Justia Montana Supreme Court Opinion Summaries

A group of residents in the Whitehorse Estates Minor Subdivision filed a complaint against their neighbors, Joseph and Amanda Kleinhans, alleging that the Kleinhans violated the subdivision’s restrictive covenants by converting their garage into an accessory dwelling unit (ADU) and renting it out as an Airbnb. The covenants in question required properties to be used only for single-family dwellings and prohibited the operation of commercial businesses.The District Court of the Twenty-Second Judicial District, Carbon County, granted summary judgment in favor of the Kleinhans. The court interpreted the single-family dwelling covenant as a structural restriction, not a use restriction, meaning it only limited the type and number of buildings but did not restrict the use of the property to single families. The court also found the commercial business covenant to be ambiguous and concluded it did not prohibit short-term rentals like Airbnb. Consequently, the court awarded the Kleinhans their Bill of Costs amounting to $4,594.35.The Supreme Court of the State of Montana reviewed the case and reversed the District Court’s decision. The Supreme Court held that the term "commercial business" was not ambiguous and should be given its plain and ordinary meaning, which includes activities conducted for profit. Therefore, the Kleinhans' operation of an Airbnb constituted a commercial business, violating the subdivision’s covenants. The Supreme Court also reversed the award of the Bill of Costs to the Kleinhans and remanded the case to the District Court to enter summary judgment in favor of the neighbors. View "Myers v. Kleinhans" on Justia Law

Garrett Michael O’Howell was arrested following a traffic stop on May 4, 2020. Broadwater County Sheriff’s Deputy Tony Cordova observed a vehicle in a parking lot and found the behavior of its occupants suspicious. The vehicle was registered to Kaitlyn Smock, whose driver’s license was revoked. After Smock drove the vehicle away, Cordova stopped it for speeding and because of Smock’s revoked license. None of the passengers, including O’Howell, had a valid driver’s license. Cordova discovered that O’Howell had an outstanding warrant and arrested him. A subsequent search of the vehicle revealed methamphetamine and drug paraphernalia.The First Judicial District Court denied O’Howell’s motion to suppress the evidence, concluding that the stop was justified and that Cordova’s actions were lawful. The court found that Cordova had a particularized suspicion to stop the vehicle and that the questioning of the passengers was within the scope of the stop. O’Howell was convicted by a jury of criminal possession of dangerous drugs with intent to distribute and possession of drug paraphernalia.The Supreme Court of the State of Montana reviewed the case. The court held that Cordova’s questioning of the passengers did not exceed the scope of the traffic stop, as it was necessary to determine if any of them could legally drive the vehicle. The court also found that there was sufficient evidence to support the jury’s verdict, including testimony from Smock and Laird, corroborated by O’Howell’s own statements and the physical evidence found in the vehicle. The court affirmed the lower court’s decision, upholding O’Howell’s convictions. View "State v. O'Howell" on Justia Law

This case involves a property dispute in Lincoln County, Montana. Tiffany House sought to sell a property initially conveyed to her former husband, Conrad Coggeshall, by an LLC owned by David E. Orr. After their divorce, House was granted permission by the Superior Court of Arizona to transfer the property into her name. However, Coggeshall, while incarcerated, executed a quitclaim deed transferring his interest in the property to Orr, who recorded it in Lincoln County. House then filed a quiet title action, alleging the transfer was fraudulent.The Nineteenth Judicial District Court reviewed the case. House served Orr with discovery requests, including admissions that Orr failed to respond to. Consequently, House filed a motion for summary judgment, which Orr did not contest. The District Court granted House’s motion, quieting title in her name and ordering Orr to execute a quitclaim deed. Orr filed a notice of appeal and a motion to stay execution, which the District Court denied. Orr’s first appeal was dismissed, and he filed a second notice of appeal.The Supreme Court of the State of Montana reviewed the case de novo. Orr argued that the requests for admission were improperly served, that he did deny them, and that the summary judgment violated his Fifth and Sixth Amendment rights. However, the court noted that these arguments were not raised in the lower court and thus were not preserved for appeal. The court emphasized the importance of procedural rules and fair notice of legal issues. Consequently, the court affirmed the District Court’s decision to grant summary judgment in favor of House. View "House v Orr" on Justia Law

