Justia Montana Supreme Court Opinion Summaries

Lena Johnson and her daughter, Katherine Grundhauser, died in a car accident in 2006. They co-owned a property in Butte, Montana, as joint tenants with the right of survivorship. Lena's estate was informally probated, and her son, Kenneth Johnson, was appointed personal representative. The estate's assets were distributed among Johnson's children and three of Katherine's children, with the remainder going to Johnson and Katherine's husband, Steven Grundhauser. The property in question was not resolved, and Johnson's children lived there rent-free.In 2020, Lena's will was discovered, which stated that all property should be divided equally between Katherine and Johnson or held in trust for their children if they predeceased Lena. This will contradicted the earlier distribution and indicated that the joint ownership of the property was for convenience only. Katherine's children and Steven Grundhauser petitioned for informal probate of Lena's estate, which was denied. Formal probate was opened in 2021 with Johnson as the personal representative. A mediation in 2022 led to a settlement agreement to buy out the interests of Katherine's children in the property.The Second Judicial District Court, Butte-Silver Bow County, denied Katherine's estate's motion to intervene and for relief from judgment, finding that the estate was bound by the settlement agreement and that the doctrine of laches barred the motions. The court concluded that Grundhauser, as a petitioner, was aware of the settlement terms and had agreed to them.The Supreme Court of the State of Montana reversed and remanded the case. It held that Katherine's estate should have been allowed to intervene as it had a valid legal interest in the property. The court found that the settlement agreement was based on a mutual mistake of law and that the district court's order was void for lack of jurisdiction and due process. The court also held that the doctrine of laches did not apply, as the delay in asserting the estate's rights was reasonable under the circumstances. View "In re Estate of Johnson" on Justia Law

In November 2006, Lloyd Kvelstad was murdered at a house party in Havre, Montana. Evidence showed that James Main was involved in a physical altercation with Kvelstad, during which Main choked Kvelstad multiple times. Kvelstad was later found severely beaten and unresponsive. Main was arrested and charged with deliberate homicide by felony murder. At trial, various testimonies and forensic evidence linked Main to the crime, leading to his conviction in February 2009.Main appealed his conviction, but the Montana Supreme Court upheld it in 2011, finding sufficient evidence to support the jury's verdict. Main later filed a petition for postconviction relief, alleging that the State violated his Brady rights by failing to disclose certain crime scene photos. He argued that these photos were crucial for determining the time and cause of Kvelstad's death. The District Court denied Main's petition without holding a hearing, taking judicial notice of findings from a co-defendant's postconviction case.The Montana Supreme Court reviewed the case and affirmed the District Court's decision. The Court found that even if the missing photos had been disclosed, they would not have changed the outcome of the trial. The evidence already presented was sufficient to establish Main's guilt for deliberate homicide by felony murder. The Court also found that Main's petition did not present newly discovered evidence but rather a new theory of the crime. Therefore, the District Court did not abuse its discretion in denying the petition without a hearing. View "Main v. State" on Justia Law

The plaintiffs, William and Ellen Solem, own property in Flathead County’s “Neighborhood 800.” In 2008, the Montana Department of Revenue (DOR) conducted a mass appraisal of lakefront properties in this neighborhood, significantly increasing the valuation of the Solems' property from $229,500 in 2002 to $1,233,050 in 2008. The Solems challenged the appraisal, arguing that DOR’s methodology was improper and unlawful. They sought approximately $450 in alleged overpaid taxes and filed a class action on behalf of other property owners in the neighborhood.The Eleventh Judicial District Court certified the case as a class action and held a bench trial on liability issues. The court found in favor of the Solems, ruling that DOR’s appraisal methodology was unlawful and unconstitutional. The court criticized DOR for excluding 17 outlier sales from its model and for using only three variables in its appraisal process. The court awarded damages, costs, and fees to the plaintiffs. The Solems also cross-appealed the court’s denial of their motion to amend the class definition.The Supreme Court of the State of Montana reviewed the case. The court held that the District Court erred by substituting its judgment for that of DOR. The Supreme Court found that DOR’s mass appraisal methodology was consistent with accepted practices and that the Solems failed to meet the substantial burden of disproving the accuracy of DOR’s appraisal. The court also noted that the District Court improperly relied on the R squared value as the sole metric for accuracy. Consequently, the Supreme Court reversed the District Court’s ruling and remanded the case for proceedings consistent with its opinion. The court did not address the constitutionality of the payment-under-protest requirement, as it was unnecessary given the resolution of the primary issue. View "Solem v. Department of Revenue" on Justia Law

