Justia Montana Supreme Court Opinion Summaries

J.W. was designated a delinquent youth and serious juvenile offender and placed on probation, subject to several conditions. On June 30, 2014, the Youth Court issued a disposition order revoking J.W.’s probation, committing him to placement within a Montana Department of Corrections (DOC) facility, and requiring him to complete certain phases of the facility’s juvenile SOTP. The State filed a motion to revoke the disposition order and transfer J.W.’s case to the District Court pursuant to Mont. Code Ann. 41-5-208. The Youth Court granted the motion. The Youth Court and District Court imposed house arrest with restrictive conditions on J.W. pending a final disposition of his case. The Supreme Court affirmed, holding (1) the Youth Court did not err in granting the State’s motion to transfer; and (2) the lower courts did not err in imposing house arrest with restrictive conditions on J.W. View "In re J.W." on Justia Law

After the conclusion of a bench trial, Defendant was found guilty of aggravated driving under the influence with a breath alcohol concentration (BAC) of 0.239. Defendant appealed to the district court and filed a motion to suppress the evidence gathered after the vehicle he was driving was stopped by an officer of the Motor Carrier Services Division, Montana Department of Transportation (MDT). The district court denied the motion. The Supreme Court affirmed, holding that the MDT officer acted properly and within the requirements of law in stopping Defendant’s truck, and therefore, the district court properly denied Defendant’s motion to suppress. View "State v. Beaver" on Justia Law

After a jury trial, Defendant was convicted of felony obstructing justice. Defendant appealed, claiming (1) the district court improperly instructed the jury regarding the “knowing” element of obstructing justice, thus violating Defendant’s due process rights; and (2) defense counsel was ineffective for failing to submit a jury instruction defining the statutory term “knowing.” The Supreme Court affirmed, holding (1) the jury was properly instructed on all of the elements of the offense even without an instruction defining “knowing” because the word “knowing,” within the stated elements of the offense, fulfilled a limited purpose that was commonly understood by the jurors; and (2) Defendant failed to establish that he received ineffective assistance of counsel. View "State v. Nuessle" on Justia Law

The Yellowstone County Attorney’s Office filed a petition to involuntarily commit R.H., who suffers from bipolar disorder and general anxiety disorder. After a hearing, the district court found that R.H. suffered from a mental disorder and was unable to care for herself, that Montana State Hospital was the least restrictive treatment option available to R.H., and that administration of medication may be necessary to facilitate treatment for R.H. The Supreme Court affirmed the order for commitment and reversed the administration of involuntary medication, holding (1) there was sufficient evidence to support the commitment of R.H.; but (2) there was insufficient evidence to support the requirement that an involuntary medication order was necessary. View "In re R.H." on Justia Law

S&P Brake Supply, Inc. and STEMCO LP entered into an alleged oral contract for a five-year arrangement to produce and sell remanufactured brakes. S&P later sued STEMCO for breach of contract, among other claims, arguing that STEMCO violated the terms of the parties’ alleged oral contract. STEMCO filed a motion for summary judgment and, when that motion was unsuccessful, a motion for judgment as a matter of law, claiming that the statute of frauds barred the oral contract and that the parol evidence rule precluded evidence of its formation. The district court denied the motions. A jury found for S&P and awarded it damages on the oral agreement. The Supreme Court affirmed, holding that the district court (1) did not err in denying STEMCO’s motion for summary judgment; (2) improperly submitted the question of part performance to the jury but properly submitted S&P’s promissory estoppel claim to the jury; (3) did not prejudicially err in excluding evidence proffered by STEMCO to rebut S&P’s breach of contract and damages claims; and (4) correctly denied costs to STEMCO. View "S & P Brake Supply, Inc. v. Stemco LP" on Justia Law

Less than one year after N.M.V. was born to Erin Verploegen, Dustin Cross and Verploegen began dating. Verploegen and N.M.V. later moved into Cross’s home. Cross and Verploegen broke up several years later, and Verploegen and N.M.V. moved out. Thereafter, Cross petitioned the district court for a parenting interest in N.M.V. The district court denied the petition. The Supreme Court affirmed, holding that the district court’s findings of fact were not clearly erroneous and its ruling on Cross’s parental interest was supported by substantial credible evidence and was not an abuse of discretion. View "In re Parenting of N.M.V." on Justia Law

Two zoning actions were at issue in this proceeding - the “Text Amendment” and the “Map Amendment.” Citizens for a Better Flathead and Sharon DeMeester (collectively, Citizens) initiated this action challenging the Board of County Commissioners of Flathead County’s adoption of both the Text Amendment and the Map Amendment. The district court granted summary judgment in favor of Citizens. The Commissioners appealed. Uncertain over the scope of relief granted by the district court’s order, Citizens cross-appealed from any partial denial of the relief it sought. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err by holding that the Map Amendment was invalid for failing to comply with statutory requirements; (2) the Text Amendment was not invalid for failure to comply with public participation requirements; and (3) the district court erred in awarding attorneys’ fees to Citizens. View "Citizens For A Better Flathead v. Flathead County Commissioners" on Justia Law

After a jury trial, Defendant was convicted of felony assault with a weapon. Defendant appealed, arguing that the district court erred in instructing the jury on the affirmative defense of justifiable force use of force. Specifically, Defendant argued that the instruction was inconsistent and contradictory to another instruction given on the issue of Defendant’s duty to retreat. The Supreme Court affirmed, holding that, based upon all of the evidence Defendant and the State presented at trial, the district court properly instructed the jury on the affirmative defense of justifiable use of force. View "State v. King" on Justia Law

Defendant was charged with partner or family member assault (PFMA) for physically assaulting his girlfriend. Defendant filed a motion to dismiss the PFMA charge, arguing that the statute under which he was charged violated his right to equal protection because it did not apply to persons in same-sex intimate relationships. The justice court denied the motion, concluding that the statute did not violate Defendant’s right to equal protection because it does not treat similarly-situated individuals unequally. The court then found Defendant guilty. The district court affirmed, concluding that the justice court correctly analyzed Defendant’s equal protection claim. The Supreme Court affirmed, holding (1) the former version of the statute under which Defendant was charged violated equal protection; (2) the unconstitutional provision was unnecessary for the integrity of the law, and severing that provision leaves the remainder of the statute complete in itself; and (3) therefore, Defendant was not entitled to dismissal of his PFMA charge. View "State v. Theeler" on Justia Law

Defendant was charged with two counts of theft and two counts of deceptive practices in the City Court of Red Lodge on March 26, 2014. The court ultimately set Defendant’s jury trial for October 31, 2014, nearly one month outside the six-month statutory speedy trial period. Defendant filed a motion to dismiss due to a violation of his statutory speedy trial right. The city court denied the motion, concluding that the speedy trial statute was inapplicable because Defendant had requested a new scheduling order. The court also found good cause. Defendant was subsequently found guilty of one count of deceptive practices. The district court affirmed the city court’s order. The Supreme Court affirmed the city court’s denial of Defendant’s motion to dismiss, holding that because Defendant moved to vacate the scheduling order, which included the trial date, he may not avail himself of the statutory protections afforded by Mont. Code Ann. 46-13-401(2). View "City of Red Lodge v. Pepper" on Justia Law