Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court revoking a deferred sentence for failure to pay restitution, holding that the district court did not abuse its discretion.Specifically, the Court held (1) substantial evidence supported the district court’s finding that Defendant did not make good faith efforts to pay his restitution and supervision fees; (2) the district court did not abuse its discretion in revoking Defendant’s deferred sentence and imposing a new sentence; (3) revocation did not violate the due process requirements of the Fourteenth Amendment because Defendant did not make good faith effort to pay his restitution; and (4) Defendant’s obligation to pay restitution was not a fine within the purview of the Excessive Fines Clause of Mont. Const. art. II, 22 because it was remedial in nature. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the district court granting summary judgment to Flathead Electric Cooperative, Inc. (FEC) alleging a violation of the Rural Electric and Telephone Cooperative Act (RETCA), holding that the district court did not err in determining that Plaintiffs’ claims were barred by the statute of limitations.Plaintiffs were former members who received electrical services from FEC, a tax-exempt rural electrical cooperative owned by its members and organized under RETCA, but since moved out of FEC’s area. In this action, Plaintiffs alleged that FEC’s practice of allocating capital credits to each member’s capital account but not actually retiring and refunding the capital credits until sometime in the future violated RETCA. The district court granted summary judgment to FEC, ruling in part that Plaintiffs’ claims were barred by the statute of limitations. The Supreme Court affirmed, holding that Plaintiffs’ claims were barred by the statute of limitations. View "Wolfe v. Flathead Electric Cooperative, Inc." on Justia Law

The Supreme Court affirmed the order of the district court dissolving the marriage of Michele Hutchins and Michael Hutchins, holding that the parties’ premarital agreement was enforceable under Nevada law and that the district court did not abuse its discretion in its valuation or distribution of the parties’ marital estate.On appeal, Michele argued that the premarital agreement was unenforceable where she was presented with the agreement by attorneys she had never encountered before one week before the parties’ wedding date. The district court applied Montana law and enforced the agreement. The Supreme Court affirmed, holding (1) Nevada law applied to determine whether the premarital agreement was enforceable, and under Nevada law, the parties’ premarital agreement was enforceable; (2) the district court equitably apportioned the marital estate; and (3) the district court did not abuse its discretion by valuing some of the parties’ assets at the time of separation instead of at the time of dissolution. View "In re Marriage of Hutchins" on Justia Law

The Supreme Court affirmed in part, reversed in part, and remanded in part the order of the district court that awarded Kevin DeTienne $1,291,635 in lost profits, prejudgment interest accruing from September 11, 2015, $150,000 in punitive damages, and $42,009 in attorney fees and costs, holding that remand was necessary on a portion of the judgment and reversal was required on another portion.DeTienne filed suit against Bryan Sandrock seeking a declaratory judgment that Sandrock’s transfer of certain property was unlawful. A default judgment was entered awarding damages. The Supreme Court remanded to the district court for an order setting forth evidence supporting its determination of damages. After the district court entered its judgment, Sandrock appealed. The Supreme Court held (1) remand was necessary to clarify the compensatory damages award; (2) the district court did not err in awarding punitive damages; (3) remand was necessary to recalculate the prejudgment interest on a portion of the damages award, and reversal was required on a portion of the prejudgment interest award; and (4) the district court properly awarded attorney fees to DeTienne, and DeTienne was entitled to an award of reasonable costs and attorney fees incurrent during the litigation on remand, as well as attorney fees on appeal. View "DeTienne v. Sandrock" on Justia Law

The Supreme Court affirmed the decision of the district court terminating Father’s parental rights to his biological child, I.K., holding that the district court did not abuse its discretion in determining that termination was in the best interests of I.K.The district court terminated Father’s parental rights to I.K. for failure to comply with an appropriate court-approved treatment plan and because Father had been incarcerated for more than one year. The Supreme Court affirmed the district court’s judgment, holding that the district court’s finding that termination was in I.K.’s best interests was supported by clear and convincing evidence and that the court did not abuse its discretion when it found that termination of Father’s parental rights was in I.K.’s best interests. View "In re I.K." on Justia Law

The Supreme Court reversed the order of the district court denying Defendant’s motion to suppress evidence gathered from a vehicle after a traffic stop, holding that sufficient evidence did not exist for an extended stop.Defendant was charged with drug-related offenses. Defendant filed motion to suppress evidence obtained after a traffic stop. The district court denied the motion, concluding that the police officer had sufficient facts to expand the traffic stop into a drug investigation and particularized suspicion to justify a canine search of the vehicle’s exterior. The Supreme Court reversed, holding (1) the officer lacked the particularized suspicion required to extend the traffic stop into a drug investigation, and the stop violated Mont. Code Ann. 46-5-403; and (2) the extension of the stop to request a search by a K-9 unit violated the constitutional prohibition against unreasonable searches. View "State v. Wilson" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of D.A. Davidson Trust Company and denying Valentine Weisz’s motion for partial summary judgment but reversed the order ordering sanctions against Valentine’s legal counsel, Henning, Keedy & Lee, holding that the district court abused its discretion when it ordered the sanctions.Valentine, who created the Valentine E. Weisz Living Trust and named Davidson as successor trustee, accused Davidson of inappropriately seizing control of the Trust. The Supreme Court held (1) the district court did not err when it determined that Davidson properly assumed the role of successor trustee; (2) the district court did not err when it denied Valentine’s motion for partial summary judgment; but (3) the district court abused its discretion in sanctioning Valentine’s legal counsel. View "Weisz v. D.A. Davidson Trust Co." on Justia Law

The Supreme Court affirmed Defendant’s conviction of sexual intercourse without consent, entered after a bench trial, holding that the district court did not violate Defendant’s right to present a full defense when it did not affirmatively offer Defendant the opportunity to make a closing argument in the bench trial.On appeal, Defendant argued that because he was not allowed to make a closing argument he was denied his right to assistance of counsel and full presentation of his defense. The Supreme Court affirmed, holding that by failing to request the opportunity to make a closing argument, Defendant waived his right to present a closing argument. View "State v. Chaplin" on Justia Law

The Supreme Court affirmed the order of the district court terminating Mother’s parental rights to her biological child, X.M., holding that Mother was not denied due process in the termination proceedings and that the district court did not abuse its discretion in terminating Mother’s rights.Specifically, the Court held (1) clear and convincing evidence demonstrated that the termination process was fundamentally fair to Mother; and (2) where clear and convincing evidence demonstrated that Mother’s treatment plan adequately addressed her specific needs and that Mother did not complete the treatment plan, and where Mother’s condition was unlikely to change within a reasonable time, the district court did not abuse its discretion in terminating Mother’s parental rights. View "In re X.M." on Justia Law

The Supreme Court affirmed Defendant’s conviction of operating a noncommercial vehicle with an alcohol concentration of 0.08 or more, a “DUI per se,” holding that the district court did not abuse its discretion by giving a “Norquay instruction” to the jury.Although Defendant did not directly attack the Norquay instruction given by the district court, he described it as a tactic to “try to force a verdict from a potentially deadlocked jury,” comparing it to disapproved jury directives used in cases such as Jenkins v. United States, 380 U.S. 445, 446 (1965), and suggested that the court acted too hastily in giving the instruction. The Supreme Court disagreed, holding (1) the instruction complied with Montana law; and (2) the district court did not abuse its discretion in the timing of its giving of the Norquay instruction. View "State v. Sweet" on Justia Law