Justia Montana Supreme Court Opinion Summaries

Under the particular facts and circumstances of this case, the municipal court erred in denying Defendant’s motion to suppress evidence.Defendant was found guilty of being a minor in possession of alcohol. Before her non-jury trial, Defendant moved for suppression of the State’s evidence of her age and date of birth on the asserted ground that the police unreasonably prolonged its initial investigative stop of her and that the police subjected her to a custodial interrogation without a rights advisory. The municipal court denied the motion. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) the police had sufficient particularized suspicion of criminal activity to initially stop Defendant and question her about her name, age, and conduct regarding the offense of minor in possession of alcohol; (2) the police had sufficient particularized suspicion of criminal activity to continue to detain Defendant for further investigation; but (3) the continuing temporary investigative stop and related non-custodial interrogation ripened into a custodial interrogation without a Miranda advisory and waiver, in violation of the Fifth Amendment of the United States Constitution and Mont. Const. art. II, 25, and therefore, the motion to suppress should have been granted. View "City of Missoula v. Kroschel" on Justia Law

In this condemnation proceeding initiated by the City of Missoula to condemn the water system serving the City, previously owned by Property Owners, the Supreme Court affirmed in part and reversed and remanded in part the district court’s orders resolving Property Owners’ claims for attorney and expert fees.After a trial, Property Owners moved for reimbursement of their litigation expenses, arguing that they were prevailing parties. Property Owners argued that Mont. Code Ann. 70-30-306(2) and (3), which cap reimbursement for attorney and expert fees to the customary rate in the county where the case is tried, is unconstitutional both facially and as-applied. The district court concluded that Property Owners were prevailing parties with a right to be reimbursed for their necessary litigation expenses but denied the constitutional challenges to the statute. On appeal, the Supreme Court held that the district court (1) did not err in denying Property Owners’ facial constitutional challenge to Mont. Code Ann. 70-30-306, but as to Property Owners’ as-applied constitutional challenge to the statute, this matter must be remanded for further proceedings; (2) did not err by determining that Property Owners were prevailing parties and entitled to recover litigation expenses; and (3) did not err in awarding attorneys’ fees for out-of-state attorneys. View "City of Missoula v. Mountain Water Co." on Justia Law

In this condemnation proceeding initiated by the City of Missoula to condemn the water system serving the City, previously owned by Property Owners, the Supreme Court affirmed in part and reversed and remanded in part the district court’s orders resolving Property Owners’ claims for attorney and expert fees.After a trial, Property Owners moved for reimbursement of their litigation expenses, arguing that they were prevailing parties. Property Owners argued that Mont. Code Ann. 70-30-306(2) and (3), which cap reimbursement for attorney and expert fees to the customary rate in the county where the case is tried, is unconstitutional both facially and as-applied. The district court concluded that Property Owners were prevailing parties with a right to be reimbursed for their necessary litigation expenses but denied the constitutional challenges to the statute. On appeal, the Supreme Court held that the district court (1) did not err in denying Property Owners’ facial constitutional challenge to Mont. Code Ann. 70-30-306, but as to Property Owners’ as-applied constitutional challenge to the statute, this matter must be remanded for further proceedings; (2) did not err by determining that Property Owners were prevailing parties and entitled to recover litigation expenses; and (3) did not err in awarding attorneys’ fees for out-of-state attorneys. View "City of Missoula v. Mountain Water Co." on Justia Law

The Supreme Court affirmed the district court’s order denying Defendant’s motion to dismiss the charge against him for lack of subject matter jurisdiction, holding that the district court did not err in concluding that the State’s appeal was not premature and that it had subject matter jurisdiction over the proceeding.The State charged Defendant with driving under the influence of alcohol or drugs (DUI) in the justice court. Defendant successfully moved to dismiss the State’s case on the ground that there was insufficient probable cause for Defendant’s arrest. Following the justice court’s oral order dismissing the State’s case but prior to its issuance of the written order, the State appealed to the district court. Defendant moved to dismiss, arguing that the State’s appeal was premature. The district court concluded (1) the State’s appeal was not premature; (2) the court had subject matter jurisdiction; and (3) there was sufficient probable cause to arrest Defendant. Defendant was subsequently convicted of DUI. The Supreme Court affirmed, holding that, under Mont. Code ann. 46-17-311(2) and 46-20-103(20(a), the State’s appeal was not premature. Therefore, the district court did not err by denying Defendant’s motion to dismiss for lack of subject matter jurisdiction. View "State v. Reger" on Justia Law

