Justia Montana Supreme Court Opinion Summaries

This case arose from Appellant’s objection to three water right claims owned by Granite County. Appellant objected to the County’s water right claims in proceedings before the Water Court, arguing that the 1906 decree in the case of Montana Water, Electric and Mining Co. v. Schuh required the County to release storage water to benefit downstream users. The Water Court rejected Appellant’s argument and granted summary judgment to Granite County. The Supreme Court affirmed, holding (1) the Water Court did not err in its interpretation of the Schuh decree; and (2) the Water Court properly considered and applied the principles of claim preclusion relied upon by Appellant to limit Granite County’s arguments concerning application of the Schuh decree. View "Granite County Commissioners v. McDonald" on Justia Law

This in rem forfeiture proceeding brought under Mont. Code Ann. 44-12-201 (2013), et seq. arose from Mike Chilinski’s alleged use of real property to manufacture dangerous drugs. The proceeding was unconnected to a state drug prosecution. The statute mandated that the proceeding be heard only before a judge, precluding the use of a jury. At the forfeiture proceeding, Chilinski argued that the forfeiture statute violated his right to a jury trial. The district court conducted the hearing without a jury, reasoning that the proceeding was an equitable action and thus outside the scope of the right to a jury trial. The district court then forfeited Chilinski’s property to the State. Chilinski appealed the district court’s denial of his right to a jury trial. The Supreme Court reversed, holding (1) Mont. Code Ann. 44-12-203(3) (2013) violates Mont. Const. art II, 26 by depriving individuals of the right to a trial by jury; and (2) therefore, the district court erred when it denied Chilinski the right to a jury trial in these civil in rem forfeiture proceedings. View "State v. Items of Property" on Justia Law

Defendant was convicted of five felony charges stemming from his illegal baiting, killing, and transportation or assistance in illegal baiting, killing, and transportation of nine black bears. The district court imposed a ten-year suspended prison sentence and twenty-six conditions. Thereafter, the State filed a motion to conform the district court’s written judgment to its oral pronouncement of Defendant’s sentence. The district court denied the motion. The Supreme Court affirmed in part and reversed in part, holding (1) the district court incorrectly applied the law when it denied the State’s petition to conform its written judgment to its oral pronouncement by striking the provision in Condition 23 that allows Defendant to petition for early termination of his lifetime hunting, fishing, and trapping prohibition; and (2) the district court correctly determined that Defendant may petition for early termination of his lifetime prohibition on accompanying any hunter, angler, or trapper. View "State v. Harrison" on Justia Law

After a jury trial, Defendant was convicted of reckless driving and failing to yield to an emergency vehicle. Defendant appealed, arguing that the victim’s in-court identification was impermissibly suggestive and unreliable and that a police officer’s testimony regarding vehicle registration information received from dispatch was inadmissible hearsay. The district court denied the appeal. The Supreme Court affirmed, holding that the trial court (1) did not err in allowing the victim’s in-court identification of Defendant at trial; and (2) did not abuse its discretion in admitting testimony concerning vehicle registration information received from police dispatch. View "City of Billings v. Nolan" on Justia Law

The underlying claim in this case, which had been appealed on three previous occasions, concerned an exclusion in the State’s health benefit insurance plan, which allowed the State to coordinate benefits in violation of Montana’s made whole laws. Jeanette Diaz, Leah Hoffman-Bernhardt, and others similarly situated (collectively, Diaz) filed suit alleging that third-party administrators and the State (collectively, Defendants) had violated employees’ made whole rights under Montana law. During the various appeals, the Supreme Court concluded that the district court certified and defined a class and that the district court correctly denied the State’s motion for summary judgment. In this, the fourth appeal, Diaz appealed a district court order determining the manner in which prejudgment interest on payments due to class members was to be calculated. The Supreme Court affirmed the district court’s order declaring interest to begin thirty days following the Court’s decision in Blue Cross & Blue Shield of Montana v. Montana State Auditor. Remanded for the district court to correct the date to be applied for determining the calculation of prejudgment interest. View "Diaz v. State" on Justia Law

In a period of approximately three years, Masonry by Muller, Inc. (Masonry) and Flathead Bank entered into four promissory notes. William Muller signed the promissory notes individually and as president of Masonry and personally guaranteed three of the loans. Flathead Bank later filed a complaint alleging that Muller and Masonry had defaulted on all four loans and that it was entitled to the outstanding balance of the loans. The district court granted Flathead Bank’s motion for summary judgment. Muller appealed. The Supreme Court affirmed, holding that the district court did not err (1) in finding that Flathead Bank’s filing of an IRS Form 1099-C did not extinguish Muller’s debt, as the issuance of an IRS Form 1099-C is not prima facie evidence of a creditor’s intent to discharge a debt; and (2) in finding that Muller could only represent himself personally and could not appear on behalf of Masonry. View "Flathead Bank of Bigfork, Montana v. Masonry by Muller, Inc." on Justia Law

Holly and Robert Labair filed a legal malpractice claim for Steve Carey and Carey Law Firm (collectively, Carey) related to Carey’s representation of them in a medical malpractice action. The district court granted summary judgment to Carey. The Supreme Court reversed and remanded to the district court for a trial to establish two required components of the damages element of the Labairs’ claim: (1) that it was more probable than not that they would have recovered a settlement or judgment but for Carey’s negligence, and (2) the value of the lost settlement and/or judgment. After a trial, the jury indicated that the Labairs would not have settled the underlying medical malpractice claim. The district court formally entered judgment in favor of Carey. The Supreme Court vacated the judgment, holding that the district court erred in instructing the jury to decide whether Plaintiffs would have settled the underlying medical malpractice suit. Remanded for a new trial on the question of the value of the lost opportunity to settle. View "Labair v. Carey" on Justia Law

After a jury trial, Defendant was convicted of criminal endangerment. Defendant appealed, arguing that the district court erred in refusing to instruct the jury on negligent endangerment as a lesser included offense of criminal endangerment and that she was entitled to a new trial on that basis. The Supreme Court affirmed, holding that the evidence demonstrates that Defendant acted knowingly in engaging in conduct that created a substantial risk of death or serious bodily injury to another, and therefore, the district court did not abuse its discretion in concluding that the evidence was insufficient to support an instruction on negligent endangerment as a lesser included offense of criminal endangerment. View "State v. Russell" on Justia Law

Appellee filed an action against Missoula Electric Cooperative (MEC), asserting age discrimination in the hiring process. A Human Rights Bureau Investigator granted summary judgment for MEC, concluding that, as a matter of law, Appellee could not prove a case against MEC. The Human Rights Commission overturned its Hearing Examiner’s decision. The district court affirmed, holding that the Commission properly reversed the Hearing examiner’s decision because genuine issue of material fact existed, thus precluding summary judgment. The Supreme Court affirmed, holding that the Commission did not err by determining that the Hearing Examiner improperly granted summary judgment to MEC. View "Missoula Electric Cooperative v. Jon Cruson Inc." on Justia Law

After a jury trial, Defendant was convicted of criminal production or manufacture of dangerous drugs. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in instructing the jury on the theory of accountability when the State did not charge Defendant with accountability in the information; (2) the district court did not abuse its discretion when it allowed the State to admit Defendant’s medical marijuana provider application during rebuttal; (3) the prosecutor’s statements during closing argument were not improper; and (4) the district court acted within the proper bounds of its discretion when it denied Defendant’s request for a surrebuttal closing argument. View "State v. Dobrowski" on Justia Law