Justia Montana Supreme Court Opinion Summaries

Defendant pleaded guilty to felony possession of dangerous drugs with intent to distribute, felony possession of dangerous drugs, and misdemeanor possession of dangerous drugs. The district court sentenced Defendant to 100 years in prison. Defendant appealed, arguing that the district court violated his right to due process by impermissibly considering an unproved allegation of rape in making its sentencing decision. The Supreme Court affirmed, holding that the jailhouse rape allegation did not form the basis for Defendant’s sentence, and therefore, Defendant failed to meet his burden of showing that the court premised its sentencing decision on “materially inaccurate or prejudicial” information. View "State v. Sherman" on Justia Law

After a jury trial, Defendant was convicted of deliberate homicide under the felony murder rule. Defendant was sentenced to life without parole. The district court also sentenced Defendant to pay costs of defense, prosecution, and jury selection. The Supreme Court affirmed the conviction but reversed the sentence to pay costs, holding (1) the district court did not abuse its discretion in admitting evidence of Defendant’s prior acts under Mont. R. Evid. 404(b) and 403; but (2) the district court erred in sentencing Defendant to pay costs of assigned defense, prosecution, and jury selection based on purely speculative information about his ability to pay. View "State v. Madplume" on Justia Law

Defendant was charged with deliberate homicide in the death of her infant daughter. Defendant moved to suppress the results of a police interrogation, asserting that her admissions that she had shaken her daughter were not voluntary. The district court denied the motion to suppress. A jury found Defendant not guilty of deliberate homicide but guilty of felony assault on a minor. The Supreme Court reversed, holding (1) based upon the totality of the circumstances, the district court erred by concluding that the interrogation was not unduly coercive or manipulative and by concluding that Defendant was “fully cognizant” of her situation; and (2) therefore, the State failed to meet its burden of proving that Defendant’s admissions were voluntary, and the district court erred in denying the motion to suppress. View "State v. Eskew" on Justia Law

After the loan secured by Susan Alexander’s property went into default, Bank of America, N.A. (BANA) initiated foreclosure proceedings. The property was sold to BANA after a trustee’s sale. When Alexander refused BANA’s demand to vacate the property BANA filed a complaint for unlawful detainer against Alexander. Alexander asserted counterclaims for breach of contract, breach of an oral agreement, and frivolous litigation. The district court granted summary judgment in favor of BANA, concluding that the foreclosure sale was valid and that Alexander was unlawfully holding possession of the property. The court also concluded that Alexander’s counterclaims were either barred by the statute of limitations or statute of frauds and that there was a lack of supporting evidence for her claims. The Supreme Court affirmed, holding (1) BANA was entitled to summary judgment and a writ of assistance based on unlawful detainer; (2) Alexander failed to state a claim of fraud; (3) Alexander’s claims of breach of written or oral contract and breach of oral agreement were barred by the statute of limitations and statute of frauds; and (4) Alexander did not properly allege or offer supporting evidence for her claim of unjust enrichment. View "Bank of America, N.A. v. Alexander" on Justia Law

On February 13, 2009, Defendant was charged with motor vehicle offenses. On May 21, 2009, the justice court issued a warrant for Defendant’s arrest for failing to appear. On April 13, 2012, Defendant was arrested on the warrant. Defendant pled not guilty, and trial was set for August 23, 2012. Defendant moved to dismiss the charges against him for lack of a speedy trial. The justice court concluded that while there was a lengthy delay of 1288 days between the initial charges and the trial date, Defendant’s constitutional right to a speedy trial had not been violated. Defendant then pled guilty to driving with a suspended license. The district court upheld the justice court’s determination that Defendant was not denied his right to a speedy trial. The Supreme Court affirmed, holding that, under the facts of this case, Defendant was not denied his right to a speedy trial. View "State v. Eystad" on Justia Law

