Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed an order of the district court affirming the Human Rights Commission’s decision granting summary judgment in favor of Costco Wholesale Corporation and dismissing Plaintiff’s claim of unlawful discrimination in employment on the basis of a disability and failure to make reasonable accommodation, holding that the district court did not err in affirming the Commission’s grant of summary judgment in favor of Costco where Costco rebutted Plaintiff’s prima facie case of discrimination with evidence that it terminated his employment for legitimate business reasons that were not a pretext for discrimination.On appeal, Plaintiff argued that Costco terminated him for conduct resulting from a disability, which cannot qualify as a legitimate, nondiscriminatory basis for termination. The Supreme Judicial Court disagreed, holding that Costco came forward with a legitimate, nondiscriminatory reason for terminating Plaintiff. View "Jackson v. Costco Wholesale" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of State Compensation Mutual Insurance Fund (State Fund) on Plaintiff’s claims that, inter alia, Mont. Code Ann. 39-71-605 was unconstitutional because it permits workers’ compensation insurers to obtain multiple medical examinations of a claimant and that State Fund committed a constitutional tort against her, holding that the district court properly dismissed the claims.Plaintiff brought this proceeding challenging State Fund’s handling of her workers’ compensation claims. The district court granted summary judgment for State Fund. The Supreme Court affirmed, holding (1) section 39-71-605 is neither facially unconstitutional nor unconstitutional as applied in Plaintiff’s case; and (2) there was no basis to claim a constitutional tort. View "Robinson v. State Compensation Mutual Insurance Fund" on Justia Law

The Supreme Court affirmed the district court’s denial of Appellants’ motion to compel arbitration of claims brought by Appellee, holding that the district court did not err in denying Appellants’ motion to compel arbitration.At issue in this case was a dealership agreement containing an arbitration clause. The agreement was signed by Frontline Ag, LLC and John Deere Company. Appellee owned an interest in Frontline. The dealer agreement contained an arbitration clause requiring arbitration of disputes between Deere and Frontline, the dealer. Appellee eventually filed this action against Deere alleging, inter alia, tortious interference with contract. Deere moved to stay the proceedings and compel arbitration. The district court denied the motion to compel arbitration, reasoning that Appellee never agreed to arbitrate his claims against Deere and that the dealer agreement only required arbitration of disputes between Deere and Frontline. The Supreme Court affirmed, holding that the arbitration clause did not incorporate Appellee’s personal damage claims within its definition of disputes subject to mandatory arbitration. View "Anderson v. John Deere & Co." on Justia Law

The Supreme Court affirmed Defendant’s convictions but remanded to the district court with instructions to strike one of the information technology fees imposed in Defendant’s sentence, holding that the district court improperly imposed multiple court information technology fees but otherwise did not err.Defendant pleaded guilty to two counts of felony assault with a weapon in violation of Mont. Code Ann. 45-5-213 and received concurrent forty-year prison sentences. The Supreme Court affirmed in part and remanded in part, holding (1) Defendant’s right to a speedy trial was not violated; (2) the district court did not deny Defendant due process of law during sentencing when it admitted a jailhouse informant letter into evidence or by basing its sentencing decision on any improper information; and (3) the district court improperly imposed two court information technology user surcharges in Defendant’s sentence. View "State v. Snider" on Justia Law

The Supreme Court affirmed in part and reversed in part Defendant’s convictions of two counts of tampering with or fabricating physical evidence and one count of impersonation of a public servant, holding that Defendant was improperly convicted of two offenses arising out of the same transaction.The Supreme Court reversed Defendant’s conviction for the second count of tampering with or fabricating evidence, holding (1) the district court did not abuse its discretion by admitting evidence related to Defendant’s prior acts; (2) Defendant’s counsel provided deficient representation for failing to object to Defendant’s convictions under the multiple conviction statute, Mont. Code Ann. 46-11-410, and the error prejudiced Defendant; and (3) the district court erred by imposing a “per count” surcharge for count information technology under Mont. Code Ann. 3-1-317(1)(a). View "State v. Ellison" on Justia Law

