Justia Montana Supreme Court Opinion Summaries

Under Montana law, a debtor may claim an exemption for a health savings account (HSA) within the constraints imposed by Mont. Code Ann. 25-13-608(1)(d) or (f).Debtor in this case filed a Chapter 11 bankruptcy petition. Debtor claimed his HSA exempt in the amount of $14,319.61 pursuant to section 25-13-608(1)(d) or (f). Debtor’s withdrawal of funds from the HSA was applied exclusively to qualified medical expenses. The trustee filed an objection to the claim of exemption. The bankruptcy court certified a question on the issue to the Supreme Court. The Supreme Court held that a debtor may claim an exemption for an HSA to the extent that it is “used or will be used to pay for the care” described in section 25-13-608(1)(f). View "In re John Charles Giacometto" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to dismiss the criminal charges against her for failure to provide a speedy trial, holding that Defendant did not demonstrate entitlement to dismissal of the charges.Defendant was charged with felony robber, felony possession of dangerous drugs, and use of a firearm. Defendant later moved to dismiss the charges for lack of a speedy trial. The district court denied the motion to dismiss. Defendant pleaded guilty to felony robbery with the use of a weapon. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to dismiss for failure to provide a speedy trial; and (2) Defendant’s claim that she received ineffective assistance of counsel in regard to her motion to dismiss was not properly raised on appeal. View "State v. Llamas" on Justia Law

Because Defendant did not comply with the statutes, rules and regulations governing Block Management Area (BMA) hunting, he did not have permission to hunt and harvest game at Skytop Ranch BMA, thus violating Mont. Code Ann. 87-6-415(1).Defendant was convicted of hunting without landowner permission in violation of section 87-6-415(1). The conviction stemmed from Defendant’s act of harvesting a cow elk without first obtaining permission to hunt at Skytop Ranch BMA. Defendant appealed the denial of his motion to dismiss, arguing that by participating in The Department of Fish, Wildlife, and Parks’ Block Management Program, Skytop Ranch statutorily gave its permission for the public to hunt on its property. The Supreme Court affirmed, holding that by violating the use restrictions for private property enrolled in the Block Management Program, Defendant violated section 87-6-415(1). View "State v. McGregor" on Justia Law

After Plaintiff gave birth to a child with cystic fibrosis (CF) Plaintiff filed suit to recover against the medical professionals who provided her with prenatal care and counseling. Plaintiff alleged that she would have opted to abort her pregnancy had she been timely provided with the child’s CF diagnosis while she was pregnant. The jury found that Defendants did not deviate from the standard of care when providing Plaintiff with prenatal care. The Supreme Court affirmed, holding that the district court (1) did not err by admitting collateral source testimony under the rule of curative admissibility; (2) did not abuse its discretion by ruling that certain expert testimony was within the scope of its corresponding disclosure and otherwise admissible; and (3) did not err by refusing to grant a new trial or alter the judgment in response to comments made by defense counsel during closing argument. View "Evans v. Scanson" on Justia Law

The justice court properly denied Defendant’s motion to suppress evidence obtained during the interrogation of Defendant by Montana Fish, Wildlife, and Park (FWP) game wardens at a game check station.Defendant was charged with license, permit or tag offense; unlawful possession, transfer, or transport of game animal; and hunting or killing of a game animal over the legal limit. Defendant moved to suppress evidence gathered at the FWP check station, asserting that his incriminating statements were the fruits of an illegal interrogation. The justice court concluded that Defendant was not required to receive Miranda warnings because he was not subject to custodial interrogation at the check station. Defendant was then found guilty on all three counts. The district court affirmed. The Supreme Court affirmed, holding (1) Defendant was not taken into custody for purposes of Miranda, and therefore, the statements he made to FWP game wardens were admissible against him; and (2) under the totality of the circumstances, Defendant’s admissions and confession were voluntary. View "State v. Maile" on Justia Law

Defendant entered a guilty plea to aggravated driving under the influence, reserving his right to appeal the denial of his motion to suppress. After an evidentiary hearing on appeal, the district court denied Defendant’s motion to suppress. The Supreme Court affirmed, holding that, under the totality of the circumstances, a corroborated tip from an identified citizen informant based, in part, on personal observations of a co-worker was sufficiently reliable to provide the law enforcement officer with particularized suspicion to stop Defendant’s vehicle. Therefore, the district court did not err in denying Defendant’s motion to suppress. View "State v. Zietlow" on Justia Law

