Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the order of the district court granting a motion to dismiss in favor of Defendant on Plaintiff's action seeking a declaratory judgment and asserting that provisions of the Montana Retail Installment Sales Act (RISA) barred Defendant from collecting fees under the parties' agreement, holding that the 2007 version of RISA controlled and did not confer a private cause of action but that the district court erred in dismissing the complaint for failure to state a claim.In 2009, Plaintiff purchased a mobile home and financed the majority of the purchased through an installment sales contract and security agreement that was later assigned to Defendant. Plaintiff later filed this action alleging Defendant assessed excessive late fees against her and violated RISA by failing to disclose the finance charge. The district court dismissed the complaint for failure to state a claim. The Supreme Court reversed in part, holding (1) the 2007 version of RISA controlled and did not confer a private cause of action; but (2) the district court erred in dismissing the motion for failure to state a claim because Plaintiff properly asked the court for a declaratory judgment clarifying her rights under the agreement in light of the provisions of RISA. View "Strauser v. RJC Investment, Inc." on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant for felony aggravated kidnapping and misdemeanor partner family member assault, holding that the district court committed reversible error by allowing the jury unrestricted access to view testimonial videos during its deliberations.In this case, the jury made no requests to view testimonial materials. The videos at issue were simply given to the jury by the court for unsupervised and unrestricted review at the start of deliberations. On appeal, Defendant argued that the videos contained testimonial evidence, and therefore, the district court abused its discretion by allowing the jury unsupervised review of these videos. The Supreme Court agreed, holding that the district court erred by allowing the jury unsupervised access to view the videos during its deliberations and that the error was not harmless. View "State v. Nordholm" on Justia Law

The Supreme Court affirmed the order of the district court denying a complaint and petition for release of confidential criminal justice information (CCJI), holding that the court did not err in denying the petition for release of CCJI without conducting an in camera review.Appellant, in her capacity as the personal representative of the Estate of John Michael Crites, sought release of an investigative file regarding Crites's murder. The district court denied the petition without conducting an in camera review, determining that Mont. Code Ann. 44-5-303 does not allow for the release of CCJI if the prosecutor determines dissemination would jeopardize an active investigation. The Supreme Court affirmed, holding that Appellant's interest in the CCJI contained in Crites's investigative file must yield to the State's police power to conduct investigations, which included the protection of CCJI in the active investigation into Crites's murder. View "Crites v. Lewis & Clark Co." on Justia Law

The Supreme Court affirmed the decision of the Workers' Compensation Court (WCC) granting summary judgment to Indemnity Insurance Company of North America on Brian Richardson's petition arguing that he was entitled to have Indemnity accept his claim for workers' compensation benefits, holding that the WCC correctly held that Richardson had not timely filed a written claim for benefits under Mont. Code Ann. 39-71-601.Richardson filed his claim for benefits almost four years after the alleged work-related accident. Indemnity denied Richardson's claim on the grounds that Richardson had failed to provide his employer with timely notice and that he had failed timely to file his claim. The Supreme Court affirmed, holding that Richardson failed to file a timely written claim under section 39-71-601. View "Richardson v. Indemnity Insurance Co. of N.A." on Justia Law

The Supreme Court reversed the order of the district court denying Exxon Mobil Corporation's (ExxonMobil) petition for interlocutory adjudication and affirming the Department of Revenue's determination that ExxonMobil was entitled to an eighty percent exclusion from income for the dividends it received from several of its domestic subsidiaries, holding that ExxonMobil correctly excluded 100 percent of the actual dividends.On appeal, ExxonMobil argued that the district court erred when it concluded that the dividends at issue were expressly apportionable as income under Mont. Code Ann. 15-31-325 and that, therefore, ExxonMobil was not entitled to a 100 percent income exclusion under Internal Revenue Code (I.R.C.) 243. The Supreme Court reversed, holding that ExxonMobil may deduct the actual dividends it receives from the domestic subsidiaries at issue for purposes of Montana taxation through I.R.C. 243. View "Exxon Mobil Corp. v. Montana Department of Revenue" on Justia Law