O.L.K. was admitted to Montana State Hospital in January 2022 following a disturbance at a mental health treatment center. The petition for involuntary commitment was based on an evaluation by Michale McLean, LCSW, which included observations and reports from medical staff and law enforcement. O.L.K. had been brought to the hospital twice in one day for aggressive behavior, including threatening his therapist and threatening to burn down the treatment center. During his second hospital visit, he made several threatening statements, including threats to kill someone.The Fourth Judicial District Court, Missoula County, appointed Shannon McNabb, a Licensed Clinical Professional Counselor, to evaluate O.L.K. McNabb testified that O.L.K. exhibited disorganized and delusional behavior and diagnosed him with Bipolar I disorder. She relied on various records, including the St. Patrick’s Report, and testified about O.L.K.’s threats and delusional statements. The District Court overruled hearsay objections raised by O.L.K.’s attorney, admitting the St. Patrick’s Report under the medical records exception. The court found that O.L.K. presented an imminent risk to others and committed him to Montana State Hospital for up to 90 days.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s decision. The Supreme Court held that while the District Court erred in admitting the St. Patrick’s Report as a hearsay exception, there was substantial admissible evidence from McNabb’s testimony to support the finding of an overt act. The court concluded that O.L.K.’s statements to McNabb, which included threats to kill someone, were sufficient to demonstrate an imminent threat of injury to others. The decision to commit O.L.K. was therefore upheld. View "In re O.L.K." on Justia Law

Joshua Allen Baldwin was arrested by Officer Daniel Beasley on July 22, 2021, at Lucky Lil’s Casino in Anaconda, Montana, for allegedly violating his pre-release conditions by being in a casino. Beasley confirmed with dispatch that Baldwin was under court conditions prohibiting him from being in such establishments. After Baldwin was arrested, officers observed suspicious items in his car, including a butane refill bottle, burnt pliers, and a Ziploc baggie with a white crystalline substance. A subsequent search of Baldwin’s car, conducted after obtaining a warrant, revealed methamphetamine and drug paraphernalia.The Third Judicial District Court, Anaconda-Deer Lodge County, denied Baldwin’s motion to suppress the evidence obtained from the search, ruling that the arrest was lawful. Baldwin then pleaded guilty to felony drug possession while reserving his right to appeal the suppression ruling. The misdemeanor charge for drug paraphernalia was dismissed.The Supreme Court of the State of Montana reviewed the case and reversed the lower court’s decision. The court held that Beasley did not have probable cause to arrest Baldwin for contempt of court based on the alleged violation of pre-release conditions. The court determined that pre-release conditions do not constitute an independent mandate of the court under Montana law, and thus, Baldwin’s arrest was unlawful. Consequently, the evidence obtained from the search of Baldwin’s car, which was conducted as a result of the unlawful arrest, should have been suppressed. The court found no applicable exceptions to the exclusionary rule, such as good faith or independent source exceptions, and concluded that the evidence was directly tied to the unlawful arrest. View "State v. Baldwin" on Justia Law

The case involves Montanans Against Irresponsible Densification, LLC (MAID), which challenged two laws passed by the 2023 Montana Legislature aimed at addressing affordable housing. Senate Bill 323 (SB 323) mandates that duplex housing be allowed in cities with at least 5,000 residents where single-family residences are permitted. Senate Bill 528 (SB 528) requires municipalities to allow at least one accessory dwelling unit on lots with single-family dwellings. MAID, consisting of homeowners from various cities, argued that these laws would negatively impact their property values and quality of life, and filed for declaratory and injunctive relief.The Eighteenth Judicial District Court in Gallatin County granted MAID a preliminary injunction, temporarily halting the implementation of the laws. The court found that MAID had standing and had demonstrated the likelihood of irreparable harm, success on the merits, and that the balance of equities and public interest favored the injunction. The court cited concerns about potential impacts on property values and neighborhood character, as well as constitutional issues related to public participation and equal protection.The Supreme Court of the State of Montana reviewed the case and reversed the District Court's decision. The Supreme Court found that MAID did not meet the burden of demonstrating all four factors required for a preliminary injunction. Specifically, the court held that MAID's evidence of potential harm was speculative and did not show a likelihood of irreparable injury. The court also noted that the balance of equities and public interest did not favor the injunction, given the legislative intent to address the housing crisis. The Supreme Court remanded the case for further proceedings. View "Montanans Against Irresponsible Densification, LLC, v. State" on Justia Law

Samuel J. Nelson appealed an order from the Eighteenth Judicial District Court, Gallatin County, which granted summary judgment in favor of Montana Rail Link, Inc. (MRL) and BNSF Railway Co. Nelson sought a prescriptive easement over a railroad right of way (ROW) granted under the Northern Pacific Railroad Company Land Grant Act of 1864. Nelson had been using a dirt road within the ROW to access his property since 1982. Despite MRL's awareness and multiple attempts to formalize Nelson's use through a lease, no agreement was reached, and MRL eventually blocked access, leading to Nelson's criminal trespass citation, which was later dismissed.The District Court ruled that a private party could not acquire a prescriptive easement over a railroad ROW granted under the 1864 Act, as these ROWs were for the exclusive use and control of the railroads, with the United States holding a reversionary interest. Nelson appealed this decision.The Supreme Court of the State of Montana affirmed the District Court's ruling. The Court held that the 1864 Act granted the railroad a limited fee with exclusive possession and control, subject to a reversionary interest by the United States. This exclusivity precludes private parties from acquiring any property interests, including prescriptive easements, within the ROW. The Court also noted that a private prescriptive easement would interfere with the railroad's operations and the federal government's reversionary interest. The Court concluded that Nelson could not obtain a prescriptive easement over the ROW, affirming the lower court's judgment in favor of MRL and BNSF. View "Nelson v. Montana Rail" on Justia Law