This contempt proceeding arose from the failure of Petitioner, the birth father’s counsel in a youth in need of care proceeding, to appear at a termination of parental rights hearing before the Honorable Gregory G. Pinski. After Judge Pinski issued the order of contempt, Petitioner filed a petition for writ of review, arguing that the contempt hearing was criminal in nature and that she was not afforded due process. The Supreme Court denied Petitioner’s petition for a writ of review, holding (1) the district court had jurisdiction of these contempt proceedings pursuant to Mont. Code Ann. 3-1-511; and (2) substantial evidence supported the order of contempt. View "Cross Guns v. Eighth Judicial District Court" on Justia Law

In 2002, Lone Moose Meadows, LLC (LMM) and Boyne USA, Inc. (Boyne) entered into an agreement wherein LMM would construct a ski lift and pay Boyne to operate it. The agreement stated that LMM shall be required to make depreciation payments for operating expenses. In 2008, Boyne filed suit for breach of contract based on LMM’s failure to make depreciation payments. In response, LMM argued that it was not obligated to make depreciation payments until Boyne owned the lift. The district court granted summary judgment in favor of Boyne. LMM appealed but also paid $634,328 to Boyne, satisfying the judgment. While the appeal was pending, LMM filed an action alleging that Boyne had engaged in wrongful collection efforts with respect to the first judgment. Boyne counterclaimed for breach of contract, asserting that LMM now owed depreciation expenses for the 2009-10, 2010-11, and 2011-12 ski seasons. LMM later voluntarily dismissed the wrongful collection claim. The district court granted summary judgment for Boyne on the counterclaim. The Supreme Court affirmed, holding that the district court properly allowed Boyne to pursue successive claims for breach of contract, and LMM’s argument that Boyne’s claims were barred by claim preclusion was unavailing. View "Lone Moose Meadows, LLC v. Boyne USA, Inc." on Justia Law

After Plaintiff’s employment was terminated, he filed suit against Defendant alleging wrongful discharge, negligent infliction of emotional distress, and defamation. The district court granted Defendant’s motion to dismiss for lack of subject-matter jurisdiction, concluding that Ohio law governed or, alternatively, that Ohio was the appropriate forum to exercise jurisdiction. The Supreme Court vacated the district court’s dismissal, holding that Montana courts had subject-matter jurisdiction over Plaintiff’s claim, and remanded for further proceedings to consider whether dismissal under the doctrine of forum non conveniens was appropriate. On remand, the district court denied Plaintiff’s motion to amend the complaint and granted Defendant’s motion to dismiss under forum non conveniens. The Supreme Court affirmed, holding that the district court (1) did not act arbitrarily or exceed the bounds of reason in concluding that Plaintiff’s amendment would prejudice Defendant and that the amendment would run counter to the Supreme Court’s remand instructions in Harrington I; and (2) did not abuse its discretion by determining that resolution of Plaintiff’s claims in Ohio would promote the convenience of witnesses and the ends of justice. View "Harrington v. Energy West Inc." on Justia Law

This dispute involved two water rights claims filed by the City of Helena for the waters of Tenmile Creek, which passes through Rimini. Andy Skinner owned junior water rights on Tenmile Creek. Both Skinner and the Community of Rimini objected to Helena’s water right claims. On remand, the water judge adopted the Water Master’s finding that the City had abandoned 7.35 cubic feet per second (cfs) of its water rights claims but that the City did not intend to abandon the 7.35 cfs. The water court also found that the City abandoned 0.60 cfs in the Rimini Pipeline. The Supreme Court affirmed in part and reversed in part, holding (1) Mont. Code Ann. 85-2-227(4), as applied to the City’s water rights claim, is not impermissibly retroactive; (2) the water court did not err in reinstating 7.35 cfs of Helena’s Tenmile Creek water rights; (3) the water court erred in determining that the City had abandoned 0.60 cfs of its Tenmile Creek water rights; and (4) the water court did not err in imposing specific place of use restrictions on Helena’s decreed Tenmile Creek water rights. View "City of Helena v. Community of Rimini" on Justia Law