After Robert Fitte burned tree branches on his property, a fire rose from the ashes of the burn and erupted into a wildfire known as the Corral Fire. At the time of the fire, Fitte carried two insurance policies issued by Mountain West Farm Bureau Mutual Insurance Company, including the commercial automobile policy at issue in this appeal. Fitte stipulated to entry of a judgment in favor of Associated Dermatology and Skin Cancer Clinic of Helena, P.C. Profit Sharing Plan and Trust for the benefit of Stephen D. Behlmer, M.D. (Behlmer). Fitte and Behlmer subsequently entered into an agreement wherein Fitte assigned his rights in the Mountain West policies to Behlmer. Behlmer then filed this action seeking a declaration that the automobile policy provided coverage for the Corral Fire damages. The district court ruled in favor of Behlmer and directed that the insurance proceeds be deposited into the district court. The Supreme Court reversed, holding that the district court erred in holding that there was coverage for the Corral Fire damage under Mountain West’s commercial automobile policy. View "Associated Dermatology & Skin Cancer Clinic of Helena, P.C. Profit Sharing Plan & Trust for the Benefit of Stephen D. Behlmer v. Mountain West Farm Bureau Mutual Insurance Co." on Justia Law

On August 3, 2013, Defendant was charged with criminal endangerment, driving under the influence of alcohol or drugs, and other offenses. On March 12, 2015, Defendant filed a motion to dismiss the charges for lack of a speedy trial. The trial court denied the motion. On April 20, 2015, Defendant’s trial commenced. The Supreme Court affirmed, holding that the district court correctly denied Defendant’s motion to dismiss for lack of a speedy trial where (1) while the State bore some responsibility for the days of delay beyond the 200-delay threshold, the primary responsibility for this delay lay with Defendant; and (2) the overall balancing clearly weighed against Defendant’s claim. View "State v. Stewart" on Justia Law

Charlene Berdahl, a court reporter, filed a sexual harassment complaint against Judge George Huss, a district judge, with the Montana Human Rights Bureau (HRB). Huss’s attorney requested that the State agree to defend and indemnify Huss regarding Berdahl's HRB claims. Berdahl and Huss subsequently entered into a stipulated judgment resulting from the State’s refusal to defend and indemnify. The State filed this action seeking declarations that the State had no duty to defend or indemnify Huss against the claims and that Huss had entered a settlement without the consent of the State, which was unenforceable against the State. Berdahl counterclaimed seeking declarations that the State was responsible for the stipulated judgment entered by Berdahl and Huss and that the State was liable under the principle of respondent superior. The district court rejected Berdahl’s request for a declaration and held that the State owed no duty to defend or indemnify Huss. The court further reasoned that Berdahl’s exclusive remedy regarding her respondent superior claim was under the Montana Human Rights Act. The Supreme Court affirmed, holding that the district court did not err in concluding that the State bore no obligation to pay the stipulated settlement between Huss and Berdahl. View "State v. Berdahl" on Justia Law

After a jury trial, Defendant was convicted of deliberate homicide. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by instructing the jury on justifiable use of force in defense of a person; (2) did not abuse its discretion when it denied Defendant’s motions to change venue based on pretrial publicity; (3) did not abuse its discretion when it declined to remove a prospective juror for cause based on her marriage to a former police officer; (4) did not abuse its discretion when it admitted rebuttal evidence of Defendant’s bad character to rebut evidence of Defendant’s good character; and (5) abused its discretion when it allowed lay opinion testimony regarding blood spatter evidence, but the error was harmless. View "State v. Kaarma" on Justia Law

After a jury trial, Defendant was convicted of securities fraud. Defendant appealed, arguing that he was denied his right to a speedy trial guaranteed by the Montana Constitution and that the district court erred when it refused his proposed jury instructions, which included language regarding exemptions to the statutes under which he was charged. The Supreme Court affirmed, holding that the district court (1) did not err in denying Defendant’s motion to dismiss for lack of a speedy trial; and (2) did not err in denying Defendant a new trial on the basis that the jury was not properly instructed. View "State v. Reynolds" on Justia Law