Justia Montana Supreme Court Opinion Summaries

Junkermeir, Clark, Campanella, Stevens, P.C. (Junkermeir) was a Montana accounting firm with offices in several Montana cities. Junkermeir lost its Bozeman branch office after the majority of its Bozeman shareholders decided to start their own firm, taking a significant number of Junkermier’s clients with them. Junkermeir filed a complaint against the former shareholders, claiming breach of contract and breach of fiduciary duty. The district court dismissed the breach of contract claim on summary judgment, concluding that the contractual covenant restricting competition that Junkermeir sought to enforce was unenforceable. After a trial, the district court ruled that most of the former shareholders owed no legal duty to Junkermeir and that while the remaining former shareholder breached his fiduciary duty to Junkermeir, Junkermeir failed to prove awardable damages from that breach. The Supreme Court reversed in part and affirmed in part, holding that the district court (1) erred in ruling that the agreement was not an enforceable contract; and (2) did not err in concluding that only one former shareholder breached a fiduciary duty but erred in concluding that Junkermeir was not entitled to collect any damages stemming from that breach. View "Junkermier, Clark, Campanella, Stevens, P.C. v. Alborn, Uithoven, Riekenberg, P.C." on Justia Law

Defendant pleaded guilty to felony theft for stealing a car. The threshold value for stolen property to support a charge of felony theft was $1,500. At a sentencing and restitution hearing, the district court imposed restitution of $2,500. Defendant appealed, arguing that the district court erred in imposing a restitution obligation of $2,500. The Supreme Court affirmed, holding (1) the district court properly relied upon the evidence to set the restitution obligation; and (2) because the victim presented evidence of valuation in the amount of $2,500, the district court’s findings were not clearly erroneous. View "State v. Hill" on Justia Law

Defendant was charged with criminal possession of dangerous drugs with intent to distribute with a persistent felony offender designation. Defendant filed a motion to suppress the evidence seized in the search of his car, asserting that the arresting officers lacked a particularized suspicion of wrongdoing involving narcotics sufficient to justify a canine sniff of his car. The district court denied the motion. Defendant entered a plea agreement admitting to the charges but reserving his right to appeal the denial of his motion to suppress. The Supreme Court affirmed, holding that, under the facts of this case, the district court did not err in determining that there was particularized suspicion to support the canine search of Defendant’s car. View "State v. Marino" on Justia Law

After a jury trial, Defendant was convicted of partner or family member assault, third or subsequent offense. Defendant appealed. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it admitted evidence of Defendant’s other crimes or acts under the transaction rule, Mont. Code Ann. 26-1-103; and (2) the district court did not abuse its discretion when it allowed the State to use leading questions to elicit testimony from the victim - who was an adult with a developmental disability, mild mental handicap, and with confusion about time and place - on direct examination. View "State v. Sayler" on Justia Law

Chris Wagner sued MSE Technology Applications, Inc. and related MSE entities (collectively, the MSE entities) and Butte Local Development Corporation (BLDC), alleging that they had improperly interfered with his attempt to purchase certain property to establish a commercial nursery. Plaintiff later amended his complaint to add Shea Relators as a defendant. The district court dismissed Wagner’s claims at trial pursuant to Mont. R. Civ. P. 50. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in granting judgment as a matter of law to the MSE entities and BLDC; but (2) erred in granting Shea Realtors summary judgment and judgment as a matter of law. Remanded. View "Wagner v. MSE Technology Applications, Inc." on Justia Law

In September 2013, Defendant was arrested for possession of drugs and drug paraphernalia and was jailed for more than ten months while he awaited testing results from the State Crime Lab. Trial was finally held at the end of July 2014. By then, Defendant had been incarcerated for 309 days. Before trial, Defendant filed a motion to dismiss the case for lack of a speedy trial. The district court denied the motion. The jury subsequently found Defendant guilty of both charges. The Supreme Court reversed, holding that the district court erred in denying Defendant’s motion to dismiss for lack of a speedy trial because he did not receive protection of his constitutional right to a speedy trial. View "State v. Velasquez" on Justia Law

Defendant was convicted of felony incest against his minor child, T.W. Prior to trial, the State obtained T.W.’s medical records but failed to disclose the medical records to the defense. After the trial, Defendant gained access to the medical records. The records provided evidence that T.W. suffered from psychosis and that T.W. may have previously made and then recanted an allegation of sexual abuse against her mother. Defendant appealed his conviction, arguing that he was entitled to a new trial based on the State’s failure to disclose T.W.’s medical records. The Supreme Court reversed, holding (1) the medical records contained favorable evidence to Defendant’s defense; and (2) the State’s failure to alert Defendant of the substance of the records caused Defendant prejudice. Remanded for a new trial. View "State v. Weisbarth" on Justia Law

In Tidyman’s I, the Supreme Court affirmed the district court’s finding that National Union Fire Insurance breached its duty to defend its insured, David and Maxwell. The Court, however, reversed the district court’s entry of summary judgment to the extent it approved a stipulated judgment of $29 million. The Court remanded for the district court to hold a hearing to assess the reasonableness of the settlement amount. On remand, after a reasonableness hearing, the district court again approved the stipulated settlement. The Supreme Court remanded the case to the district court for a second reasonableness hearing, holding (1) the district court erred in using a “reliable evidence” test to assess the reasonableness of the stipulated judgment; and (2) the district court erred in holding that Plaintiffs were entitled to prejudgment interest. View "Tidyman’s Mgmt. Servs., Inc. v. Nat’l Union Fire Ins. Co." on Justia Law

A.M.M.’s two children - Timothy McCann and Genet McCann (together, Appellants) - appealed from three groups of orders entered by the district court during actions it took to oversee the guardianship and conservatorship of A.M.M., including a preliminary injunction, Rule 11 sanctions, and a request for recusal. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by granting the Guardian’s motion for a preliminary injunction to enjoin Appellants from engaging in certain activities the Guardian believed were detrimental to A.M.M.’s health; (2) the district court did not err by denying Genet’s motion to recuse; and (3) the district court did not err by sanctioning Genet for violating Rule 11. View "In re Guardianship & Conservatorship of A.M.M." on Justia Law

After a jury trial, Defendant was convicted of driving under the influence of alcohol. The district court affirmed Defendant’s conviction. The Supreme Court affirmed, holding (1) Defendant was not denied his right to a speedy trial; (2) the justice court did not deny Defendant a fair trial when it refused to allow him to cross-examine the arresting officer about his administrative leave; (3) the justice court did not err when it allowed the officer to testify as an expert on horizontal gaze nystagmus; and (4) the justice court did not err in refusing Defendant’s proposed jury instructions on breath test refusal. View "State v. Krenning" on Justia Law