Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court granted the State’s motion to dismiss and Jefferson County’s motion for summary judgment as to Plaintiffs’ complaint against special deputy prosecutor Steven Shapiro, the State, and Jefferson County, holding that the district court properly concluded that Shapiro was entitled to absolute prosecutorial immunity and that this immunity was properly extended to both Jefferson County and the State.Plaintiffs brought this complaint seeking damages under 42 U.S.C. 1983, alleging violations of their child’s constitutional rights, a Dorwart claim, and a malicious prosecution claim. Plaintiffs also filed a negligence claim against Jefferson County. The district court granted the motion to dismiss brought by the State and Shapiro on the grounds of absolute prosecutorial immunity. The court then granted summary judgment for Jefferson County on the grounds that the public duty doctrine barred Plaintiffs’ claims. The Supreme Court affirmed, holding that the district court (1) correctly concluded that Shapiro was entitled to absolute prosecutorial immunity when he signed an affidavit establishing probable cause to file a petition initiating delinquency proceedings against Plaintiffs’ child; (2) properly extended this immunity to Jefferson County and the State; and (3) correctly concluded that the public duty doctrine prevented recovery against Jefferson County. View "Renenger v. State" on Justia Law

The Supreme Court affirmed the district court’s findings of fact and conclusions of law setting forth the court’s parenting plan, which provided for the parties’ children to reside on a primary basis in Columbus, Montana, holding that the district court did not abuse its discretion.The Supreme Court affirmed and declined to award attorney fees, holding (1) the district court’s findings were sufficiently pertinent to the issues, comprehensively set forth the basis for the court’s decision, were supported by the evidence, and were not clearly erroneous; (2) the court’s conclusions of law were correct; and (3) the court employed conscientious judgment in reaching its decision. View "In re Marriage of Williams" on Justia Law

The Supreme Court reversed the decision of the district court affirming the order of the Missoula Municipal Court’s denying Defendant’s motion to strike a twenty-five-dollar surcharge to fund the city attorney’s office after she pleaded no contest to disorderly conduct, holding that the Municipal Court exceeded its statutory authority by imposing the surcharge.Specifically, the Supreme Court held that because the Municipal Court’s written sentencing order included a surcharge that imposed a greater burden on Appellant than what Montana statutes allow for an offense made criminal by state law, the surcharge portion of the sentence was illegal. The Supreme Court remanded the matter with instructions that the Municipal Court strike the surcharge. View "City of Missoula v. Franklin" on Justia Law

The Supreme Court affirmed the district court’s orders granting motions to dismiss Plaintiffs’ negligence claims against BNSF Railway Company, holding that a company does not consent to general personal jurisdiction by registering to do business in Montana and voluntarily conducting in-state business activities.BNSF, a rail carrier incorporated in Delaware with its principal place of business in Texas, registered to do business in Montana and designated an in-state agent for service of process. Plaintiffs filed suit against BNSF under the Federal Employers’ Liability Act for injuries allegedly sustained while working for BNSF in states other than Montana. BNSF moved to dismiss Plaintiffs’ claims for lack of personal jurisdiction. The district court determined that BNSF did not consent to personal jurisdiction in Montana and, accordingly, granted BNSF’s motions to dismiss. The Supreme Court affirmed, holding (1) a foreign corporation does not consent to general personal jurisdiction when it registers to do business in Montana and then voluntarily conducts in-state business activities; and (2) accordingly, BNSF did not consent to general personal jurisdiction in this case. View "Deleon v. BNSF Railway Co." on Justia Law

The Supreme Court exercised supervisory control over pending proceedings in the underlying matter of Cepeda v. Montana State University and reversed an order sanctioning Montana State University-Bozeman (MSU), holding that the district court abused its discretion in imposing default judgment as an evidence spoliation sanction pursuant to Mont. R. Civ. P. 37(b)-(c) and (e).Plaintiff filed a claim alleging that MSU negligently hired or supervised a faculty member and that MSU’s negligence caused Plaintiff to suffer harm. Two and a half years after the district court heard oral argument on the parties’ cross-motions for summary judgment, discovery sanctions, and preliminary evidentiary rulings, the district court granted Plaintiff’s sanctions motion and summarily adjudicated liability against MSU as an evidence spoliation sanction. The Supreme Court held (1) exercise of supervisory control was necessary and proper because this case presented a significant question as to whether the district court was proceeding under a mistake of law which, if uncorrected, would likely cause significant injustice rendering ordinary appeal inadequate; and (2) the district court abused its discretion in imposing default judgment against MSU as a spoliation sanction under Rule 37(b)-(c) and (e). View "Montana State University-Bozeman v. First Judicial District Court" on Justia Law

