Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s conviction of felony aggravated assault, holding that the district court did not abuse its discretion by denying Appellant’s request for substitution of counsel.Appellant in this case was an indigent defendant who requested substitute counsel. The district court performed an adequate initial inquiry to determine whether Appellant’s complaints were seemingly substantial. The district court then denied the request, determining that Appellant did not present a seemingly substantial complaint. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying Appellant's request for substitute counsel. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to set aside the jury verdict in his case and grant him a new trial, holding that the district court correctly concluded that the interests of justice did not require a new trial.Defendant was found guilty of partner or family member assault and criminal destruction of or tampering with a communication device. Defendant later filed his motion to set aside jury verdict and grant Defendant a new trial. The district court denied the motion. The Supreme Court affirmed, holding that the district court properly denied relief. View "State v. Oschmann" on Justia Law

The Supreme Court affirmed Defendant’s conviction of driving under the influence of alcohol or drugs, holding that there was no error in the court below that warranted reversal of the conviction.Specifically, the Court held (1) the district court did not err by denying Defendant’s motion to exclude evidence because of an asserted discovery violation by the State; (2) the district court did not err by granting the State’s motion in limine to prevent Defendant from arguing that the State had not fulfilled its discovery obligations or by disallowing Defendant’s discussion of the subject to the motion in limine in his closing argument; (3) even if the district court erred by allowing the State to amend the information less than five days before trial any error was harmless; and (4) the district court did not abuse its discretion by admitting a State exhibit at trial when the redacted version of the exhibit was not provided to Defendant until the morning of the first day of trial. View "State v. Hudon" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the district court granting summary judgment in favor of Anaconda-Deer Lodge County in this dispute over the status of a road, holding that the district court did not err in concluding that the County’s use of the upper branch of the road did not amount to a taking but that Letica Land Company, LLC was not constitutionally entitled to litigation expenses and that both Letica and the County were responsible for their individual trial costs.At issue was the status of Modesty Creek Road, located near the boundary between Anaconda-Deer Lodge County (the County) and Powell County. Letica filed a complaint and sought a preliminary injunction barring public use of the road until a judgment established the existence of a right-of-way over either or both the upper and lower branches. The district court granted summary judgment in favor of the County and dismissed Letica’s takings claims. The Supreme Court held (1) the district court did not err in granting summary judgment in the County’s favor; (2) because a taking did not occur, Letica was not constitutionally entitled to compensation or litigation expenses; and (3) the district court erred in holding Letica accountable for the County’s trial costs. View "Letica Land Co., LLC v. Anaconda-Deer Lodge County" on Justia Law

The Supreme Court affirmed the judgment of the district court invalidating the Secretary of State Corey Stapleton’s (Secretary) act of certifying the eligibility of the Montana Green Party to nominate candidates for election to public officers in Montana, holding that the district court did not erroneously invalidate eighty-seven signatures due to noncompliance with Mont. Code Ann. 13-10-601(2).Plaintiffs filed this complaint seeking declaratory judgment that the Secretary’s Green Party certification was invalid due to noncompliance with section 13-10-601(2). The district court invalidated the certification and enjoined the Secretary from giving any effect to the Green Party ballot eligibility petition. The Supreme Court affirmed, holding (1) Plaintiffs’ claim for declaratory and injunctive relief challenging the legal sufficiency of the petition and the Secretary’s certification of the petition stated a cognizable claim for relief; (2) Plaintiffs’ claim did not involve a non-justiciable political question; (3) the Montana Democratic Party had legal standing to challenge the petition and the Secretary’s resulting certification thereof; and (4) the district court did not err in invalidating eighty-seven signatures due to noncompliance with the statute. View "Larson v. Secretary of State" on Justia Law

