Justia Montana Supreme Court Opinion Summaries

Kenneth Woody died after the vehicle in which he was a passenger crashed following a high-speed chase by a Big Horn County Sheriff’s deputy. The Estate submitted a claim letter to the County seeking $750,000 for wrongful death and survivorship damages. The County never responded. The Estate later filed a complaint against the County, alleging negligence, wrongful death, survivorship, and negligent infliction of emotional distress. The County moved to dismiss for failure to state a claim, asserting that the Estate’s claims were barred by the pertinent three-year statute of limitations. In response, the Estate asserted that its claim letter to the County tolled the statute of limitations. The district court granted the County’s motion to dismiss. The Supreme Court reversed, holding that the Estate’s claim was timely filed. View "In re Estate of Woody v. Big Horn County" on Justia Law

Defendant pled guilty to an amended charge of criminal endangerment for having sexual intercourse with A.C., a fourteen-year-old, which resulted in A.C. becoming pregnant and giving birth to twins. The district court ordered Defendant to pay $35,667 in restitution to A.C.’s mother, which included $25,000 A.C.’s mother, D.C., claimed as lost wages due to the leave of absence she took from work to care for A.C. and the twins after the twins were born. Defendant appealed, challenging the restitution order and several of the conditions of his probation. The Supreme Court (1) affirmed the district court’s restitution order, holding that the court did not err in awarding D.C. $25,000 in lost wages; and (2) reversed several of the probation conditions due to various errors. View "State v. Brave" on Justia Law

After a jury trial, Defendant was convicted of criminal distribution of dangerous drugs, endangering the welfare of children, and incest for giving methamphetamine to his daughter, S.K., allowing her to ingest methamphetamine while in his care, and having sexual intercourse or sexual contact with her. The Supreme Court affirmed the judgment and sentence, holding (1) the district court did not err by concluding that S.K. was not legally accountable for Kline’s incest; and (2) the State presented sufficient evidence to the jury corroborating S.K.’s testimony regarding incest, and therefore, the district court properly denied Defendant’s motion for a directed verdict of acquittal based on the State’s failure to present corroborating evidence. View "State v. Kline" on Justia Law

In 2014, a large boulder dislodged from a hillside and fell into J. Russell Parker’s unoccupied vacation cabin, causing substantial damage. Parker submitted a claim to his insurer, Safeco Insurance Company. Safeco denied the claim, determining that rockfall is considered “earth movement from landslide,” which was specifically excluded under Parker’s policy. Parker sued Safeco, claiming breach of contract and seeking damages under the Unfair Trade Practices Act. The district court granted summary judgment in favor of Safeco. The Supreme Court affirmed, holding that Safeco property denied Parker’s claim based upon an express coverage exclusion in the policy. View "Parker v. Safeco Ins. Co. of America" on Justia Law

Matt Wagenman and Tammy Wagenman filed a pro se joint petition for dissolution to dissolve their marriage and divide up their property and debt. In their petition, the parties stated that their real property should be distributed as described in Exhibit A, which they attached to their petition. In the final decree of dissolution, the court did not enter the property and debt distribution according to Exhibit A, nor did it incorporate Exhibit A into the decree. Approximately two years later, the parties discovered that the district court failed to incorporate Exhibit A into the decree. Matt’s counsel subsequently filed a motion to compel, requesting that the court order Tammy to quitclaim her interest in the home based on the final decree. Tammy, in turn, filed a motion to amend the final decree of dissolution to incorporate Exhibit A as the parties originally requested. The district court denied Tammy’s motion to amend the decree and granted Matt’s motion to compel and awarded Matt attorney fees. The Supreme Court reversed, holding that the district court (1) erred by failing to incorporate Exhibit A into the final decree and by denying Tammy’s motion to amend the final decree to incorporate Exhibit A; and (2) improperly awarded attorney fees to Matt. Remanded. View "In re Marriage of Wagenman" on Justia Law

In 2014, the Lincoln County Attorney’s office filed a second petition alleging that C.C. suffered from a mental disorder and required commitment. After an adjudicatory hearing, the district court committed C.C. to the Montana State Hospital for a period of ninety days. C.C. appealed, arguing that the district court’s order lacked a sufficiently detailed statement of facts to justify her commitment. The Supreme Court vacated the district court’s order of commitment and its separate findings of fact and conclusions of law and reversed and remanded for an order of dismissal, holding that the district court erred when it failed to provide a detailed statement of facts to justify C.C.’s involuntary commitment. View "In re C.C." on Justia Law

