Justia Montana Supreme Court Opinion Summaries

Bluebird Property Rentals, LLC, a Montana limited liability company, and its sole member, Alaina Garcia, received a $450,000 loan from World Business Lenders, LLC (WBL) and its subsidiaries in December 2020. The loan, secured by real property in Gallatin County, had an annual percentage rate of approximately 85% and required weekly payments. Bluebird signed several agreements, including a Business Promissory Note and Security Agreement, which listed Axos Bank as the lender, although Bluebird had no prior dealings with Axos. After falling behind on payments, Bluebird sold the collateral property in a distress sale and paid off the loan in October 2022, having paid a total of $945,990.39.Bluebird sued WBL, alleging that WBL engaged in a "rent-a-bank" scheme to evade Montana's usury laws, claiming that Axos Bank was merely a front and that WBL was the true lender. Bluebird sought a declaration that Montana law applied and sought double the interest paid above the maximum allowable rate under Montana law. WBL filed a motion to dismiss and compel arbitration based on the agreements' arbitration and choice-of-law provisions.The Eighteenth Judicial District Court denied WBL's motion, ruling that Montana law must be applied to determine the enforceability of the arbitration and choice-of-law provisions. The court treated WBL's motion as a Rule 12(b)(1) motion to dismiss for lack of subject matter jurisdiction and found that the validity of the arbitration clause was for the court to decide, not an arbitrator.The Supreme Court of the State of Montana affirmed the District Court's decision, holding that the general rule that courts determine arbitrability was not overcome by the facts of this case. The court found no clear and unmistakable evidence that the parties agreed to arbitrate arbitrability, despite WBL's arguments regarding the incorporation of AAA rules. The court did not address the merits of the enforceability of the arbitration agreement or the choice-of-law provision. View "Bluebird v. World Business Lenders" on Justia Law

On January 1, 2019, Missoula police were surveilling suspected illegal drug activity outside a casino. Officers observed two vehicles, a Honda and a Volkswagen, leave the casino together and head to a nearby grocery store parking lot. Officer Griffith parked his patrol car behind the Honda, where Catherine Marie Rymal was a passenger. Without activating his lights or siren, Griffith approached the Honda and asked Rymal not to dig around in the car. Rymal explained she was looking for her dog’s leash. Griffith then asked if he could talk to her and inquired about their activities at the casino. Rymal mentioned they were waiting for a friend and had been gambling. Griffith asked for her ID, and Rymal disclosed she might have a warrant for a speeding ticket.The Montana Fourth Judicial District Court denied Rymal’s motion to suppress the drug evidence found during a subsequent search, ruling that her interaction with Officer Griffith was consensual and did not constitute an unlawful seizure. The court found that Rymal’s disclosure of her possible warrant was voluntary and provided reasonable suspicion for her detention.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court’s decision. The court held that Rymal was not seized at any point before she voluntarily disclosed her possible warrant status. The interaction between Rymal and Officer Griffith was deemed consensual, and Griffith’s conduct did not amount to a show of authority that would make a reasonable person feel they were not free to leave. Therefore, the evidence obtained was not the result of an unlawful seizure, and the motion to suppress was correctly denied. View "State v. Rymal" on Justia Law

Adrianne Cotton filed a charge of discrimination against the Montana Department of Corrections (DOC), alleging retaliation for protected activity when her position was eliminated. Cotton had been employed by DOC since 2011 and held the position of government relations director. She reported concerns about the conduct of DOC Director Reginald Michael in 2017, which led to an investigation. Subsequently, an organizational assessment recommended eliminating Cotton's position, among others, due to budgetary and structural issues.The case was first reviewed by Hearing Officer Holien, who held a contested case hearing and found that DOC had legitimate, non-discriminatory reasons for eliminating Cotton's position and did not retaliate against her. Cotton appealed to the Human Rights Commission, which rejected Holien's conclusions of law, citing the temporal proximity between Cotton's protected activity and the adverse employment action as sufficient evidence of retaliation. The Commission did not find that Holien's findings of fact were unsupported by substantial evidence.The case was then reviewed by the District Court of the First Judicial District, which found that the Commission exceeded its statutory authority by reweighing the evidence and substituting its judgment for that of the hearing officer. The District Court reversed the Commission's order and reinstated Holien's decision as the final agency decision.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The Court held that the Commission had abused its discretion by not adhering to the proper standard of review and by reweighing evidence that supported Holien's findings. The Supreme Court concluded that the District Court did not err in reinstating Holien's findings as the final agency decision, as they were supported by substantial evidence in the record. View "Cotton v. Dept. of Corrections" on Justia Law