The Supreme Court affirmed the order of the district court denying Landowners' petition for writ of review asserting that the Ravalli County Board of County Commissioners exceeded its jurisdiction to grant or deny Landowners' petition for abandonment, holding that Landowners failed to meet the statutory requirement for issuance of a writ of review.Landowners erected a gate that obstructed a portion of a county road. Landowners petitioned the Board to abandon that portion of the road, but the Board denied the petition for abandonment and ordered the gate removed. Landowners later filed their petition for a writ of review. The district court denied Landowners' petition for a writ of review and accompanying application for preliminary injunction on the basis that the Board did not exceed its jurisdiction. The Supreme Court affirmed, holding that Landowners failed to show that the Board exceeded its jurisdiction. View "Bugli v. Ravalli County" on Justia Law

The Supreme Court affirmed the judgment of the district court sentencing Defendant under the 2015 persistent felony offender (PFO) statute in effect at the time Defendant committed his offense, holding that the district court properly sentenced Defendant as a PFO pursuant to Mont. Code Ann. 46-18-501 (2015).The State charged Defendant with felony driving under the influence of alcohol (DUI) and other offenses alleged to have been committed in 2016. Based on a prior conviction for felony escape, the State filed a notice seeking designation of Defendant as a PFO under Mont. Code Ann. 46-18-501 (2015). During the 2017 sentencing hearing, Defendant's counsel acknowledged there had been a legislative revision to the PFO statute but did not argue the change applied to Defendant. The district court proceeded to sentence Defendant as a PFO under section 46-18-501 (2015). The Supreme Court affirmed, holding that because Defendant committed felony DUI before the amendments at issue were made applicable to offenses, the ameliorative effects of the revision of the PFO definition did not apply to Defendant. View "State v. Thomas" on Justia Law

The Supreme Court affirmed the order of the district court dismissing the third-party complaint filed by HRC Two Rivers LLC and HRC Cottages Inc. (collectively, the General Partners) against Aultco Construction Inc. as barred under the principles of res judicata and collateral estoppel, holding that a prior suit by the partnership entity precluded the General Partners from pursuing their claims against Aultco.The HRC entities were general partners of Two Rivers Apartments LLLP, which contracted with Aultco Construction Inc. to build an apartment building. In 2015, Two Rivers filed suit against Aultco for negligent construction resulting in mold in that apartments' attic. The case was litigated, settled, and dismissed with prejudice. The apartment tenants then filed suit against Two Rivers Apartments and the General Partners alleging that they were not given the required disclosure of mold testing and its results. The General Partners filed a third-party complaint against Aultco for contribution and indemnity. The district court granted Aultco's motion to dismiss on the grounds of either res judicata or collateral estoppel. The Supreme Court affirmed, holding that the district court did not err in dismissing the third-party complaint on the grounds of res judicata and collateral estoppel. View "HRC Two Rivers, LLC v. Aultco Construction, Inc." on Justia Law

The Supreme Court reversed the order of the district court granting Plaintiff's motion to release John Doe's educational records, holding that the district court erred in concluding that Doe had no expectation of privacy in his educational records.Plaintiff, a writer, sought the student education record of a student, John Doe, that the University Court concluded had committed sexual intercourse without consent and had sanctioned him to expulsion. After Doe appealed to the Commissioner of Higher Education, Doe remained in school and continued to participate in athletics. The Commissioner refused to permit inspection or release of Doe's education records, and Plaintiff initiated this court action to obtain the records. Upon remand, the trial court ordered Doe's records be disclosed. The Supreme Court reversed and denied Plaintiff's request to examine the documents, holding that the demand of Doe's enhanced student privacy interest in his records exceeded the merits of public disclosure. View "Krakauer v. State" on Justia Law

The Supreme Court reversed the order of the district court denying Appellant's motion to dismiss based on a finding that law enforcement had the requisite particularized suspicion to initiate a traffic stop, holding that the traffic stop was not justified under Mont. Code Ann. 46-5-401.The justice court granted Defendant's motion to dismiss, concluding that the police officer who initiated the traffic stop lacked particularized suspicion. The district court disagreed and Defendant's motion. The Supreme Court reversed, holding that the officer did not have objective data available to him to support a particularized suspicion that Defendant was committing, had committed, or was about to commit an offense, and therefore, the traffic stop was not justified pursuant to section 46-5-401. View "State v. Reeves" on Justia Law