Justia Montana Supreme Court Opinion Summaries

Constitutional Initiative 116 (CI-116), commonly known as Marsy’s Law, violates the separate-vote requirement contained in Mont. Const. art. XIV, section 11.In this original petition for declaratory judgment and injunctive relief, Petitioners challenged the constitutionality of CI-116, which, as enacted, amended Mont. Const. art. II by adding a new section 36, titled Rights of Crime Victims. At issue before the Supreme Court was whether the procedure by which CI-116 was submitted to voters conformed to Montana’s constitutional requirements. The court held (1) this case was properly before this court as an original proceeding; (2) the single-subject requirement set forth in Mont. Const. art. V, section 11(e) applies to bills of the legislature and not to constitutional amendments; and (3) CI-116 violates the separate-vote requirement, set forth in Mont. Const. art. XIV, section 11, and is therefore void in its entirety. View "Montana Ass’n of Counties v. State" on Justia Law

The Supreme Court affirmed the district court’s determination that Defendant, who pled guilty to deliberate homicide, was competent to stand trial and that, at the time of the offense, Defendant was able to appreciate his behavior and conform to the requirements of the law. The court held (1) the district court did not err when it found that Defendant was competent to stand trial and was competent when he entered his guilty plea; (2) the district court did not err when it found that, at the time of the offense, Defendant was able to appreciate his behavior and conform his conduct to the requirements of the law; and (3) sentencing Defendant to prison did not violate his constitutional rights to be free from cruel and unusual punishments and to human dignity. View "State v. Spell" on Justia Law

The Supreme Court reversed the municipal court’s order denying Petitioner’s motion to dismiss the charge against him, holding that the municipal court abused its discretion in declaring a mistrial and in concluding that double jeopardy did not bar Petitioner’s retrial.Petitioner was charged with partner or family member assault (PFMA). The City of Billings moved for a mistrial, and the trial judge declared a mistrial based on the purportedly inconsistent testimony of a City’s witness. The judge then rescheduled Petitioner’s trial. Petitioner filed a motion to dismiss the PFMA on double jeopardy grounds. The municipal court denied the motion. The Supreme Court reversed, holding (1) there was no manifest necessity to discontinue the trial, and Petitioner’s conduct did not demonstrate a waiver of his right to object to termination of the proceedings and to a retrial; and (2) therefore, retrying Petitioner for the PFMA charge would violate his federal and state fundamental constitutional rights to be free from double jeopardy. View "Billings ex rel. Huertas v. Billing" on Justia Law

The district court did not err in denying a motion for relief from a formal testacy order under Mont. R. Civ. P. 60(b) filed by Appellant, the decedent’s wife. The Supreme Court held (1) the district court did not err in determining that Rule 60(b) did not apply in this case and that, rather, Appellant’s motion for relief from the formal testacy order must be considered under Mont. Code Ann. 72-3-317; (2) the district court did not err in denying Appellant’s motion to modify a formal testacy order under section 72-3-317(4); (3) the district court did not err in denying Appellant’s request for imposition of a constructive trust; and (4) the personal representative was entitled to attorney fees under Mont. Code Ann. 72-12-206. View "In re Estate of Erickson" on Justia Law

The Supreme Court affirmed Defendant’s conviction for felony driving under the influence (DUI), concluding that the district court did not err in denying Defendant’s motion to dismiss on the grounds that two of his prior convictions upon which the State based its felony enhancement were obtained in violation of his constitutional right to counsel. The district court denied the motion to dismiss on the ground that Defendant had not met his burden of rebutting the presumption of regularity that attached to the prior convictions. The Supreme Court affirmed, holding (1) the district court did not clearly err in finding that Defendant failed to satisfy his burden to rebutting the presumption of regularity in his two prior convictions; and (2) therefore, the district court’s determination that those convictions could be used for felony enhancement purposes was correct. View "State v. Rasmussen" on Justia Law

The Supreme Court affirmed the district court’s dismissal of this putative class action for lack of standing.Taxpayers, owners of real property and payers of property taxes in Glacier County, paid their taxes under protest 2015 in response to an independent audit that revealed deficiencies in the County’s budgeting and accounting practices. Taxpayers sued the County and the State, alleging that both entities failed to comply with budgeting and accounting laws. The district court denied class certification and dismissed the case for lack of standing, concluding that Taxpayers failed to demonstrate that they had suffered a concrete injury. The Supreme Court affirmed, holding that the district court correctly determined that Taxpayers lacked standing to sue either the County or the State. View "Mitchell v. Glacier County" on Justia Law

An injured first-party insured who is compelled to sue for underinsured motorist (UIM) benefits and recovers more at trial than the last insurance company offer is entitled to recover his or her attorney fees in an amount subsequently determined by the district court to be reasonable.In this case, Plaintiff was compelled to sue Insurer. The jury returned a verdict higher than the amount of the last offer made by Insurer to settle her UIM claim. The Supreme Court held that Insurer was required to pay Plaintiff’s attorney fees. The court thus reversed the district court order denying fees and remanded the case for further proceedings. View "Mlekush v. Farmers Insurance Exchange" on Justia Law

The Supreme Court affirmed the district court’s order granting HSBC Bank USA’s two motions for summary judgment and motion to exclude Richard Anderson’s expert in this judicial foreclosure action against Anderson and Limegrove Overseas, Ltd. Specifically, the court held that the district court (1) did not abuse its discretion in excluding Anderson’s expert witness; (2) did not err when it concluded that Montana law governs HSBC’s underlying foreclosure and that New York law governs any defenses and counterclaims; (3) did not err in granting HSBC summary judgment to foreclose; and (4) did not err in granting HSBC summary judgment on Anderson’s counterclaims. View "HSBC Bank USA, N.A. v. Anderson" on Justia Law

The Supreme Court affirmed the district court’s decision affirming the decision by the Unemployment Insurance Appeals Board denying Joyce Crouse’s claim for unemployment benefits. The district court affirmed the Board’s conclusion that Crouse did not qualify for unemployment benefits because her voluntary termination did not constitute “good cause” pursuant to Mont. Code Ann. 39-51-2302. The Supreme Court agreed with the lower court, holding (1) the findings of the Board were supported by substantial evidence; and (2) the district court correctly affirmed the Board’s decision to deny Crouse’s claim for benefits because she voluntarily resigned her position. View "Crouse v. State, Department of Labor" on Justia Law

The Supreme Court affirmed the judgment of the district court terminating Mother’s parental rights to her two children.The Department of Public Health and Human Services, Child and Family Services Division (DPHHS) filed a petition to terminate Mother’s parental rights based on her failure to complete her second treatment plan. That same day, Mother notified DPHHS that she wanted to relinquish her parental rights. Mother then signed an affidavit waiving all her parental rights and relinquishing her children for adoption. Thereafter, Mother moved to revoke her relinquishment of parental rights. The district court denied the motion. Based on the relinquishment, the district court terminated Mother’s parental rights. The Supreme Court affirmed, holding that the district court did not err by denying Mother’s motion to set aside her relinquishment of parental rights where Mother’s relinquishment was not obtained by duress. View "In re N.R.A." on Justia Law