Marcus Cook petitioned for a temporary order of protection against his former girlfriend, Kim Elizabeth Bodine, alleging that she had repeatedly trespassed on his property and stalked him despite his demands for no contact. Cook's petition detailed several incidents, including Bodine entering his home uninvited, driving by his house, and being arrested for stalking. Based on these allegations, the Gallatin County Justice Court issued an ex parte temporary protective order and scheduled a hearing.At the hearing, Cook testified about the ongoing harassment and its impact on his life, including increased anxiety and changes to his daily routine. He presented evidence such as police citations and surveillance footage. Bodine, represented by counsel, did not testify but attempted to discredit Cook's claims through cross-examination and by presenting a GPS report suggesting she was not near Cook's home during one alleged incident. The Justice Court found Cook's testimony credible and issued a 10-year protective order against Bodine.Bodine appealed to the Montana Eighteenth Judicial District Court, which affirmed the Justice Court's decision. She then appealed to the Supreme Court of the State of Montana, arguing that the Justice Court failed to provide sufficient findings of fact and that the evidence did not support the need for a long-term protective order.The Supreme Court of the State of Montana reviewed the case and upheld the lower courts' decisions. The Court found that the Justice Court had made adequate oral findings and that substantial evidence supported the issuance of the protective order. The Court concluded that the Justice Court did not abuse its discretion in issuing a 10-year protective order, given Bodine's pattern of conduct and the need to prevent further harm to Cook. The decision was affirmed. View "Cook v. Bodine" on Justia Law

In May 2023, the State charged Samuel Wade Frydenlund with burglary, stalking, and partner or family member assault. Frydenlund intended to present a defense of mental disease or defect. Before trial, the court dismissed the stalking and assault charges, proceeding only with the burglary charge. Frydenlund requested that the jury be instructed on criminal trespass as a lesser included offense of burglary. The court agreed to include this instruction if the jury could not reach a verdict on the burglary charge.At trial, the jury found Frydenlund not guilty of burglary but guilty of criminal trespass. Frydenlund moved to set aside the verdict, arguing that the jury should not have considered the lesser offense after acquitting him of burglary. The Ninth Judicial District Court denied his motion, stating that it was not inconsistent to find him not guilty of burglary but guilty of criminal trespass, as the latter requires proof of fewer elements.The Supreme Court of the State of Montana reviewed the case. The court held that the verdict form and jury instructions were consistent with Montana law, specifically § 46-16-607(3), MCA, which allows the jury to consider a lesser included offense if it cannot reach a verdict on the greater offense. The court found no double jeopardy violation, as Frydenlund was convicted of only one crime—criminal trespass. The court affirmed the District Court's decision, concluding that the jury's consideration of the lesser included offense was appropriate and that Frydenlund's rights were not violated. View "State v. Frydenlund" on Justia Law

In August 2020, Kimberly Strable, who was under 18, inquired about a managerial position at Arby’s in Great Falls but was told she could not apply due to her age. Strable filed an age discrimination claim with the Montana Human Rights Bureau (HRB), which issued a reasonable cause determination. The parties entered into a conciliation process, and Strable’s attorney and Arby’s attorney reached an agreement in principle for a $25,000 settlement, subject to a mutually agreeable settlement agreement. However, the parties did not finalize or sign the draft conciliation agreement, which included affirmative relief provisions required by the HRB.The First Judicial District Court, Lewis and Clark County, granted summary judgment in favor of Arby’s, finding that no enforceable contract existed between the parties. The court noted that the negotiations were part of an ongoing HRB case and that Arby’s had not consented to the affirmative relief provisions, which were essential terms of the conciliation agreement.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s decision. The court held that the essential element of consent was lacking because the parties had not agreed on all essential terms, including the HRB’s affirmative relief provisions. The court emphasized that a binding contract requires mutual consent on all essential terms, and in this case, Arby’s could not consent to terms it was unaware of. Therefore, the court concluded that no enforceable contract existed, and summary judgment in favor of Arby’s was appropriate. View "Strable v. Carisch" on Justia Law