Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed in part the district court’s denial of class certification on the basis that Plaintiff failed to satisfy the Mont. R. Civ. P. 23(b)(3) element of superiority.Plaintiff was terminated at the conclusion of her six-month probationary period due in part to concerns with her background check and credit report. Plaintiff sued the organization that performed the background check, asserting claims in her individual capacity, as well as a claim for class action. The district court determined that Plaintiff met the four rule 23(a) prerequisites but failed to meet her burden regarding the two rule 23(b)(3) requirements of predominance and superiority. The Supreme Court held (1) the district court did not abuse its discretion by denying Plaintiff’s motion for class certification on grounds that she failed to satisfy the superiority requirement, and (2) therefore, there need be no discussion regarding the district court’s holding regarding the predominance requirement. View "Ascencio v. Orion International Corp." on Justia Law

The Supreme Court affirmed the judgment of the district court reversing the decision of the Office of the Commissioner of Political Practices (the Commissioner) that the Montana Department of Fish Wildlife and Parks (FWP) was responsible for ethics violations.Trap Free Montana Public Lands (Trap Free) filed an ethics complaint alleging that FWP allowed the Montana Trappers Association (MTA) to use an FWP-owned trailer and equipment in MTA’s efforts to oppose a ballot initiative, in violation of Mont. Code Ann. 2-2-101 and -121. A hearing examiner found that FWP staff were responsible for three statutory violations for the occasions when MTA members used the trailer and equipment in conjunction with its political advocacy efforts. The Commissioner adopted the hearing examiner’s recommendation that the Commissioner impose an administrative penalty on FWP. The district court reversed, concluding that FWP employees did not violate state ethics laws. The Supreme Court affirmed, holding that where section 2-2-121(3)(a) prohibits public employees from using public resources for political purposes, and where MTA members are not public employees, there was no violation of the ethics code. View "Montana Fish, Wildlife and Parks v. Trap Free Montana Public Lands" on Justia Law

The Supreme Court reversed the judgment of the district court concluding that the weighted average discount ratio (WADR), codified in Mont. Code Ann. 16-2-101(2)(b)(ii)(B), violated liquor store owners’ (collectively, Storeowners) rights to substantive due process and equal protection.The WADR was effective from 1995 to 2016. The State, Department of Revenue (DOR) sold liquor to certified liquor stores (agency liquor stores) and provided those stores with three discounts, one of which was the WADR. The agency liquor stores sold the liquor to individual retail customers and licensed taverns and bars (licensees). When the agency liquor stores sold to licensees whole or unbroken cars of liquor, known as case lots, section 16-2-201(1) required them to provide a separate discount (case discount). Four liquor store owners certified as a class representing similarly situated liquor store owners filed suit challenging the constitutionality of the WADR. Specifically, Storeowners claimed that the WADR should have fully reimbursed them for the cost of providing the case discount to Licensees. The district court concluded that the WADR was unconstitutional. The Supreme Court reversed, holding that the WADR did not violate Storeowners’ rights to substantive due process and equal protection and was, rather, a constitutional part of a statutory scheme designed to privatize liquor stores in Montana. View "Kohoutek v. State, Department of Revenue" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the district court dismissing Plaintiff’s amended complaint against several lenders, holding that the district court did not err in dismissing some of Plaintiff’s claims but erred in dismissing the remaining claims.After Plaintiff defaulted on her loan on real property, she received at least nine notices of sale. Plaintiff filed an amended complaint against Lenders, alleging six causes of action. The district court granted Lenders’ motion to dismiss the amended complaint pursuant to Mont. R. Civ. P. 12(b)(6). The Supreme Court held that the district court (1) did not err in dismissing Plaintiff’s declaratory judgment claim as a matter of law or in dismissing Plaintiff’s negligent and/or intentional infliction of emotional distress claim fore failure to state sufficient facts to entitle her to relief; and (2) incorrectly determined that Plaintiff’s amended complaint failed to state a claim on her asserted breach of contract and breach of the implied covenant of good faith and fair dealing, Fair Debt Collection Practices Act (FDCPA), and Montana Consumer Protection Act (MCPA) claims. View "Puryer v. HSBC Bank" on Justia Law