David Stanley was convicted in the Montana Eighteenth Judicial District Court, Gallatin County, for felony criminal possession of methamphetamine. Stanley appealed, arguing that the District Court erred in denying his motion to suppress drug evidence found during a post-arrest jail intake search. The key issue was whether the police had the requisite particularized suspicion to justify the investigative stop that led to Stanley's arrest and the subsequent discovery of the drugs.In the lower court, the District Court found that the police lacked particularized suspicion to justify the stop. However, it ruled that the "attenuation doctrine" exception to the exclusionary rule applied, meaning the drug evidence did not need to be suppressed despite the initial unlawful stop. Stanley then pled guilty under a plea agreement that reserved his right to appeal the suppression ruling.The Montana Supreme Court reviewed the case and held that the police had a reasonable particularized suspicion to stop Stanley. The court noted that the police received an anonymous tip about a fugitive, Daniel Sobrepena, who was reportedly wearing a distinctive red curly wig to avoid arrest. When Officer Ahmann saw Stanley wearing a similar wig in the area described, it was reasonable to suspect he might be Sobrepena or have information about him. The court found that the initial stop and subsequent questioning were justified and conducted within a reasonable scope and duration.The Montana Supreme Court concluded that the District Court reached the correct result in denying the motion to suppress, albeit for different reasons. The court affirmed Stanley's conviction, holding that the investigative stop was lawful and the resulting drug evidence was admissible. View "State v. Stanley" on Justia Law

David Rodman Ash petitioned to dissolve his marriage with Bree Elliot in September 2022. The Eleventh Judicial District Court, Flathead County, issued a decree dissolving the marriage and dividing the marital property on July 13, 2023. Ash moved to amend the decree, arguing that the court had disregarded his labor contributions in constructing a shared home and his poor health and limited future income prospects. The District Court denied his motion on October 2, 2023. Ash appealed the allocation of the marital assets.The District Court awarded 80% of the value of the Eastman Property to Elliot and 20% to Ash. Ash argued that the distribution was inequitable, given his significant nonmonetary contributions to the construction and maintenance of the marital properties. The court found that Elliot had invested $1,150,000 in the Eastman Property, while Ash's interest was valued at $325,385, including his initial investment and documented cash contributions.The Supreme Court of the State of Montana reviewed the case. The court held that the District Court abused its discretion by diminishing the value of Ash's nonmonetary contributions to the marital estate. The court noted that Ash's labor in constructing the Lodge and maintaining the properties was significant and should have been considered in the distribution of the marital assets. The court also found that the District Court erred by seeking to return the parties to their premarital positions, which is not a factor under Montana law for equitable apportionment.The Supreme Court reversed the distribution of the marital assets and remanded the case to the District Court for further proceedings consistent with its opinion. View "In re Marriage of Ash" on Justia Law

The case involves the Parrot Ditch Company (PDC) and its four water rights in the Jefferson River. PDC delivers water to its shareholders through the Parrot Ditch, which runs parallel to the Jefferson River in Basin 41G. The ditch was constructed in 1895, and PDC was organized in 1916 to manage and distribute water through the ditch. PDC issued shares that correspond to water entitlements, and the company stopped issuing shares in 1981. Two of the water rights were litigated in 1926 in the Carney case, which established shareholders' interests in PDC and referenced priority dates and volumes for two water rights.The Montana Water Court issued a Temporary Preliminary Decree in 1989, which included abstracts for PDC's four water rights. PDC objected to the place of use for one of the rights in 1990 and later requested amendments to the flow rate and irrigated acreage. The Water Court adopted various recommendations over the years, ultimately increasing the place of use to 6,710.78 acres. In 2018, the Water Court issued a Preliminary Decree, and PDC objected, seeking a larger service area and other corrections. Objectors (AMD) also raised objections to various elements of PDC's water rights.The Montana Supreme Court reviewed the case and affirmed the Water Court's decisions. The Court held that PDC failed to provide sufficient evidence to support a larger service area beyond 6,710.78 acres. The Court also found that the Carney decision did not adjudicate water rights and that AMD provided sufficient evidence to overcome the prima facie status of PDC's claims regarding the Townsend and Methodist rights. Finally, the Court upheld the Water Court's modification of the Nolte flow rate to 100 cfs, based on the lack of notice to affected water users when PDC requested the amendment in 1997. View "Parrot Ditch v. Ashcraft" on Justia Law

In 2018, Robert Spoklie purchased land neighboring the property of the Paul Phillip Bardos and Mary L. Bardos Revocable Trust (Bardos) near Kalispell, Montana. Spoklie divided his land into smaller parcels for residential development and entered into an Easement Agreement with Bardos, granting mutual easements for access. Spoklie's easement allowed him to use a 60-foot-wide path through Bardos's property for ingress, egress, and utility installation. Spoklie used this easement to transport construction equipment, sometimes parking it temporarily within the easement boundaries, which Bardos contested.The Eleventh Judicial District Court, Flathead County, denied Bardos's request for a preliminary injunction and later granted summary judgment in favor of Spoklie. The court found that Spoklie's activities, including temporary parking and unloading of construction equipment within the easement, were within the scope of the easement agreement. Bardos appealed, arguing that material facts were in dispute and that Spoklie's actions constituted trespass and nuisance.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The court held that the easement's language allowed for temporary parking and unloading of construction equipment as reasonably necessary for ingress and egress. The court also found that Spoklie's actions did not constitute trespass or nuisance since they were within the scope of the easement. Additionally, the court noted that the issue of Spoklie's proposed mailbox structure was not ripe for adjudication as no substantial steps had been taken toward its construction. The court concluded that there were no genuine issues of material fact and that the District Court correctly applied the law. View "Bardos Revocable Trust v. Spoklie" on Justia Law