The Supreme Court reversed the order of the district court terminating Mother’s parental rights to her two children, holding that the district court erred when it proceeded with termination of Mother’s parental rights before it had a conclusive determination of the children’s status in the Chippewa Cree Tribe and when it did not address whether the Department of Public Health and Human Services made “active efforts” to prevent the breakup of the Indian family and that those efforts were unsuccessful.Specifically, the Court held (1) where the district court had reason to believe that the children may be eligible for enrollment in the Chippewa Cree Tribe, the court failed to satisfy the threshold requirement of the Indian Child Welfare Act to verify the children’s eligibility; (2) the district court did not err when it did not address whether the Department provided “active efforts” pursuant to 25 U.S.C. 1912(d); and (3) Mother’s due process were not violated when the Department raised the issue of abandonment during closing arguments at the termination hearing and Mother’s counsel did not object. View "In re L.A.G." on Justia Law

The Supreme Court affirmed Defendant’s judgment of conviction of felony theft and misdemeanor theft, as defined by Mont. Code Ann. 45-6-301(1), holding that the district court erred in allowing the State to present inadmissible expert legal opinion testimony but that the error was harmless.On appeal, Defendant argued that the district court (1) erroneously denied his pretrial and post-verdict motions to dismiss based on the principle that a claim of right precludes a purposeful deprivation of property under the statute, (2) erroneously failed to instruct the jury on the claim-of-right defense, and (3) erroneously allowed the state to present expert testimony on matters of law. Regarding Defendant’s first two assignments of error, the Supreme Court held that the district court committed no error. And although the district court erroneously admitted inadmissible expert legal opinion testimony, the Supreme Court held that the error was harmless under the circumstances of this case. View "State v. Mills" on Justia Law

The Supreme Court affirmed the judgment of the district court sentencing Defendant to 100 years imprisonment with seventy-five years suspended and twenty-five years of parole ineligibility on each count of two counts of incest but reversed and remanded for the district court to correct the written judgment to indicate that the sentences will run concurrently.The Supreme Court held (1) Defendant waived his statutory vagueness claims by failing to raise them before trial; (2) Defendant’s sentence was not illegal, and the district court’s underlying factual findings supporting the sentence and its decision not to apply an exception were not clearly erroneous; and (3) the district court erred when it issued a written judgment that conflicted with its oral pronouncement of the sentence. View "State v. Hamilton" on Justia Law

The Supreme court affirmed the judgment of the district court granting summary judgment to NorthWestern Corporation, doing business as NorthWestern Energy (NWE), on Boulder Hydro LP’s (Boulder) complaint, holding that the district court’s decision was not in error or an abuse of discretion.At issue in this contract pricing dispute was how to move forward after the Dow Jones Mid-C price index ceased publication in September 2013 and could no longer serve as the price setting reporting term in the parties’ power purchase agreement (PPA). The district court concluded that the Dow should be replaced with a reasonable market rate reporting substitute and held Boulder to its fifteen-year, market rate PPA. The Supreme Court affirmed, holding that the district court correctly interpreted the PPA between NWE and Boulder, properly granted summary judgment for NWE, and did not err in finding that a reasonable price reporting index should replace the Dow Mid-C index under the parties’ PPA. View "Boulder Hydro Limited Partnership v. NorthWestern Corp." on Justia Law

The Supreme Court affirmed the district court’s decision sentencing Defendant to the Montana State Prison (MSP) instead of committing him into the custody of the Montana Department of Health and Human Services (DPHHS), holding that the court’s decision was supported by the record.Defendant entered an Alford plea to the charge of deliberate homicide. During sentencing, Defendant argued that he should be sentenced to DPHHS custody rather than to MSP because he allegedly suffered from a mental disease, defect, or development disability that rendered him unable to appreciate the criminality of his behavior or to conform his behavior to the requirements of law. The district court disagreed and sentenced Defendant to life in prison. The Supreme Court affirmed, holding that the sentence of life imprisonment was not imposed in error and was supported by the record. View "State v. Coburn" on Justia Law