The Supreme Court granted Petitioner’s request to exercise supervisory control over the Eighth Judicial District Court, Cascade County, in a criminal action following the district court’s denial of Petitioner’s motion to substitute assigned Judge Gregory G. Pinski (substitution motion).Petitioner was charged with assault with a weapon. Petitioner’s arraignment was scheduled for January 4 but, after Petitioner did not appear, set Petitioner’s arrangement for January 25. Petitioner appeared at his arraignment and then filed the substitution motion on January 31. The district court denied the substitution motion as untimely because it was outside of the ten-day timeframe. Specifically, the court concluded that the arraignment occurred on January 4. The Supreme Court granted Petitioner’s petition for a writ of supervisory control, holding (1) a defendant must be present at his scheduled arraignment, and if he fails to appear at the arraignment, that hearing cannot be defined as his actual arraignment; (2) instead, the arraignment is the subsequent hearing at which the defendant is formally called into open court to enter a plea answering a charge; and (3) Petitioner’s arraignment in this case occurred on January 25, and therefore, his January 31 substitution motion was timely. View "Collins v. Honorable Gregory G. Pinski" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the district court’s denials of Defendant’s motion to suppress and motion in limine and the grant of the State’s motion in limine in this criminal case.Defendant was charged with aggravated driving under the influence (DUI), a felony, or, in the alternative, aggravated DUI per se, a felony. Defendant filed a motion to suppress field sobriety tests based on newly discovered evidence calling into question whether the arresting officer made accurate individualized reports of his traffic stops and whether he possessed sufficient particularized suspicion to investigate Defendant for DUI in this case. Defendant also filed a motion in limine requesting exclusion of his prior DUI convictions. The district court denied both motions. The Supreme Court held that the district court (1) did not err by denying Defendant’s motion to suppress; (2) abused its discretion by granting the State’s motion in limine and preventing Defendant from challenging the arresting officer’s credibility in front of the jury; and (3) erred when it denied Defendant’s motion in limine and allowed the evidence of his prior DUI convictions to establish the offense of aggravated DUI. View "State v. Zimmerman" on Justia Law

The Supreme Court affirmed Defendant’s conviction for deliberate homicide, holding that the prosecutor did not commit misconduct during closing argument that prejudiced Defendant’s right to a fair trial and warranted plain error review.A jury convicted Defendant of deliberate homicide. On appeal, Defendant argued that the prosecutor committed misconduct during closing argument. Because Defendant did not object to the statements, he sought plain error review. The Supreme Court affirmed, holding that Defendant did not demonstrate that failure to review the asserted errors would result in a miscarriage of justice, raise a question about the fundamental fairness of the proceedings, or compromise the integrity of the judicial process. View "State v. Lau" on Justia Law

The Supreme Court affirmed Defendant’s conviction for assault with a weapon, two counts of partner or family member assault, and unauthorized use of a motor vehicle. The Court held that the district court (1) did not abuse its discretion by granting the State’s motion to join the first and second cases for trial, after a mistrial in the first case; (2) did not abuse its discretion by concluding that the probative value of letters letters Defendant wrote to the victim from jail was not substantially outweighed by any prejudice to Defendant and by admitting the letters into evidence; and (3) did not act arbitrarily or exceed the bounds of reason by denying Defendant’s motion for a mistrial. View "State v. Ankeny" on Justia Law

The justice court did not err in concluding that Defendant waived his right to a jury trial when he failed to appear at his jury confirmation hearing.Defendant was found guilty by the justice court of driving while under the influence of alcohol and obstructing a peace officer. On appeal, Defendant argued that the justice court erred in determining that Defendant waived his right to a jury trial when he failed to appear at the jury confirmation hearing. The Supreme Court affirmed, holding that, under the circumstances, the justice court did not err in determining that Defendant waived his right to a jury trial by failing to attend his jury confirmation hearing. View "State v. Sherlock" on Justia Law

The Supreme Court affirmed Defendant’s conviction upon a nolo contendere plea for driving under the influence (DUI), holding that the arresting officer did not unreasonably impede Defendant’s right to obtain an independent blood test, and therefore, the district court did not err in denying Defendant’s motion to dismiss the DUI charge.On appeal, Defendant argued that not releasing her at the police station and instead driving her home, ten miles from the hospital, was a deviation from standard procedure that frustrated her ability to obtain an independent blood test. The Supreme Court disagreed, holding that, under the facts of this case, the officer did not unreasonably impede Defendant’s right to obtain an independent blood test. View "State v. Neva" on Justia Law