Justia Montana Supreme Court Opinion Summaries

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Defendant was charged with one count of arson, a felony. Pursuant to a plea agreement, Defendant pleaded no contest to arson. Defendant subsequently filed a motion to withdraw his no contest plea, asserting that the district court did not comply with the statutory procedures for rejecting plea agreements. The district court denied Defendant’s motion to withdraw his plea, concluding that Defendant entered the plea voluntarily and knowingly. The district court then sentenced Defendant to ten years’ imprisonment with five years suspended. The Supreme Court reversed and remanded with instructions for the district court to conduct another sentencing hearing, holding that the plea agreement in this case should be construed as a Mont. Code Ann. 46-12-211(1)(b) agreement and that the district court erred by not following the required procedures for rejecting the parties’ plea agreement. View "State v. Langley" on Justia Law

Posted in: Criminal Law
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Appellant was convicted of deliberate homicide and related felonies and misdemeanors. Appellant was sentenced to life imprisonment for the deliberate homicide conviction. The Supreme Court affirmed the convictions on appeal. Thereafter, Appellant filed a petition for postconviction relief, alleging ineffective assistance of counsel during his trial. The district court denied postconviction relief. The Supreme Court affirmed, holding (1) Appellant was not entitled to relief on any of his claims of ineffective assistance of counsel; and (2) because there was no ineffective assistance of counsel on Appellant’s individual claims, there can be no cumulative error. View "Heavygun v. State" on Justia Law

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Appellant, a severe alcoholic, consented to his initial commitment to the Montana State Hospital. When Appellant’s commitment was extended, he was transferred to the Montana Mental Health Nursing Care Center. A psychology specialist at the Nursing Care Center subsequently petitioned the district court to again extend Appellant’s commitment. After a hearing, the district court granted the petition and issued an order for recommitment requiring that Appellant be committed to the Nursing Care Center for a period not to exceed one year. The Supreme Court affirmed, holding that the district court’s order met the statutory requirements for extending commitment under Mont. Code Ann. 53-21-127 and -128. View "In re S.G.R." on Justia Law

Posted in: Health Law
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Father and Mother took Child, who was only a few weeks old at the time, shoplifting at a department store. The shoplifting turned into a robbery. Thereafter, the district court granted the petition of the Department of Public Health and Human Services to adjudicate Child as a youth in need of care. Father was later sentenced to twenty years with eighteen years suspended for the offenses. Upon the finding that Father’s treatment plan had not been successful, the district court terminated Father’s parental rights to Child. The Supreme Court affirmed, holding that the termination of Father’s parental rights was not an abuse of discretion where the district court did not commit clear error in finding that the treatment plan was unsuccessful. View "In re J.B." on Justia Law

Posted in: Family Law
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After a jury trial, Defendant was convicted of felony murder, aggravated assault, and related charges. The Supreme Court reversed the conviction for aggravated assault because it was an included offense of the charge of felony murder and affirmed the remaining convictions. Defendant subsequently filed a petition for postconviction relief, asserting that his attorneys at trial and on appeal provided ineffective assistance. The district court denied Defendant’s petition for postconviction relief. The Supreme Court affirmed, holding that the district court did not err in deciding that Defendant did not receive ineffective assistance of counsel at trial and on appeal. View "Russell v. State" on Justia Law

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Three defendants (jointly, Appellants) were convicted in municipal court of various traffic violations, including driving with a suspended license. The district court affirmed the convictions. Appellants appealed separately to the Supreme Court. The Supreme Court consolidated the cases and affirmed, holding (1) Mont. Code Ann. 61-5-212 imposes absolute liability, and a conviction under this statute does not require a culpable mental state; (2) because the evidence presented in each of Appellant’s trials met the requirements for conviction under section 61-5-212, the district court did not err in affirming Appellants’ convictions; and (3) the district court did not abuse its discretion by concluding that the letters notifying Appellants of their suspensions were admissible as certified copies of public records under Mont. R. Evid. 904. View "City of Kalispell v. Omyer" on Justia Law

Posted in: Criminal Law
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Appellants (collectively, the Teisingers) claimed a 3/5ths royalty interest in oil, gas, and minerals located on several sections of land in Richland County. The Teisingers’ assert that their 3/5ths royalty interest was reserved in a 1953 warranty deed. The district court denied the Teisingers’ claim and quieted title to the royalty interest in favor of Appellees (collectively, the Sundheims). The Supreme Court reversed, holding that the district court (1) improperly admitted testimony from an English professor interpreting the language of the warranty deed’s royalty interest reservation; (2) erred by resolving the ambiguity in the warranty deed in favor of the Sundheims; and (3) erred in applying the doctrine of laches to bar the Teisingers’ claim to the 3/5ths royalty interest. Remanded for entry of judgment quieting title to the 3/5ths royalty interest reserved in the warranty deed in favor of the Teisingers. View "Wicklund v. Sundheim" on Justia Law

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Roy Volk and Pamela Dee Volk had a son, RBV, in the fall of 2000. In 2011, the marriage was dissolved. At the time of the divorce, Roy owned two term life insurance policies. While a statutorily-mandated temporary restraining order was still in effect, Roy changed the beneficiary designations on both policies and designated his sister, Valerie Goeser, as the new beneficiary. Just over four months after the divorce was final, Roy died. Valerie received the life insurance proceeds from both policies. Pamela subsequently filed this action on behalf of RBV against Valerie and Roy’s estate seeking a constructive trust over the insurance policy payouts for the benefit of RBV. The district court granted summary judgment in favor of Valerie, concluding that Valerie was not unjustly enriched when she received Roy’s life insurance proceeds. The Supreme Court reversed, holding that Valerie was unjustly enriched because Roy’s errors in changing the beneficiary of his life insurance under the statutorily-mandated restraining order invalidated his designations on the insurance policies, and a constructive trust was created on RBV's behalf as a result of these errors. Remanded. View "Volk v. Goeser" on Justia Law

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When Daughter was two years old, Mother and Father dissolved their marriage. The district court approved a stipulated parenting plan entered into by the parties providing that Daughter would split her time equally between the parties in their respective homes in different states. Before Daughter was to enter kindergarten, Father filed a motion to modify the parenting plan. Mother responded with her own proposed parenting plan. The district court’s standing master issued an order amending the parenting plan and awarded custody of Daughter to Mother during the school year. The district court affirmed. The Supreme Court affirmed, holding that the district court did not err in affirming the standing master’s order amending the parenting plan. View "In re Marriage of Davis" on Justia Law

Posted in: Family Law
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The marriage of Creed Evans and Dava Bliss was dissolved in 2015. The day before the parties were married, they signed an antenuptial agreement providing that all property held by individually by a party before and during the marriage remained that party’s sole property upon dissolution. During the dissolution proceedings, Evans disputed the validity of the agreement. After a hearing, the standing master issued a declaratory judgment that the agreement was enforceable. The district court issued an order affirming and adopting the standing master’s declaratory judgment. The Supreme Court affirmed, holding that the district court did not err in finding the agreement valid and enforceable and in determining that more than 150 firearms belonged to Bliss. View "In Marriage of Bliss" on Justia Law

Posted in: Family Law