Justia Montana Supreme Court Opinion Summaries

Appellants, three individuals, alleged that Appellees, a newspaper and its editor, published defamatory statements about the group concerning an incident at a rest area near Conrad, Montana. The district court ruled that the statements did not constitute defamatory libel and granted summary judgment in favor of Appellees. The Supreme Court affirmed the grant of summary judgment as to Appellees, holding that, under the three-part analysis to determine whether the publication was defamatory, Appellees’ defamatory libel allegations failed because the public was not false within the meaning of court precedent regarding libel. View "Lee v. Traxler" on Justia Law

Cory Patterson and Jesse Alma King each pleaded guilty to two counts of burglary. As part of his sentence, Patterson was ordered to pay, jointly and severally with King, $28,592 in restitution. Patterson challenged the restitution ordered for one of the victim’s lost wages, damages to firearms that were stolen, mileage expenses, and copying costs. The Supreme Court affirmed, holding that the district court did not err in granting the victim’s restitution requests for lost wages, mileage, copying costs, and personal property damage, and the claims were supported by sufficient evidence. View "State v. Patterson" on Justia Law

Robert Crawford was pulled over by Flathead Tribal Police Officer Casey Couture on the Flathead Reservation. Crawford was allowed to leave but was then informed that he was in violation of his parole because he did not have permission to be traveling in that area. Crawford was arrested upon a warrant issued for parole violations and then charged with criminal possession of dangerous drugs. A jury found him guilty. Thereafter, Crawford filed this action in state court against Couture, the Flathead Tribal Police Department, and the Confederated Salish Kootenai Tribal Government alleging numerous claims due to inappropriate conduct by Couture. The district court dismissed Crawford’s claims based on lack of subject matter jurisdiction and the sovereign immunity of the Tribe. The Supreme Court affirmed, holding that the district court properly dismissed Crawford’s claims based on lack of subject matter jurisdiction and sovereign immunity. View "Crawford v. Couture" on Justia Law

At dispute in this case was the existence and use of an easement along Turk Road, a private road that ran through multiple properties. All parties in this case owned property accessed via Turk Road, which passed through portions of Defendants’ properties. This appeal concerned the right of Marc and Gloria Flora (Plaintiffs) to use Turk Road over two properties owned by four defendants (Defendants). Plaintiffs sought a declaratory judgment that they had legal access along Turk Road as it passed through Defendants’ properties pursuant to an express easement. The Floras then moved for a preliminary injunction to enjoin Defendants from interfering with the Floras’ access along Turk Road. The district court granted the Floras a preliminary injunction because the Floras laid out a prima facie case for a prescriptive easement. The court then limited the easement to light-duty passenger vehicles. The Floras appealed. The Supreme Court affirmed, holding that the district court did not err by (1) granting the Floras’ motion for a preliminary injunction on the basis of a prescriptive easement theory rather than on an express public easement theory; and (2) limiting the Floras’ prescriptive easement to the use of passenger vehicles. View "Flora v. Clearman" on Justia Law

In 2014, the State charged Defendant with felony driving under the influence (DUI). The probable cause affidavit alleged that Defendant had three prior DUI convictions, one from North Dakota in 1988. Defendant filed a motion arguing that the 1988 conviction was not a qualifying conviction because it was impossible to determine whether the conviction was a “blood alcohol concentration” conviction or an “under the influence” conviction because the same North Dakota statute governed both offenses. The district court denied Defendant’s motion, concluding that it was Defendant’s burden to prove the nature of the 1988 conviction. The court then ruled that the conviction could be used to support the felony charge. Defendant pleaded guilty to the felony, reserving his right to appeal the denial of his motion. The Supreme Court reversed, holding that the State bore the burden of proving that the 1988 conviction could be used to support its felony charge against Defendant and that the State failed to meet this burden. Remanded. View "State v. Krebs" on Justia Law

