Justia Montana Supreme Court Opinion Summaries

Frank Hallberg rented an apartment from Steve Schmitz in Helena. Schmitz sent Hallberg a 30-day notice to vacate, and upon inspecting the apartment on July 12, 2021, Schmitz found 20-30 holes in the walls. Schmitz took photos and called the police, who also documented the damage. Hallberg was charged with Criminal Mischief Damage to Rental Property.The Municipal Court scheduled an omnibus hearing, which Hallberg attended without his attorney. The hearing was rescheduled multiple times, and neither Hallberg nor his attorney appeared at the final rescheduled hearing. Consequently, the court set a bench trial for April 15, 2022, which was held on December 14, 2022. The court found Hallberg guilty and ordered him to pay $1,226.45 in restitution. Hallberg appealed to the District Court, arguing he was denied a jury trial, the evidence was insufficient, and the restitution amount was incorrect. The District Court affirmed the Municipal Court's decision, stating Hallberg waived his right to a jury trial by not objecting and that the restitution amount was supported by Schmitz’s testimony.The Supreme Court of the State of Montana reviewed the case. It held that Hallberg waived his right to a jury trial by failing to object to the bench trial. The court found sufficient evidence to support Hallberg’s conviction based on the testimonies and photographic evidence presented. The court also upheld the restitution amount, finding it was not clearly erroneous as it was supported by Schmitz’s testimony regarding repair costs. The Supreme Court affirmed the District Court’s decision. View "City of Helena v. Hallberg" on Justia Law

In August 2022, Cole Levine moved from New Mexico to Missoula, Montana, to attend law school. On August 18, 2022, a woman identified as M.H. was sexually assaulted in an alley. During the incident, the assailant took M.H.'s phone but dropped another phone, which was later identified as belonging to Levine. Following an investigation, Levine was charged with several offenses, including attempted sexual intercourse without consent and aggravated assault. On October 3, 2022, the District Court issued a search warrant to Verizon Wireless for data related to Levine's phone, which was stored on servers outside Montana.Levine filed a motion to suppress the data obtained from the warrant, arguing it was an illegal extraterritorial warrant. The Fourth Judicial District Court agreed, ruling that Montana courts did not have jurisdiction to issue such a warrant to an out-of-state entity. The court relied on the reasoning from United States v. Webb and found that the good-faith exception to the exclusionary rule did not apply, declaring the warrant void ab initio. Consequently, the court granted Levine's motion to suppress the evidence obtained from the warrant.The Supreme Court of the State of Montana reviewed the case and reversed the District Court's decision. The Supreme Court held that the Secure Communications Act (SCA) grants Montana district courts jurisdiction to issue search warrants for electronic communications stored by out-of-state third parties. Additionally, Montana law under § 46-5-605(3)(a), MCA, provides an independent basis for such jurisdiction. The Supreme Court concluded that the District Court had jurisdiction to issue the search warrant and erred in granting Levine's motion to suppress. The case was remanded for continuation of proceedings. View "State v. Levine" on Justia Law

Law enforcement responded to the defendant's home after his ex-girlfriend reported that he had threatened suicide during a phone call. The officers, aware of his history of alcohol abuse and mental health issues, entered his home without a warrant after he failed to respond to their attempts to contact him. Inside, an officer shot the defendant, believing he was armed. The defendant was charged with Assault on a Peace Officer.The District Court of the Third Judicial District denied the defendant's pretrial motions to dismiss and suppress evidence obtained from the warrantless entry. The court also denied his motion for a new trial based on an alleged Brady violation, where the defendant claimed the State failed to disclose that the officer who shot him had been shot at in a prior incident. The jury found the defendant guilty.The Supreme Court of Montana reviewed the case and affirmed the lower court's decisions. The court held that the officers' warrantless entry was justified under the community caretaker doctrine, given the exigent circumstances of a potential suicide. The court also found no Brady violation, as the undisclosed evidence about the officer's prior incident would not have changed the trial's outcome. The court concluded that the officers acted reasonably in their entry and subsequent actions, and the defendant's conviction was upheld. View "State v. Case" on Justia Law