The Supreme Court affirmed the district court’s order denying Defendant’s motion to dismiss the charge against him for lack of subject matter jurisdiction, holding that the district court did not err in concluding that the State’s appeal was not premature and that it had subject matter jurisdiction over the proceeding.The State charged Defendant with driving under the influence of alcohol or drugs (DUI) in the justice court. Defendant successfully moved to dismiss the State’s case on the ground that there was insufficient probable cause for Defendant’s arrest. Following the justice court’s oral order dismissing the State’s case but prior to its issuance of the written order, the State appealed to the district court. Defendant moved to dismiss, arguing that the State’s appeal was premature. The district court concluded (1) the State’s appeal was not premature; (2) the court had subject matter jurisdiction; and (3) there was sufficient probable cause to arrest Defendant. Defendant was subsequently convicted of DUI. The Supreme Court affirmed, holding that, under Mont. Code ann. 46-17-311(2) and 46-20-103(20(a), the State’s appeal was not premature. Therefore, the district court did not err by denying Defendant’s motion to dismiss for lack of subject matter jurisdiction. View "State v. Reger" on Justia Law

In this complaint alleging breach of a lease, the Supreme Court affirmed the order of the district court denying the motions to set aside default and default judgment filed by Anthony Raelund, Candice Raelund, and Raelund Family Trust (collectively, the Raelunds) and the motion for leave to intervene filed by Brooke Anthony Weeks. The Court held that the district court did not abuse its discretion in (1) denying the motions to set aside default and default judgment for lack of standing to pursue the motions; and (2) denying Weeks’ motion to intervene, where Weeks was not entitled to intervene as a matter of right under Mont. R. Civ. P. 24(a). View "Enz v. Raelund" on Justia Law

In this complaint alleging breach of a lease, the Supreme Court affirmed the order of the district court denying the motions to set aside default and default judgment filed by Anthony Raelund, Candice Raelund, and Raelund Family Trust (collectively, the Raelunds) and the motion for leave to intervene filed by Brooke Anthony Weeks. The Court held that the district court did not abuse its discretion in (1) denying the motions to set aside default and default judgment for lack of standing to pursue the motions; and (2) denying Weeks’ motion to intervene, where Weeks was not entitled to intervene as a matter of right under Mont. R. Civ. P. 24(a). View "Enz v. Raelund" on Justia Law

The Supreme Court reversed the district court’s deemed denial of Scottsdale Insurance Company’s motion to set aside the default judgment entered against it, holding that Scottsdale satisfied its burden of establishing that doubt existed concerning whether service was properly effectuated.National Parks Reservations (NPR) filed a complaint and demand for jury trial, naming Scottsdale. Because Scottsdale was a foreign insurer, NPR was statutorily required to serve Scottsdale through the Office of the Montana State Auditor, Commissioner of Securities and Insurance (the Commissioner). The Commissioner, in turn, was statutorily required to forward the complaint and summons to Scottsdale. After Scottsdale failed to appear the district court entered a partial default judgment against Scottsdale. Scottsdale moved to set aside the default judgment, arguing that both NPR and the Commissioner had failed strictly to comply with foreign insurer service requirements under Mont. Code Ann. 33-1-603(1), and, thus, the default judgment was void. Scottsdale’s motion was deemed denied. The Supreme Court reversed, holding that Scottsdale established that doubt existed regarding whether service was properly completed by the Commissioner. View "Reservation Operations Center LLC v. Scottsdale Insurance Co." on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Plaintiff’s complaint for failure to state a claim, holding that the allegations in the complaint failed to state a claim of unjust enrichment upon which relief could be granted.Michael Grauman, the decedent, executed transfer on death (TOD) beneficiary designations for three Ameriprise Financial accounts. After the decedent died and the funds were distributed pursuant to the TOD designations, Steve Darty, the successor trustee of the Michael R. Grauman Living Trust, filed a complaint challenging the validity of the TOD designations. Darty claimed that transfers unjustly enriched the TOD beneficiaries because the decedent intended to transfer the Ameriprise accounts into the Trust. The district court concluded that the decedent’s TOD designations superseded the contrary provisions in the Trust because the Ameriprise accounts were nonprobate assets. The Supreme Court affirmed, holding that the district court correctly concluded that the decedent’s TOD designations controlled the distribution of the proceeds from the Ameriprise accounts on the decedent’s death. View "Darty v. Cornish" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of criminal possession of methamphetamine and other drug offenses after law enforcement found drugs and paraphernalia in Defendant’s pickup truck during a traffic stop, holding that the district court committed reversible error when it curtailed Defendant’s cross-examination of Leslie Hill, the lone passenger in the vehicle at the time of the traffic stop.Specifically, the Court held that the district court abused its discretion when it excluded evidence of Hill’s plea agreement with the State and prevented Defendant from fully cross-examining Hill about her plea agreement, and the error prejudiced Defendant and required a new trial. View "State v. Flowers" on Justia Law