Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court granting summary judgment specifically enforcing post-auction real property buy-sell agreements between Sellers and respective auction purchasers, Buyers, holding that the district court properly granted summary judgment and did not err in denying Sellers Mont. R. Civ. P. 56(f) relief prior to rendering summary judgment.On appeal, Sellers asserted, among other things, that genuine issues of material fact remained on the Rule 56 factual record as to whether Buyers respectively satisfied conditions precedent to formation of their respective buy-sell agreements. The Supreme Court affirmed, holding (1) the district court did not erroneously grant summary judgment specifically enforcing the buy-sell agreements with Sellers; and (2) the district court did not abuse its discretion in not granting Sellers Rule 56(f) relief prior to rendering summary judgment on the parties’ cross-motions for summary judgment. View "Davidson v. Barstad" on Justia Law

The Supreme Court affirmed Defendant’s conviction of three felony counts of aggravated animal cruelty, five felony counts of cruelty to animals, and a misdemeanor count of cruelty to animals, holding that the district court did not err in the proceedings below.Specifically, the Court held that the district court (1) did not err by denying Defendant’s motion to suppress evidence obtained in warrantless searches of her commercial kennel property; (2) did not err by denying Defendant’s Batson challenge; and (3) did not err in imposing the costs to be reimbursed by Defendant under Mont. Code Ann. 45-8-211(3). View "State v. Warren" on Justia Law

The Supreme Court affirmed the judgment of the district court terminating Mother’s parental rights to her two minor children for failure to comply with a reunification-oriented treatment plan, holding that the district court’s failure to properly determine whether the children were Indian children before terminating Mother’s parental rights was harmless.On appeal, Mother asserted that the district court abused its discretion by failing properly to confirm or dispel a reason to know that the children were Indian children as defined by the federal Indian Child Welfare Act, 25. U.S.C. 1901, et seq. The Supreme Court affirmed, holding that, in light of a subsequently and conclusive tribal determination that neither child was eligible for tribal enrollment, the district court’s abuse of discretion in failing to comply with 25 U.S.C. 1912(a) and 25 C.F.R. 23.107(b) and 23.108 was harmless. View "In re S.R." on Justia Law

The Supreme Court affirmed the judgment of the district court designating Defendant a repeat persistent felony offender (PFO) and sentencing him as a repeat PFO under Mont. Code Ann. 46-18-502(2), holding that there was no error in the proceedings below.Defendant pled guilty to robbery by accountability and assault with a weapon. The district court concluded that, based on Defendant’s prior felony convictions and PFO designation, it had no choice but to sentence him under section 46-18-502(2) to a minimum of ten years incarceration on both the robbery by accountability and assault charges and that the sentence must run consecutively to a three-year suspended sentence for Defendant’s probation violation in a separate case. The Supreme Court affirmed, holding that the district court did not err when it sentenced Defendant as a repeat PFO under section 46-18-502(2). View "State v. Martin" on Justia Law

The Supreme Court affirmed the order of the district court affirming the Montana Department of Labor and Industry’s Human Rights Bureau’s (HRB) decision concluding that Ronis Bollinger was properly terminated from her employment with the Billings Clinic, holding that the district court did not err in upholding Bollinger’s termination from employment because she failed to demonstrate that the Clinic retaliated against her for engaging in protected activity.Bollinger filed this complaint asserting that her history of discipline and investigative interactions with the Clinic demonstrated a retaliatory motive that caused or contributed to the Clinic’s decision to terminate her employment. The Supreme Court affirmed, holding that the district court (1) did not err in upholding the hearing officer’s conclusion that Bollinger was properly terminated by the Clinic for her dishonesty; (2) did not err in upholding the HRB's denial of Bollinger’s motion to compel Clinic production of certain emails; and (3) did not abuse its discretion in awarding costs to the Clinic. View "Bollinger v. Billings Clinic" on Justia Law