Anthony Cordero, a student at Montana State University (MSU) during the Spring 2020 semester, sued MSU for prorated reimbursement of his tuition and fees after the university transitioned to online learning due to the COVID-19 pandemic. Cordero claimed that MSU breached an express contract to provide in-person education and services. He also asserted claims for breach of implied contract, unjust enrichment, due process violation, violation of the takings clause, and inverse condemnation.The First Judicial District Court of Lewis and Clark County dismissed four of Cordero’s six claims, including the implied contract and unjust enrichment claims, under M. R. Civ. P. 12(b)(6). The court granted summary judgment in favor of MSU on the remaining claims, including the express contract claim, and denied Cordero’s motion to certify the case as a class action. The court found that Cordero did not identify a specific, bargained-for promise by MSU to provide in-person education and that he had no compensable property interest in the tuition and fees paid.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decisions. The court held that there was an express contract between Cordero and MSU, but it did not include a specific promise to provide in-person education. The court found that MSU had the right to change its regulations and policies, including transitioning to online learning during emergencies. The court also affirmed the dismissal of the implied contract and unjust enrichment claims, noting that an implied contract cannot exist when an express contract is present. The court concluded that MSU did not breach its contractual duties regarding tuition and fees, as it maintained campus facilities and services to the extent possible during the pandemic. View "Cordero v. Montana State University" on Justia Law

A group of Bozeman residents challenged a zoning provision within the City’s Unified Development Code (UDC), claiming they were not given sufficient notice regarding the City’s consideration of an amendment. The amendment, part of a general replacement of the UDC adopted in 2018, reclassified Greek housing into a new “group living” category, allowing fraternities and sororities in certain residential zones. The residents, who began experiencing disturbances from a nearby fraternity house in early 2022, filed a complaint against the City in October 2022, asserting that the notice provided for the zoning change was insufficient.The Eighteenth Judicial District Court of Gallatin County granted summary judgment in favor of the residents, declaring the Greek housing reclassification void ab initio due to insufficient notice. The court reasoned that the City’s notice did not adequately inform the public about the specific change and its impact on the community. The court also held that the residents’ claims were not time-barred under § 2-3-114(1), MCA, because the provision was void from the beginning, and thus the statute of limitations did not apply.The Supreme Court of the State of Montana reversed the District Court’s decision. The Supreme Court held that § 2-3-114(1), MCA, which requires challenges to agency decisions to be filed within 30 days of when the person learns or reasonably should have learned of the decision, applied to this case. The Court concluded that the residents’ action was untimely because they filed their complaint more than 30 days after they became aware of the zoning change in April 2022. The Supreme Court remanded the case for entry of judgment in favor of the City. View "Johnson v. City of Bozeman" on Justia Law

In 2003, Joshua Duane Wolfblack was charged with burglary and theft in Flathead County, Montana. He pled guilty to felony theft, and the burglary charge was dismissed. He received a ten-year sentence with five years suspended. In 2010, Wolfblack was charged with felony sexual intercourse without consent in Lewis and Clark County, pled guilty, and received another ten-year sentence with five years suspended. Subsequently, his 2003 theft sentence was revoked, and he was given a five-year suspended sentence to run consecutively to his 2010 sentence.The District Court of the Eleventh Judicial District, Flathead County, revoked Wolfblack’s 2010 theft sentence in 2022, imposing a five-year term. Wolfblack appealed, arguing the court lacked authority to impose a consecutive sentence upon revocation. The District Court had denied his motion to dismiss, reasoning that the sentences were presumed to run consecutively under Montana law.The Supreme Court of the State of Montana reviewed the case. The court held that under § 46-18-203, MCA, the District Court did not have the authority to impose a consecutive sentence upon revocation that extended the original sentence. The court emphasized that sentencing upon revocation is governed by § 46-18-203, MCA, not § 46-18-401, MCA, which applies to initial sentencing. The court found that the District Court’s imposition of a consecutive sentence violated the statutory limits, as it effectively increased the term of the original sentence. Consequently, the Supreme Court reversed the District Court’s judgment, vacated the sentence, and dismissed the proceedings. View "State v. Wolfblack" on Justia Law

Robert Frisk owns property at 1196 Swan Hill Drive, Bigfork, Montana, and John and Lori Thomas own the neighboring property at 1194 Swan Hill Drive. The properties share a common driveway and a water well located on Frisk’s property. Disputes arose over the width of the easement for the driveway and access to the water well, leading Frisk to file a lawsuit seeking a declaration of an easement and an injunction against Thomas. Thomas counterclaimed for breach of contract regarding the water well agreement and trespass due to Frisk’s fence and house encroaching on their property.The Montana Eleventh Judicial District Court granted Frisk a prescriptive easement over 15 feet of the existing roadway and an equitable easement for the encroaching portion of Thomas’s property. The court dismissed Thomas’s breach of contract claims but affirmed his right to access the water well, imposing additional restrictions on this access due to the parties' animosity. Thomas appealed the decision.The Supreme Court of the State of Montana reviewed the case and found that Montana law does not recognize the creation of an equitable easement. The court held that Frisk must remove his fence and gate from Thomas’s property but allowed the house to remain due to its de minimis encroachment. The court affirmed the additional restrictions on the water well agreement, finding them reasonable and consistent with the agreement’s terms. The decision was affirmed in part and reversed in part. View "Frisk v. Thomas" on Justia Law