Laura Marie Obert, a former Broadwater County Commissioner, was investigated by the Montana Department of Justice Division of Criminal Investigation (DCI) in 2015 for allegedly receiving unlawful overtime pay and potential ethics violations. In 2016, Obert entered a deferred prosecution agreement with the Assistant Attorney General, agreeing to repay the excess wages and abstain from voting on matters where she had a conflict of interest. In 2019, based on new allegations of violating the agreement, Obert was charged with felony theft and misdemeanor official misconduct. The district court dismissed these charges in 2021, finding Obert had complied with the agreement and there was insufficient evidence for the misconduct charge.Obert then sued the State of Montana and Broadwater County Attorney Cory Swanson, alleging breach of contract, bad faith, due process violations, and malicious prosecution. The First Judicial District Court dismissed her claims, leading to this appeal.The Montana Supreme Court reviewed the case and made several determinations. It reversed the lower court's dismissal of Obert's breach of contract and good faith and fair dealing claims, holding that these claims were not time-barred and did not accrue until the criminal charges were dismissed. However, the court affirmed the dismissal of Obert's bad faith claim, finding no special relationship existed between Obert and the State that would support such a claim. The court also upheld the dismissal of the malicious prosecution claim, ruling that Swanson was protected by prosecutorial immunity as he acted within his statutory duties. Lastly, the court affirmed the dismissal of the due process claim, concluding that Obert's procedural due process rights were not violated as the State followed proper procedures in charging her and the district court provided an appropriate forum to address the alleged breach of the agreement. View "Obert v State" on Justia Law

D.A. Davidson & Co. initiated an interpleader action to resolve a dispute over funds held in an investment account for Whitefish Masonic Lodge 64. The Grand Lodge of Ancient Free and Accepted Masons of Montana revoked Whitefish Lodge's charter and claimed the funds. Donald Slaybaugh, a member of Whitefish Lodge, contested the revocation and the transfer of funds, arguing that the Grand Lodge did not follow proper procedures.The Eleventh Judicial District Court, Flathead County, granted summary judgment in favor of the Grand Lodge, dismissing Slaybaugh's cross claims. The court determined that Slaybaugh lacked standing to bring claims against the Grand Lodge on behalf of Whitefish Lodge or in his individual capacity. The court found that Whitefish Lodge, having had its charter revoked, no longer existed as a legal entity capable of bringing claims. Additionally, the court concluded that Slaybaugh did not have the authority to act on behalf of the Lodge, as he was not an elected officer and his previous authority to oversee the investment account had been revoked.The Supreme Court of the State of Montana affirmed the District Court's decision. The court held that Slaybaugh did not have standing to bring claims on behalf of Whitefish Lodge because the Lodge was dissolved and could not appear in litigation. The court also rejected Slaybaugh's argument that he had standing as a fiduciary or under a derivative action, noting that he did not meet the pleading requirements for a derivative action and that his fiduciary authority had been revoked. Finally, the court found no evidence to support claims of fraud or arbitrary action by the Grand Lodge in revoking the Lodge's charter. View "D.A. Davidson v. Slaybaugh" on Justia Law

In this case, Billy Lee Henderson appealed the denial of his petition for postconviction relief from his 2019 conviction for Aggravated Sexual Intercourse Without Consent (SIWC). The conviction stemmed from a series of assaults on Jane Doe over five days in April 2018. Henderson was found guilty of multiple related offenses, including witness tampering and protective order violations. He was sentenced to 75 years in prison, with 25 years suspended.Henderson's petition for postconviction relief was based on newly discovered evidence, specifically Doe's recantation of her trial testimony. Doe had initially testified that Henderson forced her to have non-consensual sex, but later, in recorded conversations and an interview, she claimed the intercourse was consensual and that she had been pressured by authorities to testify otherwise. The District Court of the Fourth Judicial District, Missoula County, denied the petition, finding Doe's recantations inconsistent and lacking credibility, especially given Henderson's history of witness tampering.The Montana Supreme Court reviewed the case, focusing on whether the District Court applied the correct standards in assessing the newly discovered evidence. The Supreme Court affirmed the lower court's decision, holding that the District Court did not err in its evidentiary assessment. The court emphasized that Doe's recantations were not sufficiently credible or weighty to warrant a new trial, especially in light of her inconsistent statements and the context of Henderson's attempts to influence her testimony. The Supreme Court concluded that the District Court's findings were supported by substantial evidence and were not clearly erroneous. View "Henderson v. State" on Justia Law