The Supreme Court reversed the decision of the district court granting summary judgment in favor of RJC Investment, Inc. on Deneige Kapor’s complaint alleging that RJC failed to pay her the surplus allegedly realized on the resale of her mobile home after she returned it to RJC when she could not make the payments, as required by Article 9 of the Uniform Commercial Code (UCC), holding that the district court erred in granting RJC summary judgment based on its determination that Kapor was equitably estopped from pursuing her claims.Specifically, the Court held that the district court (1) erred in determining that the release agreement Kapor signed terminated any further application of the UCC; (2) erred in determining that the release constituted an acceptance of the collateral in full satisfaction of Kapor’s secured obligation; and (3) correctly held that Kapor was equitably estopped from pursuing her claims because all six elements of equitable estoppel could not be satisfied here. View "Kapor v. RJC Investment, Inc." on Justia Law

The Supreme Court affirmed the decision of the district court denying Appellant’s motion to suppress, holding that the denial of Appellant’s motion to suppress was not erroneous.Defendant was charged with criminal possession of dangerous drugs. Defendant filed a motion to suppress his statements on the basis that he was detained without reasonable suspicion and arrested without probable cause. The district court denied the motion to suppress. The Supreme Court affirmed, holding (1) the district court did not err in its determination that the officers’ initial investigation was supported by particularized suspicion; (2) the immediate use of handcuffs did not elevate the investigatory stop into an arrest; and (3) the district court did not err in its determination that the arrest was supported by probable cause. View "State v. Stevens" on Justia Law

The Supreme Court affirmed the jury verdict and sentencing order of the district court finding Appellant guilty of criminal possession of dangerous drugs, holding that there was no error that required reversal of Appellant’s conviction.Specifically, the Supreme Court held that the district court (1) properly exercised its discretion in denying Appellant’s motion for directed verdict; (2) correctly instructed the jury on the charge of criminal possession of dangerous drugs; (3) did not abuse its discretion by denying Appellant’s requested instruction on “mere presence”; and (4) did not abuse its discretion by overruling Appellant’s hearsay objection regarding his traveling companions’ conflicting statements to officers during Appellant’s second jury trial. View "State v. Ellerbee" on Justia Law

The Supreme Court affirmed the judgment of the Montana district court temporarily suspending a previously imposed parenting plan for L.G.B., a minor child, holding that the district court did not erroneously grant and maintain a temporary emergency order pursuant to Mont. Code Ann. 40-4-220(2)(a)(ii) without an adequate showing and finding of changed circumstances under Mont. Code Ann. 40-4-219(1) and -220(1).Specifically, the Supreme Court held that the district court (1) did not erroneously modify the parties’ prior parenting plan without a sufficient finding of changed circumstances as required by section 40-4-219(1); (2) did not erroneously limit Mother to supervised visitation without making a sufficient finding under section 40-4-218(2); (3) did not erroneously fail to refer this matter to Family Court Services in violation of the then-governing local rule; and (4) did not abuse its discretion in precluding admission of a psychological evaluation report authored by a non-testifying mental health professional. View "In re Marriage of Bessette" on Justia Law

The Supreme Court affirmed Defendant’s convictions for two counts of criminal possession of drug paraphernalia, holding that Defendant was not entitled to a protection from prosecution through the Montana Marijuana Act (MMA) exception under Mont. Code Ann. 45-10-103 and that sufficient evidence supported Defendant’s convictions.The municipal court held that Defendant needed to show proof that she had a valid registry card before the statute’s MMA exception could apply to her, but Defendant offered no such proof. The municipal court then found Defendant guilty of two counts of criminal possession of drug paraphernalia. The Supreme Court affirmed, holding (1) because Defendant failed to show she possessed a registry card and was in compliance with the MMA she was not entitled to a protection from prosecution through the MMA exception; and (2) sufficient evidence supported Defendant’s convictions. View "City of Missoula v. Shumway" on Justia Law