The case involves a water rights dispute on Indian Creek in Madison County, Montana. William Fraser claimed a senior stock use water right in Indian Creek, which Bradley Livestock, LC contested. Fraser's claim is based on historical use dating back to the late 1800s when his predecessor, William Tiernan, acquired ranchland and water rights in the Ruby Valley. The dispute arose when Fraser sought enforcement of his water right, and the Water Commissioner refused, leading Fraser to file a complaint.The Fifth Judicial District Court certified Fraser’s complaint to the Montana Water Court to resolve the water distribution controversy. The Water Court issued an order decreeing Fraser’s stock use claim as senior to Bradley’s irrigation rights in Indian Creek. Bradley appealed, arguing that the Water Court misinterpreted a 1905 District Court decree and that Fraser’s chain of title was broken, thus invalidating his claim.The Supreme Court of the State of Montana reviewed the case. The court affirmed the Water Court’s decision, holding that Fraser has a valid stock use right with an April 20, 1866 priority date. The court found that the chain of title supporting Fraser’s claim was unbroken and that the Water Court correctly interpreted the historical evidence. The court also upheld the Water Court’s interpretation of the 1905 decree, which limited Fraser’s right to make a call on junior appropriators after July 15 unless he could show that curtailment would result in water reaching his property in beneficial amounts. The court concluded that this limitation only applies to appropriators addressed in the 1905 decree. View "Bradley Livestock v. Fraser" on Justia Law

Dr. Thomas C. Weiner, an oncologist, had his medical staff membership and clinical privileges revoked by St. Peter’s Health (SPH) in 2020. Prior to this, Weiner had initiated litigation (Weiner I) against SPH, alleging wrongful termination, civil conspiracy, and due process violations. During Weiner I, he requested an administrative hearing under SPH Bylaws, leading SPH to seek a stay, which was denied. Weiner was allowed to amend his complaint once but was denied a second amendment to include claims related to the administrative review process.The First Judicial District Court, Lewis and Clark County, denied Weiner’s motion to file a second amended complaint in Weiner I, citing untimeliness and potential prejudice to SPH. Subsequently, Weiner filed a new lawsuit (Weiner II) in June 2022, asserting claims similar to those he sought to add in Weiner I. SPH moved to dismiss Weiner II, arguing it was an impermissible collateral attack and constituted claim-splitting. The District Court dismissed Weiner II based on res judicata, reasoning that Weiner could have included his new claims in Weiner I and that the denial of his motion to amend was a final judgment on the merits.The Supreme Court of the State of Montana reviewed the case and affirmed the dismissal of Weiner II, but on different grounds. The court held that the District Court erred in applying res judicata because the denial of the motion to amend in Weiner I was not a final judgment on the merits. However, the Supreme Court concluded that Weiner II was properly dismissed under the doctrine of claim-splitting, which prevents parties from maintaining multiple lawsuits based on the same transaction or series of connected transactions. The court emphasized that claim-splitting aims to promote judicial economy and prevent duplicative litigation. View "Weiner v. St. Peter's Health" on Justia Law

The case involves a dispute between Judge Kerry L. Burman, the Glendive City Judge, and Mayor Deb Dion of Glendive, Montana. Judge Burman petitioned for a writ of mandamus to reinstate Mary York to her position as Clerk of Glendive City Court after Mayor Dion terminated York's employment. The termination occurred following a disagreement over the justification for York's attendance at a training conference. York was terminated without notice and escorted out of the court, leaving unfinished work and causing operational disruptions.The District Court initially ordered York's interim reinstatement pending further review. Judge Burman argued that Mayor Dion's actions violated state statute, the court's holding in Carlson v. City of Bozeman, and the constitutional doctrine of separation of powers. Respondents contended that Mayor Dion had the statutory authority to terminate York, who was still in her probationary period, and that the court's operations were not significantly impaired.The Supreme Court of the State of Montana reviewed the case. The court determined that the matter was more appropriately characterized as an application for a writ of prohibition rather than mandamus. The court found that Mayor Dion's actions disrupted the court's operations and violated § 3-1-111, MCA, which grants courts the authority to control their ministerial officers. The court held that the executive's authority to hire or fire employees must be exercised in a manner that does not impair the court's ability to conduct its business.The Supreme Court of Montana granted the petition for a writ of prohibition, arresting Mayor Dion's action of terminating York's employment. The court emphasized the need for coordination between branches of government to avoid such disruptions. View "Burman v. City of Glendive" on Justia Law