Justia Montana Supreme Court Opinion Summaries

Jessica Huckins filed a complaint against Barry Van Sickle and his real estate agent alleging several causes of action related to Van Sickle’s failure to disclose previous basement flooding problems in the sale of his home. At all relevant times, Van Sickle held three insurance policies through United Services Automobile Association (USAA). USAA denied coverage for the claims stated in the underlying complaint. Van Sickle settled the underlying litigation with Huckins by way of a consent judgment and Van Sickle’s assignment of all claims under his insurance policies to Huckins in exchange for a covenant not to execute. Huckins then brought this case against USAA, alleging, inter alia, breach of duty to defend Van Sickle. The district court concluded that USAA had not breached its duty to defend under any of the policies because the claim did not constitute an “occurrence” as defined by the policies. The Supreme Court reversed, holding (1) USAA had a duty to defend Van Sickle, at least until a ruling was obtained declaring there was no coverage; and (2) by failing to defend Van Sickle, USAA breached its duty to defend. View "Huckins v. United Services Automobile Ass’n" on Justia Law

While employed by a company now known as Asurion Services, LLC, Christy Harris filed industrial injury claims for two different incidents. Lumbermens Mutual Casualty Company adjusted Harris’s workers’ compensation claims until it was declared insolvent. Montana Insurance Guaranty Association (MIGA) subsequently assumed the handling of Harris’s claims. Thereafter, MIGA notified Asurion that it would seek reimbursement for the benefits it paid to Harris pursuant to Mont. Code Ann. 33-10-114(2). Asurion filed a declaratory judgment action against MIGA. The district court granted motion for Asurion based on the exclusivity provision of the Montana Workers’ Compensation Act (Act), concluding that because Asurion met its obligation to obtain workers’ compensation insurance, it had no payment obligations to Harris, and therefore, Mont. Code Ann. 33-10-114(2) did not afford MIGA relief. The Supreme Court affirmed, holding that because Asurion provided workers’ compensation coverage in accordance with the Act, Asurion was not required to reimburse MIGA for benefits paid to Harris. View "Asurion Services, LLC v. Montana Insurance Guaranty Ass’n" on Justia Law

Landowners appealed from an order of the district court granting summary judgment to the City of Lewistown and allowing the City to annex portion of the Landowners’ properties. The Supreme Court affirmed, holding that the district court did not err in (1) concluding that the City followed the statutory annexation requirements of Title 7, chapter 2, part 43, Mont. Code Ann.; (2) concluding that the City had correctly determined that there were less than a majority of valid protests; (3) concluding that the Landowners were not denied equal protection of the law by the City’s decision of what properties to annex; and (4) concluding that the Landowners lacked standing to enforce a contract between the City and a subdivision developer. View "St. John v. Lewistown" on Justia Law

Defendant appealed his conviction for deliberate homicide. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in instructing the jury on Defendant’s justifiable use of force defense without including a “forcible felony” component; (2) Defendant’s claims that the prosecutor’s comments regarding Defendant’s failure to tell police his self-defense story constituted plain error did not warrant plain error review because Defendant had not demonstrated that the State violated his fundamental rights; and (3) the prosecutor’s misstatement of the legal elements for justified use of lethal force did not constitute plain error. View "State v. Lackman" on Justia Law

Roger and Carrie Peters and Draggin’ Y Cattle Company (collectively, Peters) entered into a stipulated settlement with Junkermier, Clark, Campanella, Stevens, P.C. and Larry Addink (collectively, Junkermier). Judge George Huss, the presiding judge, determined that the stipulated settlement was reasonable and entered judgment against New York Marine and General Insurance Company, Junkermier’s insurer. On appeal, the Supreme Court held that Judge Huss improperly failed to disclose a potential conflict of interest. On remand, the district court determined that Judge Huss was required to recuse himself and should have been disqualified and vacated Judge Huss’s orders issued after he should have been disqualified. The Supreme Court affirmed, holding that the district court (1) correctly held that Judge Huss was required to disqualify himself pursuant to Montana Code of Judicial Conduct Rule 2.12(A); and (2) did not err in vacating Judge Huss’s orders issued after he should have disqualified himself. View "Draggin Cattle Co. v. New York Marine & General Insurance Co." on Justia Law

After the Montana Department of Justice informed employees of the Deer Lodge office of the Department’s Title and Registration Bureau (TRB) that the office would be formally closed, Plaintiffs filed suit, alleging violations of the public’s rights to know and participate. Plaintiffs ultimately sought an order setting aside the Department’s decision to close the TRB office. The district court entered judgment in favor of the Department. Plaintiffs appealed but did not move to stay the district court’s judgment, and the Department relocated the TRB functions to its Helena offices. The Supreme Court dismissed the appeal, holding that Plaintiffs’ claims were moot because the circumstances of this case precluded effective relief that would meaningfully remedy the department’s alleged disregard of the public notice and participation requirements of Title 2, chapter 3, Mont. Code Ann. View "City of Deer Lodge v. Fox" on Justia Law

The district court affirmed Defendant’s conviction of aggravated DUI, agreeing with the justice court that evidence of Defendant’s prior DUI convictions proved an element of the charged crime of aggravated DUI that must be determined by the jury. On appeal, Defendant argued that it was impermissibly prejudicial to his interests to allow the jury to know that he was twice convicted of DUI. The Supreme Court affirmed, holding that because proof of the prior DUIs was required as an element of the offense of aggravated DUI, the evidence of prior DUIs was not erroneously admitted. View "State v. Meyer" on Justia Law

The Montana Public Service Commission, which requires that certain regulated telecommunications companies publicly disclose the salary information of their executive or managerial employees earning more than $100,000 per year, denied the motions for protective orders filed by Southern Montana Telephone Company and Lincoln Telephone Company to keep the salary information confidential. The district court affirmed. The Supreme Court reversed, holding that the Commission’s “rubric,” by which the Commission judged companies’ motions for protective orders of employee compensation information, constituted a de facto rule within the meaning of the Montana Administrative Procedure Act (MAPA) and that the Commission was obligated to comply with MAPA’s rulemaking procedures before implementing the rubric. View "Southern Montana Lincoln Telephone Co. v. Montana Public Service Commission" on Justia Law

The district court did not err in ruling that Defendant’s federal conviction for conspiracy to distribute methamphetamine did not bar a subsequent state prosecution for possession of dangerous drugs on double jeopardy grounds.Defendant pled guilty to a charge of conspiracy to distribute in federal court. Thereafter, Defendant moved to dismiss the State’s drug-related charges, arguing that the State prosecution violated Montana’s double jeopardy prohibition. The district court denied the motion to dismiss. Thereafter, Defendant entered an Alford plea to one count of felony criminal possession of dangerous drugs, reserving the right to appeal the denial of his motion to dismiss. The Supreme Court affirmed, holding that Defendant’s possession of methamphetamine for his personal use was a distinct and separate prosecutable offense pursuant to Mont. Code Ann. 45-9-102(1). View "State v. Glass" on Justia Law

Richland Aviation filed this proceeding to determine whether it was a “scheduled airline” and therefore subject to central tax assessment by the Montana Department of Revenue (DOR). The district court concluded that Richland Aviation was not a scheduled airline because it “does not hold out to the public that it operates between certain places at certain times[.]” Therefore, the district court concluded that Richland Aviation was not subject to central assessment. Applying the definitions found in Montana Department of Revenue v. Alpine Aviation, Inc., 384 P.3d 1035, the Supreme Court affirmed, holding that Richland Aviation does not engage in “regularly scheduled flights” required for central assessment. View "Richland Aviation, Inc. v. State, Department of Revenue" on Justia Law