Larry Reinlasoder, the former chief of police for the City of Colstrip, sued Colstrip for wrongful discharge. In its defense, Colstrip contended that it had fired Reinlasoder for good cause. The jury returned a verdict for Reinlasoder. Colstrip appealed, arguing that the district court erred by denying its motion for judgment as a matter of law where Reinlasoder failed to contest that he had sexually harassed an employee. The Supreme Court reversed and remanded for entry of judgment in favor of Colstrip, holding that judgment as a matter of law was appropriate in this case because the undisputed facts precluded Reinlasoder from establishing an absence of good cause, the crucial element of his wrongful discharge claim. View "Reinlasoder v. City of Colstrip" on Justia Law

When Chrysler Group, LLC filed with the Montana Department of Justice, Motor Vehicle Division a notice of intent to establish an additional Chrysler-Jeep dealership in Billings, Lithia Motors, Inc. filed an administrative protest. The Department sustained Lithia’s protest. Rimrock Chrysler, Inc. sought judicial review, but the district court dismissed the petition on the grounds of mootness and lack of a justiciable controversy. While Rimrock’s appeal was pending, the Sixth Circuit Court of Appeals ruled that section 747 of the United States Consolidated Appropriations Act of 2010 preempted state regulation of new dealerships issued under certain dealership protest laws. The Montana Supreme Court dismissed Rimrock’s appeal. On remand, Rimrock moved to vacate the Department’s administrative decision and to dismiss the the judicial review proceeding on the ground that section 747 preempted Montana dealer protest laws and deprived the state of subject matter jurisdiction to hear the administrative claim. The district court denied Rimrock’s motion and dismissed the appeal. The Supreme Court (1) affirmed the district court’s order denying Rimrock’s motion to vacate and to dismiss, holding that Rimrock waived its section 747 preemption defense when it entered into the settlement agreement; and (2) reversed the district court’s order dismissing Rimrock’s petition for judicial review, holding that Rimrock’s petition involved a justifiable controversy, and the court erred in concluding otherwise. View "Rimrock Chrysler, Inc. v. Lithia Motors, Inc." on Justia Law

Plaintiff and Defendants owned adjoining properties. Defendants’ property held an easement that ran through Plaintiff’s land. When Defendants began to build a road on their easement to access their property, Plaintiff filed a complaint. The Cascade Conservation District eventually issued the necessary permit so Defendants could continue road construction. The Defendants completed the road along their easement in 2010. In 2013, Plaintiff filed suit alleging that Defendants destroyed an access trail when constructing the easement road. Plaintiff also filed a notice of lis pendens, which prevented Defendants from closing on the sale of their property. The district court held that Plaintiff’s trespass and negligence claims were barred by the statutes of limitations and that his remaining claims were barred by laches. The Supreme Court affirmed, holding the district court properly applied the doctrine of laches and did not err by granting summary judgment in favor of Defendants on all of Plaintiff’s claims not already barred by statutes of limitation. View "Algee v. Hren" on Justia Law

Plaintiffs and Defendants owned real property on a peninsula in Echo Lake. Defendants owned a parcel on the southern end of the peninsula, through which the sole vehicular road granting access to the northern lots owned by Plaintiffs ran. Defendants purchased their property subject to a long-term existing easement allowing Plaintiffs access to their properties. In 1992, the parties entered into a road maintenance agreement setting forth the responsibilities of the parties regarding maintenance of the access road. When a flood damaged the road, Plaintiffs filed a complaint seeking declaratory judgment that the maintenance agreement was valid and enforceable and alleging that Defendants breached the agreement. Defendants counterclaimed. The district court entered judgment in favor of Defendants. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) erred by concluding that the maintenance agreement was unenforceable against Defendants for lack of consideration, but the error was harmless; (2) did not err by ruling that Defendants did not breach the maintenance agreement; and (3) did not err by ordering Plaintiffs to pay Defendants’ counterclaim-related attorney’s fees and costs. View "Low v. Reick" on Justia Law