Justia Montana Supreme Court Opinion Summaries

Defendant was charged with criminal possession of dangerous drugs with intent to distribute and criminal possession of dangerous drugs/opiates. Defendant moved to suppress the evidence found in his vehicle during a search pursuant to a search warrant, arguing that the police lacked particularized suspicion to initiate a traffic stop. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the district court did not err in determining that the stop of Defendant was supported by a particularized suspicion that Defendant’s tail light covers violated Mont. Code Ann. 61-9-204(5). View "State v. Massey" on Justia Law

The district court terminated Mother’s parental rights to one of her three children after holding a final parental rights termination hearing. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it terminated Mother’s parental rights, as the record clearly showed that the Department of Health and Human Services engaged in reasonable efforts to reunite the family pursuant to Mont. Code Ann. 41-3-423(1), and the decision to terminate Mother’s parental rights was supported by substantial evidence; and (2) Mother’s due process right was not infringed when she was without counsel. View "In re M.V.R." on Justia Law

Defendant was charged with driving under the influence (DUI) in violation of Mont. Code Ann. 61-8-401. Defendant filed a motion to suppress the results of a blood test taken at Marcus Daly Memorial Hospital, conceding that he verbally consented to the blood test but arguing that he withdrew his consent by not signing a patient consent form at the hospital. The Supreme Court affirmed the district court’s order denying Defendant’s motion to suppress the results of his blood test, holding that the district court did not err by rejecting Defendant’s argument and in finding that the patient consent form has no bearing on consent under Montana’s DUI law. View "State v. Shepp" on Justia Law

Defendant was arrested and charged with felony criminal possession. The district court granted the State’s motion for a continuance and reset Defendant’s trial for a day 285 days after his arrest. Defendant filed a motion to dismiss for speedy trial violations. The district court denied the motion. Defendant pleaded guilty but reserved the right to appeal the denial of his speedy trial motion. The Supreme Court reversed, holding that Defendant was denied his right to a speedy trial, considering the State’s reason for the delay, the simplicity and nature of the charges, and the prejudice to Defendant by his inability to participate in drug rehabilitation programs and community placement because of his unduly lengthy incarceration in county jail, in conjunction with Defendant’s need for treatment. Remanded for dismissal of the charges. View "State v. Mayes" on Justia Law

The Dawson County Attorney petitioned for the involuntary commitment of C.V. alleging that, due to her mental disorder, she was unable to provide for her own basic needs of safety and there was an imminent threat of injury to herself or others. The district court ultimately granted the State’s petition for involuntary commitment, concluding that C.V. suffered from a delusional disorder and that there was an imminent threat of injury to herself or others from her acts or omissions. The Supreme Court (1) affirmed the district court’s decision that there was sufficient evidence to commit C.V. to the Montana State Hospital; but (2) reversed and remanded to the district court to strike the condition that C.V. shall be immediately taken back to the Montana State Hospital to continue treatment if she does not comply with discharge recommendations after the ninety-day commitment. View "In re C.V." on Justia Law

After a jury trial, Defendant was convicted of sexual intercourse without consent and sexual assault. Defendant appealed, arguing that the district court erred in denying his motion for discovery sanctions, specifically the denial of a continuance, and Defendant’s motion for mistrial. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it denied Defendant’s request for a sanction, in the form of a continuance; and (2) the district court did not abuse its discretion when it denied Defendant’s motion for mistrial on grounds that the State made improper comments or suggestions during opening statements. View "State v. Pierce" on Justia Law

J & C Moodie Properties, LLC hired Haynie Construction, owned by Kyle Haynie, as general constructor to construct a building for Moodie’s farm equipment dealership. Scottsdale insured Haynie under a policy that was in effect when the building project was completed. Moodie later sued Haynie, asserting construction defect claims regarding the construction project. Scottsdale denied coverage. Haynie and Moodie subsequently filed a stipulated settlement, under which Haynie assigned its rights and interest in the Scottsdale policy to Moodie. The district court then entered judgment in the case against Haynie. Thereafter, Moodie filed a fourth amended complaint requesting a declaratory judgment against Scottsdale, claiming that Scottsdale had breached its duty to defend, Haynie had entered a stipulated judgment due to Scottsdale’s failure to defend, the stipulated judgment was reasonable, and Scottsdale was liable for the stipulated judgment. The district court ruled in favor of Moodie on all issues. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court (1) correctly found that Scottsdale breached its duty to defend Haynie; (2) erred by ruling that there were no grounds for a reasonableness hearing regarding the stipulated judgment; and (3) erred by ruling that Scottsdale was not entitled to discovery regarding the reasonableness determination. View "J & C Moodie Properties, LLC v. Deck" on Justia Law

In 2012, the district court entered a decree dissolving the marriage of John and Emily Brown. The decree incorporated by reference a separation agreement that provided a parenting plan and child support for the parties’ daughter. The parenting plan designated Emily as the primary parent. In 2014, John filed a motion to modify his child support obligation, claiming that his income and financial circumstances had changed significantly. The next year, John filed a motion to amend the parenting plan seeking increased visitation. The district court denied John’s motions without holding a hearing, concluding that John had not shown a substantial change in circumstances or provided a basis for modifying his child support obligations. The Supreme Court affirmed, holding (1) the district court did not err in denying John’s motions to modify child support and amend the parenting plan without a hearing; and (2) Emily was not entitled to attorney’s fees associated with the appeal. View "In re Marriage of Brown" on Justia Law

Plaintiffs were both insured by USAA Casualty Insurance Company under auto insurance policies that provided medical payments coverage. Plaintiffs filed a complaint against USAA arguing that USAA’s practice of sending medical claims to Auto Injury Solutions (AIS) for review was an improper cost containment scheme designed to deprive Montana consumers of their first-party medical pay benefits. Plaintiffs subsequently filed a motion to certify a proposed class. The district court issued its order certifying the class, concluding “all members of the proposed class were subject to the same claims processing procedure of outsourcing claims to AIS. USAA appealed from the certification order. The Supreme Court reversed, holding that the district court abused its discretion by certifying the class under Mont. R. Civ. P. 23(a) and under Mont. R. Civ. P. 23(b)(3). Remanded. View "Byorth v. USAA Casualty Insurance Co." on Justia Law

Defendant was convicted of disorderly conduct in the Bozeman Municipal Court. Defendant was sentenced to pay a $100 fine and $135 in surcharges and fees. Defendant appealed his sentence to the district court, asserting eight grounds for appeal. The district court declined appellate jurisdiction and remanded the matter to the municipal court for enforcement of Defendant’s sentence, determining that Defendant’s $100 fine did not satisfy the threshold amounts for appellate jurisdiction set forth in the applicable rules or statutes and that it was unlikely that Defendant would prevail on any of the issues raised. The Supreme Court affirmed, holding that the district court’s denial of Defendant’s motion to appeal did not constitute an abuse of discretion or error. View "City of Bozeman v. King" on Justia Law