Justia Montana Supreme Court Opinion Summaries

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After a jury trial, Defendant was found guilty of sexual intercourse without consent. The victim was four years old at the time of the offenses. Defendant was sentenced to 100 years in prison and was not eligible for parole for the first fifty years. The Supreme Court affirmed, holding (1) the district court did not err by denying Defendant’s motions that were made during trial to dismiss the charge for insufficient evidence; and (2) Defendant’s claim that trial counsel provided ineffective assistance by failing to call expert witnesses was more properly brought by a petition for postconviction relief. View "State v. McAlister" on Justia Law

Posted in: Criminal Law
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Wife filed a petition for dissolution of her marriage to Husband. After a bench trial, the district court entered written findings of fact, conclusions of law, and decree of dissolution, ordering that certain properties owned by the parties be sold and that the proceeds be put toward paying off delinquent tax liability to the Internal Revenue Service and the Montana Department of Revenue. Wife appealed the court’s finding and conclusion regarding the tax liability. The Supreme Court affirmed, holding that the district court did not err in considering the tax liability as marital debt or by including that debt in apportioning the marital estate. View "In re Marriage of Rose" on Justia Law

Posted in: Family Law
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Keller Transport, Inc. leased a tanker truck from Wagner Enterprises, LLC to transport gasoline. The truck’s trailer overturned and spilled 6,380 gallons of gasoline, which flooded several homeowners’ properties. Keller and Wagner were both insured under a commercial transportation policy. Westchester Surplus Lines Insurance Company insured both Keller and Wagner under an excess liability policy. Homeowners initiated suit against Keller and Wagner. Westchester undertook defense of the suit on behalf of Kohler and Wagner pursuant to a reservation of rights and defended Keller and Wagner until the limit of its excess coverage had allegedly been exhausted. Westchester sought a declaration that the limit under its excess policy was $4 million in total and that the limit had been exhausted. As relevant to this appeal, the district court granted summary judgment against Westchester. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err by determining that Westchester’s policy was ambiguous and that it provided an additional $4 million in coverage under the “general aggregate” limit; but (2) erred by holding that Westchester breached its duty to defend the insureds under its policy. View "Westchester Surplus Lines Ins. Co. v. Keller Transport, Inc." on Justia Law

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The State charged Defendant in Ravalli County with felony theft by common scheme for double-cashing seven paychecks issued by an employment agency located in Ravalli County. The paychecks were issued for Defendant’s work as a temporary employee at a senior living community in Missoula County. Defendant moved to dismiss the charges against him, alleging that they were brought in an improper venue. After a non-jury trial, Defendant was convicted. The Supreme Court affirmed, holding that the district court did not err in concluding that Ravalli County was a proper venue for the State to charge Defendant with felony theft by common scheme. View "State v. Deshazer" on Justia Law

Posted in: Criminal Law
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Plaintiff was involved in a vehicle collision with Defendant. Defendant admitted that she was negligent, and Plaintiff filed suit for damages. After a trial, the jury returned a verdict for Plaintiff. The district court entered judgment for Plaintiff in the amount of $3,057 after factoring in offsets for previously-made payments. Plaintiff appealed, alleging several claims of error. The Supreme Court affirmed, holding that the district court did not err or abuse its discretion by (1) excluding trial testimony of Plaintiff’s treating physician; (2) excluding trial testimony of Plaintiff’s physical therapist; (3) granting a directed verdict on Plaintiff’s claim that her rotator cuff tear and shoulder arthritis were caused by the collision; and (4) concluding that Plaintiff could not recover damages incurred by her business. View "Cleveland v. Ward" on Justia Law

Posted in: Injury Law
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In 2014, the Montana Environmental Information Center (MEIC) filed suit challenging the decision of the Montana Department of Environmental Quality (DEQ) to approve the expansion of Golden Sunlight Mines, Inc.’s (GSM) gold mine to include a nearby pit. DEQ and GSM (together, Appellees) asserted that MEIC should be collaterally estopped from relitigating the question of whether the Montana Constitution and the Montana Metal Mine Reclamation Act (MMRA) require lands disturbed by a mining operation to be fully reclaimed because this precise issue had already been litigated, with MEIC receiving an adverse ruling from the district court. The district court agreed and entered judgment in favor of Appellees. The Supreme Court affirmed, holding (1) the district court correctly found that collateral estoppel precluded MEIC from relitigating whether the Montana Constitution or the MMRA requires land disturbed by the taking of natural resources to be fully reclaimed to its previous condition; and (2) the district court did not err by upholding the DEQ’s decision. View "Mont. Envtl. Info. Ctr. v. Mont. Dep’t of Envtl. Quality" on Justia Law

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After a jury trial, Defendant was convicted of seven counts of attempted deliberate homicide. The district court sentenced Defendant to serve a life term in prison on each count and declared him ineligible for parole. Defendant appealed, arguing that the district court erred when it denied his request to instruct the jury on misdemeanor assault as a lesser-included offense of attempted deliberate homicide. The Supreme Court affirmed the judgment, holding that the trial court did not act arbitrarily, act without conscientious exercise of judgment, or exceed the bounds of reason when it determined that the evidence supported the jury’s consideration of only the offenses of attempted deliberate homicide or attempted aggravated assault, and further, the court’s refusal to instruct the jury on misdemeanor assault did not prejudice Defendant’s substantial rights. View "State v. Stewart" on Justia Law

Posted in: Criminal Law
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In 2013, the district court adjudicated Mother’s two minor children youths in need of care. In 2015, the district court terminated Mother’s parental rights, concluding that Mother’s conduct or condition rendering her unfit was unlikely to change within a reasonable time because Mother had an extensive history and current issues related to substance abuse, was homeless, and had no income. The Supreme Court affirmed, holding (1) the district court did not err in concluding that the conduct or condition that made Mother unfit to parent was unlikely to change within a reasonable time; (2) the district court correctly applied the presumption in Mont. Code Ann. 41-3-604(1) to conclude that termination of Mother’s parental rights was in her children’s best interests; and (3) Mother failed to demonstrate that her counsel was ineffective or that she was prejudiced as a result. View "In re C.W.E." on Justia Law

Posted in: Family Law
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This appeal concerned individual objectors to the Crow Water Compact, an agreement to distribute and manage water rights among the United States, the Crow Tribe, and the State of Montana. The Supreme Court affirmed the Water Court’s order, holding (1) the Water Court applied the proper legal standard of review in approving the Compact in the final order; (2) the Objectors failed to meet their burden of showing that the Compact was unreasonable and materially injured their interest; and (3) the Compact negotiation process did not violate the Objectors’ due process rights. View "In re Crow Tribe Water Compact" on Justia Law

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After a jury trial, Defendant was convicted of driving under the influence (DUI), a fifth-offense felony. Defendant was sentenced to a thirteen-month commitment at the Montana Department of Corrections (DOC) followed by a five-year suspended commitment at the DOC. Defendant appealed, arguing that his blood sample was not taken in compliance with Mont. Code Ann. 61-8-405(1). The Supreme Court affirmed, holding that the district court correctly ruled that the results of Defendant’s blood-alcohol test were admissible at trial because Defendant’s blood sample was taken in compliance with section 61-8-405(1). View "State v. Allport" on Justia Law

Posted in: Criminal Law