Miriam Penado sought a temporary order of protection for herself and her two minor children in Butte-Silver Bow County Justice Court against Daniel Hunter, the children's father. The Justice Court issued a temporary ex parte order of protection and scheduled a hearing. Subsequently, Hunter filed a parenting plan petition in Gallatin County District Court and moved to remove the protection order case to that court, citing a state statute. The Justice Court transferred the case and vacated the hearing. The Gallatin County District Court then referred the case to a standing master, who set a hearing and maintained the temporary order of protection.Penado filed a motion in the Justice Court to vacate the transfer orders, which was denied. She appealed to the Gallatin County District Court, which also denied her appeal, stating that any appeal should have been made to the Butte-Silver Bow County District Court. The District Court found that Hunter had properly removed the case under the relevant statute. At the subsequent hearing, the District Court granted a one-year order of protection for Penado and allowed Hunter visitation rights.The Supreme Court of the State of Montana reviewed the case. The court held that the removal of the temporary order of protection case to the Gallatin County District Court was proper under § 40-15-301(3), MCA, which allows either party to remove the matter to district court before or after the hearing. The court found that the statute's language and intent were to consolidate related family law matters in the district court handling the parenting plan. The court also determined that Penado's due process rights were not violated, as she had notice and the opportunity to participate in the hearing. The Supreme Court affirmed the District Court's final order of protection. View "Penado v. Hunter" on Justia Law

Jay Le Cleveland was approached by Polson police officers for a welfare check after a 911 caller reported him slumped over the steering wheel of his running car. Upon interaction, Cleveland explained he was fine but had burning eyes. When asked for his driver’s license, Cleveland stated he did not have it. The officer then verified Cleveland’s probation status and, with authorization from Cleveland’s probation officer, conducted a search of Cleveland’s car, finding drugs and a digital scale. Cleveland was charged with felony possession with intent to distribute.The Twentieth Judicial District Court denied Cleveland’s motion to suppress the evidence obtained from the search, ruling that the officer had particularized suspicion to expand the welfare check into a drug investigation. Cleveland entered a plea agreement, pleading no contest to one count and agreeing to pay a $300 prosecution fee, while reserving the right to appeal the suppression ruling.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court’s decision. The Court held that the officer had reasonable cause to continue the interaction beyond the initial welfare check based on Cleveland’s behavior and responses. The Court also found that the probation officer had reasonable suspicion to authorize the search of Cleveland’s car. Additionally, the Court upheld the $300 prosecution fee, noting that Cleveland had agreed to it in his plea deal and did not object at sentencing. View "State v. Cleveland" on Justia Law

Ariel Jonae Powers was charged with arson in September 2020. In August 2021, her attorney informed the court that an evaluator found her unfit to proceed. The court ordered the evaluation to be filed under seal and allowed the State to respond. The State agreed with the unfitness finding and requested Powers be committed to the Montana State Hospital (MSH) for evaluation and treatment. In December 2021, the court stayed the proceedings, committed Powers to the Department of Public Health and Human Services, and she was transferred to MSH.Powers moved to dismiss the charge in March 2022, arguing the court failed to review her fitness within 90 days as required by law. Six days later, she was released from MSH after being found fit to proceed. The evaluators' report was filed with the court in March 2022. The District Court denied her motion to dismiss in May 2022, stating her commitment duration was less than 90 days from her admission to MSH. Powers then pled no contest to misdemeanor negligent endangerment and was sentenced to one year in the Park County Detention Center, all suspended, with fines and fees totaling $175.The Supreme Court of the State of Montana reviewed the case. Powers argued that the failure to review her fitness within 90 days required dismissal of the charges. The court held that while the statute mandates a review within 90 days, it does not automatically compel dismissal if the review is delayed. The court emphasized that dismissal is required only if the defendant remains unfit and unlikely to become fit in the foreseeable future. The court found that Powers regained fitness within a reasonable time, and thus, the District Court did not err in denying her motion to dismiss. The Supreme Court affirmed Powers's conviction. View "State v. Powers" on Justia Law

The Montana Democratic Party (MDP) sought a writ of supervisory control over the First Judicial District Court, Lewis and Clark County, after the court dissolved a temporary restraining order and denied MDP’s request for a temporary restraining order and preliminary injunction. MDP aimed to prevent Robert Barb from appearing on the general election ballot as the Montana Green Party’s 2024 U.S. Senate candidate, arguing that the District Court erred in its decision.The First Judicial District Court, presided over by Judge Michael McMahon, had previously denied MDP’s motion for a temporary restraining order and preliminary injunction. The court found that MDP had not followed the statutory process for contesting nominations as outlined in § 13-36-102, MCA. The court concluded that MDP was unlikely to succeed on the merits and thus was not entitled to a preliminary injunction. MDP appealed this decision and simultaneously filed a petition for a writ of supervisory control with the Montana Supreme Court.The Montana Supreme Court reviewed the case and determined that supervisory control was warranted due to the urgency of the upcoming election. However, the court ultimately concluded that the District Court did not err in its ruling, albeit for different reasons. The Supreme Court found that the terms "nomination" and "appointment" are distinct within the context of Montana election law. The court agreed with MDP that the procedure for contesting nominations did not apply to the appointment of a replacement candidate under § 13-10-327, MCA. However, the court also found that MDP failed to demonstrate that the Green Party violated its bylaws in appointing Barb, and thus, MDP was unlikely to succeed on the merits.The Montana Supreme Court denied MDP’s petition for a writ of supervisory control, affirming the lower court’s decision to allow Barb to appear on the ballot. View "Montana Democratic Party v. First Judicial District Court" on Justia Law

