Justia Montana Supreme Court Opinion Summaries

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

The Supreme Court affirmed in part and reversed and remanded in part the order of the district court dismissing Plaintiff’s claims under the Montana Residential Landlord and Tenant Act of 1977 (Landlord-Tenant Act) and alleging violations of restrictive covenants, holding that the district court erred by dismissing Plaintiff’s claims alleging violations of the property covenants’ business use restrictions. Specifically, the Court held (1) where Plaintiff did not allege he was a landlord, tenant or guest or that he otherwise suffered an injury on the premises, Plaintiff could prove no set of facts in support of his claim that would entitle him to relief under the Landlord-Tenant Act; and (2) Plaintiff’s business use allegations satisfied notice pleading requirements, and Plaintiff pled sufficient facts to allege a violation of the covenants based on noxious or offensive activity. View "Cossitt v. Flathead Industries, Inc." on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the order of the district court dismissing Plaintiff’s claims under the Montana Residential Landlord and Tenant Act of 1977 (Landlord-Tenant Act) and alleging violations of restrictive covenants, holding that the district court erred by dismissing Plaintiff’s claims alleging violations of the property covenants’ business use restrictions. Specifically, the Court held (1) where Plaintiff did not allege he was a landlord, tenant or guest or that he otherwise suffered an injury on the premises, Plaintiff could prove no set of facts in support of his claim that would entitle him to relief under the Landlord-Tenant Act; and (2) Plaintiff’s business use allegations satisfied notice pleading requirements, and Plaintiff pled sufficient facts to allege a violation of the covenants based on noxious or offensive activity. View "Cossitt v. Flathead Industries, Inc." on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence discovered in the course of a probationary search of the vehicle in which Defendant was a passenger, holding that, under the facts of this case, Defendant had no reasonable expectation of privacy in the vehicle or its contents. Therefore, there was no search.Defendant’s counsel moved to suppress the evidence seized as a result of the vehicle search on the grounds that there was no inquiry to determine if Defendant was the owner of or if he had control over the vehicle. The district court denied the motion, concluding that a probationer need not be a driver or owner of a vehicle in order for officers to initiate a probationary search of the vehicle, so long as the probationer was a passenger immediately prior to the search. The Supreme Court affirmed, holding (1) Defendant failed to show he had an actual expectation of privacy as a passenger in the vehicle; and (2) even though the vehicle was not Defendant’s, the probation officer had the authority to search it. View "State v. Conley" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress evidence discovered in the course of a probationary search of the vehicle in which Defendant was a passenger, holding that, under the facts of this case, Defendant had no reasonable expectation of privacy in the vehicle or its contents. Therefore, there was no search.Defendant’s counsel moved to suppress the evidence seized as a result of the vehicle search on the grounds that there was no inquiry to determine if Defendant was the owner of or if he had control over the vehicle. The district court denied the motion, concluding that a probationer need not be a driver or owner of a vehicle in order for officers to initiate a probationary search of the vehicle, so long as the probationer was a passenger immediately prior to the search. The Supreme Court affirmed, holding (1) Defendant failed to show he had an actual expectation of privacy as a passenger in the vehicle; and (2) even though the vehicle was not Defendant’s, the probation officer had the authority to search it. View "State v. Conley" on Justia Law

Where Juliana Arechaga, a non-tenured teacher for Victor School District No. 7, did not receive written notice of the school district’s decision not to renew her employment contract for the 2017-2018 school year until June 7, Arechaga demonstrated that she was entitled to the school district’s performance of a “clear legal duty” to renew her contract for the upcoming school year and that there was no other “speedy and adequate remedy” available to her apart from a writ of mandamus.On May 23, 2017, the school district’s Board of Trustees voted not to renew Arechaga's employment contract for the 2017-2018 school year. Arechaga did not receive written notice of the decision until after June 1, the date a school district is obligated to provide such written notice pursuant to Mont. Code Ann. 20-4-206(1). Arechaga sought a writ of mandamus, arguing that the school district was statutorily obligated to renew her contract. The district court denied the application, finding that Arechaga’s neglect in maintaining a current address on file with the school district was the sole cause of her failure to receive timely notice of the non-renewal of her contract. The Supreme Court reversed, holding that the district court erred when it held that Arechaga did not satisfy the requirements for mandamus. View "Arechaga v. Victor School District No. 7" on Justia Law

