the marital estate, with Dennis receiving 58% and Louise 42%. The court did not require Dennis to pay interest on these payments.The Montana Supreme Court reviewed the case and affirmed the District Court's decision to award equalization payments, finding it supported by substantial evidence. However, the Supreme Court reversed the decision not to include interest on the payments, citing § 25-9-205, MCA, which mandates interest on judgments. The case was remanded to the District Court to amend the decree to include interest and correct a scrivener's error in the payment schedule. View "In re Marriage of Schaub" on Justia Law

The case involves a challenge to two Montana laws, HB 544 and HB 862, and a rule adopted by the Montana Department of Public Health and Human Services (DPHHS) regarding Medicaid funding for abortions. The plaintiffs, including Planned Parenthood of Montana and other healthcare providers, argue that these provisions infringe on the constitutional rights of their patients by imposing restrictions on Medicaid coverage for abortions. Specifically, the laws and rule bar Medicaid from covering abortions provided by non-physicians, require prior authorization for abortion services, and limit Medicaid coverage to abortions deemed "medically necessary" under a restrictive definition.The First Judicial District Court of Lewis and Clark County issued a preliminary injunction to halt the enforcement of HB 544, HB 862, and the DPHHS rule. The court found that the plaintiffs were likely to succeed on the merits of their claims, which included violations of the right to privacy and equal protection under the Montana Constitution. The court applied strict scrutiny, determining that the laws and rule were not narrowly tailored to serve a compelling state interest. The court also found that the plaintiffs would suffer irreparable harm without the injunction and that the balance of equities and public interest favored granting the injunction.The Montana Supreme Court reviewed the case and affirmed the District Court's decision to grant the preliminary injunction. The Supreme Court agreed that the plaintiffs were likely to succeed on the merits, as the challenged provisions infringed on the fundamental right to privacy and equal protection. The court held that the state failed to demonstrate that the laws and rule were narrowly tailored to address a medically acknowledged, bona fide health risk. The Supreme Court also found that the plaintiffs would suffer irreparable harm without the injunction and that the balance of equities and public interest supported maintaining the injunction. View "Planned Parenthood v. State" on Justia Law

J.F.R., an 80-year-old individual diagnosed with cognitive impairments and dementia, lives with her daughter Stephanie in Montana. A dispute arose between Stephanie and J.F.R.'s other daughter, Jana, regarding J.F.R.'s care and financial management. Jana filed a petition for the appointment of both daughters as co-guardians and co-conservators, while J.F.R. supported Stephanie's appointment as sole guardian and conservator. The District Court initially appointed both daughters as temporary co-guardians and co-conservators but later vacated this order, directing the parties to proceed with discovery.The District Court of the Third Judicial District, Granite County, held a hearing and found substantial evidence of financial mismanagement and communication issues between the daughters. The court noted that J.F.R.'s assets were being depleted rapidly and that her current advisors were insufficient to protect her financial interests. Consequently, the court appointed the Western Montana Chapter for Prevention of Elder Abuse (Western) as J.F.R.'s temporary conservator and Western, Stephanie, and Jana as temporary co-guardians.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The court held that the District Court did not err in determining that J.F.R.'s welfare required immediate action, justifying the appointment of a temporary guardian and conservator. The court also found no abuse of discretion in appointing Western, despite the statutory order of priority, as the circumstances warranted a neutral third party. Additionally, the court ruled that Western's dual role as co-guardian and conservator did not violate statutory provisions, and the appointment of a neuropsychologist for evaluation was appropriate under the circumstances. View "In re J.F.R." on Justia Law

Benedict Dale Fredericks was involved in an altercation in the parking lot of the Bourbon Street Hotel in Billings, Montana, on January 25, 2022. Hotel clerk Marion Ackerman confronted Fredericks, suspecting him of trying to enter a car that did not belong to him. After a verbal exchange, Fredericks shoved Marion, who shoved him back. During the ensuing scuffle, Fredericks stabbed Marion three times. Marion's brother, Trevor, restrained Fredericks until law enforcement arrived. Fredericks was charged with Felony Assault with a Weapon and claimed he acted in self-defense.The Thirteenth Judicial District Court, Yellowstone County, presided over the case. During the trial, the defense requested a jury instruction on justifiable use of force, which the court denied, stating there was insufficient evidence to support this defense. The jury subsequently convicted Fredericks of Felony Assault with a Weapon, and he was sentenced to twenty years in prison, with five years suspended.The Supreme Court of the State of Montana reviewed the case. The main issue on appeal was whether the District Court abused its discretion by not instructing the jury on justifiable use of force. The Supreme Court found that although the District Court erred in its reasoning for denying the instruction, the refusal was ultimately correct. The evidence showed that Fredericks initiated the physical altercation and had opportunities to escape but chose to escalate the situation by using a knife. Therefore, the Supreme Court affirmed the District Court's judgment, concluding that the justifiable use of force instruction was not warranted based on the evidence presented. View "State v. Fredericks" on Justia Law

Christian Michael Smith was involved in a motorcycle accident on September 2, 2023, in Cascade County, Montana. Montana State Trooper Perry Woodland responded to the scene and found Smith injured and already being attended to by paramedics. Smith admitted to drinking the previous evening but could not perform a field sobriety test due to his injuries. Woodland followed Smith to the hospital, where Smith initially consented to a blood test but later refused after consulting with his mother. Consequently, Smith's driver's license was suspended under Montana's implied consent statute.Smith petitioned the Eighth Judicial District Court to reinstate his license, arguing that Trooper Woodland lacked particularized suspicion to request the blood test and that he did not refuse the test. The State contended that Woodland had probable cause to believe Smith was involved in an accident resulting in serious bodily injury, justifying the request for a blood test. The District Court found that while Woodland did not have particularized suspicion of DUI, he had probable cause to believe the accident resulted in serious bodily injury, thus upholding the request for the blood test. The court also found that Smith refused the test when he said, "I don’t want that," after speaking with his mother.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The Court held that Woodland had probable cause to believe Smith's injuries were serious, as defined by Montana law, and that Smith's statement constituted a refusal to submit to the blood test. The Court also declined to consider Smith's argument that he was incapable of refusing the test due to pain medication, as this argument was raised for the first time on appeal. The suspension of Smith's driver's license was upheld. View "Smith v. State" on Justia Law