The City of Shelby operates a municipal water system in Toole County, Montana, supplying water to several service areas. In 2017, the Montana Department of Natural Resources and Conservation (DNRC) approved changes allowing Shelby to temporarily service these areas. In 2019, Shelby applied to expand its service area and increase groundwater production. DNRC issued preliminary approvals for these applications in 2020, which the Town of Kevin objected to, leading to a hearing examiner's review.The hearing examiner denied Kevin's motion for summary judgment and later approved Shelby's applications, concluding that Shelby met the statutory criteria based on service agreements with communities in its service area. Kevin then petitioned the Montana Water Court for judicial review, arguing that DNRC misinterpreted the law and that Shelby's applications did not meet statutory requirements. The Water Court denied Kevin's petition, affirming DNRC's decisions.The Supreme Court of the State of Montana reviewed the case, focusing on whether DNRC erred in approving Shelby's permit and change of use applications. The court found that DNRC's interpretation of the law, which allowed service agreements to satisfy the statutory requirement for written consent, was reasonable. However, the court noted that the record lacked evidence of a service agreement with Galata, one of the proposed new service areas. Consequently, the court affirmed DNRC's decision in part but reversed it regarding the inclusion of Galata.The court remanded the case to DNRC to determine whether all required service agreements exist and to issue an order consistent with this opinion. The main holding was that DNRC's interpretation of the statutory criteria was correct, except for the missing service agreement with Galata. View "Town of Kevin v. Department of Natural Resources and Conservation" on Justia Law

A group of residents in the Whitehorse Estates Minor Subdivision filed a complaint against their neighbors, Joseph and Amanda Kleinhans, alleging that the Kleinhans violated the subdivision’s restrictive covenants by converting their garage into an accessory dwelling unit (ADU) and renting it out as an Airbnb. The covenants in question required properties to be used only for single-family dwellings and prohibited the operation of commercial businesses.The District Court of the Twenty-Second Judicial District, Carbon County, granted summary judgment in favor of the Kleinhans. The court interpreted the single-family dwelling covenant as a structural restriction, not a use restriction, meaning it only limited the type and number of buildings but did not restrict the use of the property to single families. The court also found the commercial business covenant to be ambiguous and concluded it did not prohibit short-term rentals like Airbnb. Consequently, the court awarded the Kleinhans their Bill of Costs amounting to $4,594.35.The Supreme Court of the State of Montana reviewed the case and reversed the District Court’s decision. The Supreme Court held that the term "commercial business" was not ambiguous and should be given its plain and ordinary meaning, which includes activities conducted for profit. Therefore, the Kleinhans' operation of an Airbnb constituted a commercial business, violating the subdivision’s covenants. The Supreme Court also reversed the award of the Bill of Costs to the Kleinhans and remanded the case to the District Court to enter summary judgment in favor of the neighbors. View "Myers v. Kleinhans" on Justia Law

Garrett Michael O’Howell was arrested following a traffic stop on May 4, 2020. Broadwater County Sheriff’s Deputy Tony Cordova observed a vehicle in a parking lot and found the behavior of its occupants suspicious. The vehicle was registered to Kaitlyn Smock, whose driver’s license was revoked. After Smock drove the vehicle away, Cordova stopped it for speeding and because of Smock’s revoked license. None of the passengers, including O’Howell, had a valid driver’s license. Cordova discovered that O’Howell had an outstanding warrant and arrested him. A subsequent search of the vehicle revealed methamphetamine and drug paraphernalia.The First Judicial District Court denied O’Howell’s motion to suppress the evidence, concluding that the stop was justified and that Cordova’s actions were lawful. The court found that Cordova had a particularized suspicion to stop the vehicle and that the questioning of the passengers was within the scope of the stop. O’Howell was convicted by a jury of criminal possession of dangerous drugs with intent to distribute and possession of drug paraphernalia.The Supreme Court of the State of Montana reviewed the case. The court held that Cordova’s questioning of the passengers did not exceed the scope of the traffic stop, as it was necessary to determine if any of them could legally drive the vehicle. The court also found that there was sufficient evidence to support the jury’s verdict, including testimony from Smock and Laird, corroborated by O’Howell’s own statements and the physical evidence found in the vehicle. The court affirmed the lower court’s decision, upholding O’Howell’s convictions. View "State v. O'Howell" on Justia Law