This case related to circumstances surrounding a data entry error that resulted in a significant sum of money being deposited into the wrong bank account. Grizzly Security Armored Express (Grizzly Security) filed suit against Bancard Services (Bancard) and B&B Lounge and Leland Ruzicka (collectively, Ruzicka). The district court concluded that the claim against Ruzicka was time-barred under the pertinent statute of limitations and that the claims against Bancard failed for various reasons. The court further awarded attorney’s fees to Bancard. The Supreme Court affirmed, holding that the district court (1) did not err in granting summary judgment in favor of Ruzicka; (2) did not err in granting summary judgment in favor of Bancard; and (3) did not err in awarding attorney’s fees to Bancard under the terms of a contract between the parties. View "Grizzly Security Armored Express, Inc. v. Bancard Services, Inc." on Justia Law

After she was demoted from her position with the Montana Department of Transportation, Sheila Cozzie filed a grievance. Following a contested case proceeding, the hearing examiner recommended that Cozzie’s grievance be denied. Cozzie appealed to the full Board of Personnel Appeals (BOPA). The BOPA voted to grant Cozzie’s grievance and issued a final decision reinstating Cozzie. On appeal, the district court ruled that BOPA acted outside the scope of review, concluding that the BOPA improperly struck findings of fact and incorrectly modified conclusions of law. The Supreme Court affirmed, holding that the district court (1) did not err by affirming the evidentiary ruling made by the hearing examiner; and (2) did not err by reversing the BOPA’s just cause decision. View "Department of Transportation v. Department of Labor" on Justia Law

Peter Lee and three other passengers were injured in a single vehicle accident. The driver held an insurance policy issued by USAA Casualty Insurance Company and United States Automobile Association (collectively, USAA), and all of the passengers were covered by TRICARE. TRICARE paid medical benefits for the passengers and asserted medical payment liens for the passengers’ combined medical expenses. Lee made a settlement demand on USAA for Perez’s $100,000 policy limits. USAA offered to pay the policy limits provided that Lee first secure lien releases from TRICARE. TRICARE eventually waived its liens, and USAA issued a check for the policy limits of $100,000. Lee continued his suit against Perez after receiving the policy limits payment from USAA. Perez agreed to a consent judgment and assigned his claims against USAA to Lee. Elizabeth West, acting as guardian ad litem for Lee, filed suit asserting that USAA acted in bad faith by conditioning payment on resolving the TRICARE liens. The district court granted summary judgment for West, holding USAA liable to Lee for the consent judgment. The Supreme Court reversed, holding that USAA’s grounds for conditioning its payment of policy limits upon resolution of the TRICARE liens were reasonable under existing law, and therefore, USAA was entitled to judgment as a matter of law. View "West v. United Services Automobile Ass’n" on Justia Law

The Montana Department of Revenue (DOR) informed Alpine Aviation, Inc. that it would be centrally assessed pursuant to Mont. Code Ann. 15-23-101 and 15-6-145. The DOR denied Alpine’s request for reclassification. After Alpine appealed to the State Tax Appeal Board, DOR brought an interlocutory appeal to the district court seeking an adjudication of the meaning of “scheduled airline” and “scheduled air commerce” for property tax purposes. Those terms are further informed by the statutory phrase “regularly scheduled flights.” After the district court interpreted the phrases as requested, Alpine appealed, arguing that the court incorrectly interpreted the phrase “regularly scheduled flights.” The Supreme Court affirmed in part and reversed in part, holding that the district court’s definition of “regularly scheduled flight” was satisfactory with the exception of its use of the phrase “patterned but not necessarily uniform.” View "Department of Revenue v. Alpine Aviation, Inc" on Justia Law

Defendant was convicted of criminal possession of dangerous drugs after police officer discovered Oxycodone residue on a spoon in Defendant’s possession. During trial, the court instructed the jury that Defendant could assert as a defense that he had obtained the Oxycodone pursuant to a valid prescription. When, during deliberations, the jury asked the court whether crushing prescription Oxycodone violated the law, the court responded that the jury was to rely “on the instructions previously given.” Defendant appealed, contending that the court abused its discretion in refusing to further instruct the jury on the legality of crushing prescription Oxycodone. The Supreme Court affirmed, holding that the district court did not abuse its discretion in deciding to refer the jury back to its original instructions. View "State v. Temple" on Justia Law