Justia Montana Supreme Court Opinion Summaries

Seventeen-year-old Defendant was charged with two counts of sexual intercourse without consent. Defendant filed two motions to transfer each charge to Youth Court. The district court denied both transfer motions. Defendant ultimately pleaded guilty to one count of sexual intercourse without consent. Defendant was sentenced to fifty years in prison, with ten years suspended. The Supreme Court (1) affirmed the district court’s refusal to transfer the charges to Youth Court, holding that the district court did not err in denying the transfer motions; and (2) remanded for entry of an amended judgment and review of the sentence as provided by law, holding that the district court erred by not including the requirements found in Mont. Code Ann. 41-5-2503(1) in Defendant’s sentence. View "State v. Talksabout" on Justia Law

The Yellowstone County Attorney filed four petitions for commitment against C.B., a twenty-eight-year-old female with a lengthy history of mental illness. The first three petitions were dismissed. After an evidentiary hearing, the district court granted the fourth petition and commitment to the Montana State Hospital (MSH). The court also authorized the administration of involuntary medication in the event that C.B. refused to take her medications. The Supreme Court affirmed, holding (1) the district court did not err in concluding that the State had satisfied its burden of proof authorizing commitment; (2) the district court did not err by authorizing the administration of involuntary medication when it “may be necessary”; and (3) C.B. received effective assistance of counsel. View "In re C.B." on Justia Law

Pursuant to a plea agreement, Defendant entered a plea of guilty to the charge of criminal distribution of dangerous drugs with intent to distribute. After a sentencing hearing, the district court imposed a six-year deferred sentence, with a $1,500 fine to be paid to the Eastern Montana Drug Task Force, and a $15,000 fine pursuant to Mont. Code Ann. 45-9-130. Defendant appealed, challenging the imposition of the $15,000 fine. The Supreme Court affirmed, holding (1) the $15,000 fine was not a sentence enhancement that violated the requirements of Apprendi v. New Jersey and Mont. Code Ann. 46-1-401; (2) the $15,000 fine did not violate Montana’s constitutional prohibition of “excessive fines”; and (3) Defendant’s double jeopardy argument, which he did not raise below, did not warrant plain error review, and Defendant was not entitled to relief pursuant to the Lenihan Rule. View "State v. Le" on Justia Law

In 2005, Martha Guthrie, Richard Guthrie, and Richard Guthrie, as custodian for Taylor Guthrie (collectively, Guthrie), took out a loan for the purchase of real property. Capital One eventually took over as successor to the mortgage. In 2010, Capital initiated a foreclosure action against Guthrie. Capital moved for summary judgment seeking the right to foreclose on the property. Ultimately, the trial judge granted Capital’s motion for summary judgment, concluding that Guthrie had failed to put any material fact in dispute. The Supreme Court affirmed, holding (1) the retired district court judge had jurisdiction over the proceedings; (2) the district court did not err in granting partial summary judgment to Capital One on the equitable estoppel claim; and (3) the district court properly relied on an affidavit when it granted Capital One’s summary judgment motion. View "Capital One, NA v. Guthrie" on Justia Law

Defendant was convicted of eight counts of sexual intercourse without consent, three counts of felony sexual assault, three counts of sexual abuse of children, and two counts of criminal distribution of dangerous drugs. Defendant was sentenced to a cumulative total of five consecutive life sentences. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by admitting evidence of prior acts under Mont. R. Evid. 404(b) after balancing its prejudicial effect against its probative value; and (2) to the extent the district court erred in applying Mont. Code Ann. 45-5-511(2), Montana’s Rape Shield Law, the error was harmless. View "State v. Daffin" on Justia Law

Michael Estes and Beverly Sue Estes were married in 2002. In 2015, Michael filed for dissolution. The next year, the district court issued its findings of fact, conclusions of law, and decree of dissolution. The decree divided the parties’ marital estate and and denied Michael maintenance. The Supreme Court affirmed, holding that the district court did not abuse its discretion (1) by excluding premarital property from the marital estate; (2) in apportioning the marital estate; (3) when it denied Michael’s request for maintenance; and (4) when it declined to award Michael attorney fees. View "In re Marriage of Estes" on Justia Law

The Missoula County Attorney’s Office petitioned for a determination that K.P. suffered from a mental disorder requiring involuntary commitment. After a commitment hearing, the district court involuntarily committed K.P. to the Montana State Hospital (MSH) in Warm Springs. K.P. appealed, arguing that the district court’s oral order of involuntary commitment violated Mont. Code Ann. 53-21-127(8) and due process because it failed to include the required factual findings. The Supreme Court reversed and vacated the district court’s commitment order, holding that the district court’s order did not satisfy section 53-21-127(8) because there were no findings of facts to support the general conclusions. View "In re K.P." on Justia Law

After securing two loans with deeds of trust on the same property, Appellants paid off the smaller loan. A title agent filed a deed of reconveyance containing a scrivener’s error that mistakenly released Appellants’ interest in their property from the larger lien. Although the error was later corrected, Appellants argued that U.S. Bank, the beneficiary to the larger loan, did not have a valid, perfected lien prior to commencement of Appellants’ Chapter 7 bankruptcy proceedings. The district court granted U.S. Bank’s motion for judgment on the pleadings. The Supreme Court affirmed, holding that the lien at issue survived Appellants’ bankruptcy proceedings because the lien was unaffected by the scrivener’s error contained within the deed of reconveyance. View "Reeves v. US Bank National Ass’n" on Justia Law

The State filed a petition seeking the commitment of C.K. to the Montana State Hospital (MSH) for involuntary mental health treatment pursuant to Mont. Code Ann. 35-21-127. At the commitment hearing, the examining mental health professional, Kim Waples, testified about C.K.’s behavior based on her initial evaluation report and a therapeutic group home’s counseling and staff records. At the close of the hearing, the district court granted the State’s petition and committed C.K. to the MSH for ninety days. C.K. appealed, arguing that the district court erred in admitting and considering inadmissible hearsay referenced in Waples’ hearing testimony. The Supreme Court affirmed, holding (1) otherwise inadmissible hearsay may be admissible through an expert under Mont. R. Evid. 703 upon proper foundation and for the limited purpose of explaining the basis of the expert’s opinion rather than proving the facts asserted in the statement; and (2) the district court in this case did not abuse its discretion in admitting and considering the otherwise inadmissible hearsay referenced in Waples’ testimony for the purpose of explaining her opinions and recommendations. View "In re C.K." on Justia Law

Donnie Dorrell Nolan was incarcerated at the Yellowstone County Detention Facility at the time that RiverStone Health Care contracted with Yellowstone County to prove medical services for its inmates. Nolan filed a pro se complaint against RiverStone alleging that it violated the Eighth and Fourteenth Amendments by denying him access to a prescribed pain medication while incarcerated. The district court dismissed Nolan’s complaint for lack of timely service of process. The Supreme Court affirmed, holding that the district court correctly dismissed Nolan’s complaint due to his failure to comply with the mandatory rules for proper service of process on RiverStone. View "Nolan v. Riverstone Health Care" on Justia Law