The Supreme Court affirmed the summary judgment dismissal of Plaintiff’s medical malpractice claim against Defendant, holding that the district court did not err by ruling that Plaintiff’s expert was not qualified under Mont. Code Ann. 26-2-601(1)(a).Plaintiff brought this action claiming that Defendant breached the standard of care when performing a spinal surgery on Plaintiff. Defendant moved for summary judgment, arguing that Plaintiff’s expert was not qualified to opine on this malpractice claim. The district court agreed and granted summary judgment in favor of Defendant. The Supreme Court affirmed, holding that the district court did not err by excluding the testimony of Plaintiff’s medical expert under section 26-2-601(1)(a) and granting summary judgment on that basis. View "Melton v. Speth" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of stalking Thresa Goldberg and sentencing Defendant to five years in prison with two years suspended but instructed the court to correct its written judgment regarding the amount of restitution to be paid by Defendant.A jury convicted Defendant of stalking and the district court sentenced Defendant to a term of imprisonment and $42,798.90 in restitution. The Supreme Court held (1) although Defendant could not see Goldberg during her testimony, Defendant’s trial satisfied the elements of confrontation and did not violate his rights under the Sixth Amendment to the United States Constitution or Mont. Const. art. II, 24; and (2) the district court’s written judgment requiring Defendant to pay $47,798.90 in restitution was incorrect and should be corrected to match the amount of $42,262.06 in restitution included in the restitution order. View "State v. Weik" on Justia Law

The Supreme Court affirmed the order of the Fourth Judicial District Court, Missoula County (Montana Court) determining that it had jurisdiction over a child custody proceeding concerning Father’s minor child (Child), holding the court did not err in finding Child's home state to be Montana and assuming initial subject matter jurisdiction over the child custody proceeding.Child was born in Montana, where she lived with Mother after Father moved to Minnesota. Mother and Child moved to Minnesota and lived there for approximately eight months before moving back to Montana. When Father “took custody” of Child Mother commenced a child custody proceeding by petitioning the Montana Court to establish a parenting plan for Child. Father then brought a separate custody proceeding in a Minnesota Court by filing complaint to establish paternity and resolve parenting issues. The Montana Court determined Montana to be the home state of Child and assumed jurisdiction over the matter. The Supreme Court affirmed, holding that, consistent with the requirements and intent of Uniform Child Custody Jurisdiction and Enforcement Act, the Montana and Minnesota Courts appropriately communicated and cooperated to resolve the jurisdictional issue; and (2) there was substantial credible evidence supporting the findings and conclusions of the Montana Court. View "Smalling v. Klubben" on Justia Law

The Supreme Court affirmed Defendant’s conviction for felony possession of methamphetamine and misdemeanor possession of marijuana possession but reversed his sentence, holding that trial counsel’s deficient performance prejudiced Defendant during sentencing.Specifically, the Court held (1) Defendant’s contention that trial counsel provided ineffective assistance by failing to file a motion to suppress evidence found during a search incident to arrest because Defendant’s initial arrest was illegal was not reviewable on direct appeal; (2) trial counsel provided ineffective assistance by incorrectly advising the district court that it had no authority to suspend or defer Defendant’s sentence; and (3) the district court improperly imposed multiple court information technology user surcharges in Defendant’s sentence. The Court remanded the case for a new sentencing hearing. View "State v. Larsen" on Justia Law

The Supreme Court affirmed the district court’s entry of judgment as a matter of law in favor of Defendants, corporate entities and individuals, at the close of Plaintiff’s case-in-chief in the bench trial held on her claims, holding that there was no prejudicial error in the proceedings below.On the scheduled day for trial, the district court noted that Plaintiff’s claims were “not entirely clear” but understood them to constitute a derivative action seeking forced dissolution of the corporations. Plaintiff’s evidence in support of her case focused primarily on allegations of corporate records mismanagement. At the close of Plaintiff’s case-in-chief, the district court granted judgment as a matter of law for Defendants. The court then granted an individual defendant attorney fees pursuant to the equity exception to the American Rule. The Supreme Court affirmed and granted Defendants’ request to declare Plaintiff a vexatious litigant, holding (1) the district court did not err in granting judgment in favor of Defendants; (2) the district court did not err in granting attorney fees; (3) Plaintiff was not denied a fair trial; and (4) the district court did not abuse its discretion in the administration of the trial. View "McCann v. McCann" on Justia Law