In this dispute over the distribution of settlement proceeds that arose out of litigation regarding the Pine Creek Fire in August 2012, the Supreme Court affirmed the order of the district court approving the special master’s recommendation for allocating the Pine Creek Fire settlement proceeds among the Funks, the Pitmans, the Wilcoxes, and four other plaintiffs, holding that the district court did not clearly err by adopting the special master’s factual findings.Seeking to recover damages for injuries the Pine Creek Fire caused, the Funks, Pitmans, Wilcoxes, and four other property owners brought negligence claims against multiple defendants. The parties agreed to a settlement, and because the settlement proceeds could not cover all the plaintiffs’ damages, the district court appointed a special master to allocate the settlement proceeds. Of the settlement proceeds, the special master awarded approximately sixty-six percent to the Wilcoxes, twenty-four percent to the Funks, and three percent to the Pitmans. The district court adopted the special master’s recommendations for allocating the settlement funds. The Supreme Court affirmed, holding that the special master did not commit a clear error by finding that the Wilcoxes lost sixty acres of forested land during the fire. View "Funk v. Wilcox" on Justia Law

The Supreme Court affirmed the findings of the district court that a confessed judgment was unreasonable and the product of collusion, and, on the basis of these findings, reversed and remanded the district court’s amended judgment with instructions to dismiss Plaintiffs’ claims with prejudice, holding that the district court abused its discretion when it opted to reduce the settlement amount rather than dismiss the action.Plaintiff brought this action against a contractor after it discovered construction defects and associated problems with a massive luxury home. The district court entered a $12 million stipulated judgment against the contractor. The Supreme Court reversed with instructions for the district court to address an insurer’s request to intervene to challenge the reasonableness of the confessed judgment and whether it was the product of collusion. On remand, the district court reduced the judgment to approximately $2.4 million. The Supreme Court held (1) the confessed judgment was unreasonable and the product of collusion; (2) the district court should have dismissed the action rather than reduce the settlement amount; and (3) the district court properly awarded attorney fees and costs to the insurer, but the case is remanded for recalculation of the award to include only costs allowable under Mont. Code Ann. 25-10-201. View "Abbey/Land, LLC v. Glacier Construction Partners, LLC" on Justia Law

The Supreme Court affirmed the decision of the district court affirming the order of the standing master denying Mother’s request to relocate with the parties’ child and ordering the parenting plan, which provided for the child to continue to reside on a primary basis in Montana, holding that the district court’s affirmation of the standing master’s decision was not in error.In a stipulated final parenting plan, both parents were given nearly equal parenting time. Mother subsequently filed a notice of intent to relocate, seeking to move to Boston with the child. Father objected, and a hearing was held before the standing master. The standing master denied Mother’s request to relocate, and the district court affirmed. The Supreme Court affirmed, holding that the standing master’s findings were supported by the evidence presented and were not clearly erroneous, and the district court did not err or abuse its discretion in affirming the standing master’s findings of fact and conclusions of law. View "Northcutt v. McLaughlin" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant for failure of sexual offender to provide notice of change of residence, holding that the district court abused its discretion by granting the State’s motion to amend the information on the day of trial and immediately prior to opening statements.In allowing the amendment, the district court concluded that changing the offense date in the information from December 19, 2013 to August 5, 2014 was an amendment of form, not substance. Therefore, the court concluded, the court had the discretion to allow the amendment on the day of trial and that Defendant’s substantial rights had not been prejudiced. The Supreme Court disagreed, holding that the amendment to the date was one of substance, and therefore, the district court abused its discretion in allowing the State to amend the information on the day of trial. View "State v. Hardground" on Justia Law

The Supreme Court affirmed the order of the district court awarding punitive damages against Farmers State Financial Corporation for fraudulent stock conversion, holding that there was no error.Specifically, the Court held (1) the district court order restoring John Cote, Jr.’s converted stock constituted an award of compensatory damages, which enabled the district court to consider punitive damages against Farmers; (2) the district court did not err in awarding punitive damages against Farmers and did not abuse its discretion in determining the amount of the award; and (3) the award of punitive damages was not excessive and fell within acceptable constitutional and statutory parameters. View "In re Estate of Cote" on Justia Law