Where Juliana Arechaga, a non-tenured teacher for Victor School District No. 7, did not receive written notice of the school district’s decision not to renew her employment contract for the 2017-2018 school year until June 7, Arechaga demonstrated that she was entitled to the school district’s performance of a “clear legal duty” to renew her contract for the upcoming school year and that there was no other “speedy and adequate remedy” available to her apart from a writ of mandamus.On May 23, 2017, the school district’s Board of Trustees voted not to renew Arechaga's employment contract for the 2017-2018 school year. Arechaga did not receive written notice of the decision until after June 1, the date a school district is obligated to provide such written notice pursuant to Mont. Code Ann. 20-4-206(1). Arechaga sought a writ of mandamus, arguing that the school district was statutorily obligated to renew her contract. The district court denied the application, finding that Arechaga’s neglect in maintaining a current address on file with the school district was the sole cause of her failure to receive timely notice of the non-renewal of her contract. The Supreme Court reversed, holding that the district court erred when it held that Arechaga did not satisfy the requirements for mandamus. View "Arechaga v. Victor School District No. 7" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court in this case involving a dispute over a road easement.Quarter Circle JP Ranch, LLC sought declaratory relief that Barbara Jerde, in Counts I-III, (1) improperly deviated from the easement onto Quarter Circle’s unburdened property, (2) used the easement to access certain property not benefitted by the easement, and (3) used the easement for residential purposes that were not contemplated by the easement. The district court granted summary judgment for Quarter Circle on Counts I-II and granted summary judgment to Jerde on Count III of the complaint. On appeal, the Supreme Court held that the district court (1) erred by concluding the road easement “for the purpose of conducting farming and ranching operations and activities” was specific in nature and unambiguously included residential use; (2) did not err by concluding that the Jerde contract property was not subject to the easement; and (3) did not err by denying joinder of the owner of the after-acquired property to the litigation. View "Quarter Circle JP Ranch, LLC v. Jerde" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court in this case involving a dispute over a road easement.Quarter Circle JP Ranch, LLC sought declaratory relief that Barbara Jerde, in Counts I-III, (1) improperly deviated from the easement onto Quarter Circle’s unburdened property, (2) used the easement to access certain property not benefitted by the easement, and (3) used the easement for residential purposes that were not contemplated by the easement. The district court granted summary judgment for Quarter Circle on Counts I-II and granted summary judgment to Jerde on Count III of the complaint. On appeal, the Supreme Court held that the district court (1) erred by concluding the road easement “for the purpose of conducting farming and ranching operations and activities” was specific in nature and unambiguously included residential use; (2) did not err by concluding that the Jerde contract property was not subject to the easement; and (3) did not err by denying joinder of the owner of the after-acquired property to the litigation. View "Quarter Circle JP Ranch, LLC v. Jerde" on Justia Law

The Supreme Court affirmed the order of the district court staying proceedings and compelling Investors to submit all asserted claims against FSC Securities Corp. (FSC) and Rocky Mountain Financial Advisors, LLC and Eric Roshoven (collectively, RMF) to arbitration.On the recommendation of RMF brokers and advisors, Investors purchased securities in Invizeon Corporation through FSC. After Invizeon failed, Investors sued FSC and RMF, alleging that FSC failed adequately to supervise its registered RMF representatives and that RMF wrongfully induced Investors to invest in Invizeon on various grounds. FSC and RMF moved to stay proceedings and compel arbitration before the Financial Industry Regulatory Authority (FINRA). After a hearing, the district court issued an order compelling Investors to submit their claims to arbitration as provided in FSC customer agreement forms. The Supreme Court affirmed, holding that the district court (1) did not err in concluding that Investors knowingly, voluntarily, and intelligently assented to the terms of the standard-form arbitration agreements and validly waived their Montana constitutional rights to full legal redress and jury trial; (2) correctly concluded that the standard-form FSC arbitration agreements were not unconscionable; and (3) correctly compelled Investors to submit their claims against FSC and RMF to arbitration. View "Lenz v. FSC Securities Corp." on Justia Law