Justia Montana Supreme Court Opinion Summaries

In 2010, Scott Reis and Austin Luckett, who were both driving separate vehicles, were involved in a three-car automobile accident. Luckett admitted liability for the accident. In 2013, Reis filed a complaint alleging that Luckett’s negligence caused him neck, back, and hand injuries. After a jury trial, the district court concluded that Luckett’s negligence was not a cause of injury to Reis. Thereafter, Reis filed a motion to vacate the jury verdict and grant a new trial. The district court granted the motion for a new trial, concluding that the uncontroverted evidence proved Luckett’s negligence caused injury to Reis’s hand and that the jury verdict materially affected Reis’s substantial rights. The Supreme Court affirmed, holding that the district court did not err in granting Reis’s motion for a new trial. View "Reis v. Luckett" on Justia Law

Plaintiff was severely injured during a single vehicle accident that occurred on a City of Billings road. Plaintiff filed two complaints - one against the City Public Works Director and one against the State, Yellowstone County, and the City. Both complaints alleged negligence in the placement, installation, and maintenance of concrete barriers along the sharp curve where the accident took place. The district court granted Defendants’ motions for summary judgment. The Supreme Court affirmed, holding that the district court correctly granted summary judgment to Defendants on the ground that Plaintiff failed to raise an issue of material fact regarding Defendants’ breach of their alleged duties of care. View "Not Afraid v. Mumford" on Justia Law

Three minor children had potential claims against their father (Father) and their father’s business arising out of an automobile accident that killed their mother. An attorney petitioned the district court to appoint a guardian ad litem (GAL) to determine if litigation was in the children’s best interests and counsel to pursue those claims on the children’s behalf. Father objected to the attorney’s application for the appointment of a GAL, contending that his family is financially secure and that pursuing further insurance coverage would be traumatic for his children. The district court determined that Father had a conflict of interest with the children because he would be the named defendant in a suit filed on their behalf and appointed a GAL to determine whether litigation was in the best interests of Father’s children. The Supreme Court affirmed, holding that the district court did not abuse its discretion in appointing a GAL to determine whether the pursuit of certain legal claims would be in the best interests of Father’s children. View "In re Conservatorship of Soule" on Justia Law

After a bench trial, Defendant was convicted of operating a motor vehicle with an alcohol concentration in excess of 0.08. Defendant appealed and filed a motion to suppress the results of two separate blood alcohol concentration tests. The district court denied the motion. Defendant subsequently entered a guilty plea, reserving his right to appeal the denial of his motion. The Supreme Court affirmed, holding that one blood test, drawn more than eight hours after the act of driving, was taken within a reasonable time under the circumstances, and therefore, the district court did not err by denying Defendant’s motion to suppress on this ground. View "State v. Hala" on Justia Law

When Mary Stewart failed to pay real property taxes on her property, the Flathead County Treasurer held a tax lien sale for the delinquent taxes. The County was listed as the purchaser of the tax lien. In 2013, RN & DB, LLC paid the delinquent taxes, penalties, interests, and costs for the property and applied for a tax deed. The County issued a tax deed to RN & DB, after which RN & DB filed an action to quiet title in the property. The district court granted RN & DB’s motion for summary judgment and entered a decree quieting title in favor of RN & DB. The Supreme Court affirmed, holding (1) the district court did not err in not applying the statutory homestead exemption to the tax lien sale on Stewart’s property; (2) Stewart’s claim that the district court should have considered the tax assessor’s failure to investigate Stewart’s complaints regarding irregular tax assessments on Stewart’s property was barred; and (3) the district court did not abuse its discretion in granting summary judgment without holding a hearing. View "RN & DB, LLC v. Stewart" on Justia Law

Defendants acquired real property by borrowing more than $2 million from Whitefish Credit Union (WCU) and signing a promissory note to WCU, secured by mortgages on the property. Defendants later defaulted on that note, owing a principal balance of $1,951,670. WCU filed this action for foreclosure and collection of the debt. The property was sold at a sheriff’s sale to WCU for $1,100,000. Thereafter, WCU filed a request for entry of a deficiency judgment against Defendants for the amount of $745,365. Defendants opposed the request, arguing that the fair market value of the property exceeded the loan balance. After a hearing, the district court found the property was worth $2,366,667 as of the date of the sheriff’s sale and that no deficiency was owed to WCU. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not abuse its discretion by proceeding in equity to determine the fair value of the property for purposes of entering a deficiency judgment; but (2) evidentiary errors clearly affected the outcome of the proceeding to the prejudice of WCU. Remanded for further proceedings on the evidentiary issues and the applicable standard. View "Whitefish Credit Union v. Prindiville" on Justia Law

When Kent Roose was injured in an automobile crash his wife was an employee of Lincoln County, which provided health benefits via a group health plan (the Plan) that was part of Joint Powers Trust (JPT). Employee Benefit Management Services, Inc. (EBMS administered the Plan. The Plan contained an exclusion stating that medical benefits would not be paid when any automobile or third-party liability insurance was available to pay medical costs. EBMS denied Roose’s request for reimbursement for medical expenses he paid out of the liability insurance payment he received from the tortfeasors’ insurer. Roose subsequently brought suit against EBMS and JPT. The Supreme Court held that the exclusion violated Mont. Code Ann. 2- 18-902(4). Appellants subsequently reimbursed Roose the requested amount. In 2014, Roose filed a motion for partial summary judgment and class certification, arguing that Appellants violated section 2-18-902 through systematic practices that amounted to seeking subrogation against the tortfeasor’s liability carrier before Roose was made whole. Roose also sought class certification on behalf of every member of Appellants’ plans subject to Montana law that contained the coverage exclusion. The district court granted Roose’s motion. The Supreme Court affirmed, holding that the district court did not abuse its discretion in certifying the class or in defining the class. View "Roose v. Lincoln County Employee Group Health Plan" on Justia Law

Letica Land Company, LLC and Don McGee (collectively, Plaintiffs) filed an amended complaint for declaratory and injunctive relief seeking a preliminary injunction to close Modesty Creek Road, which consisted of an upper branch and a lower branch and crossed Plaintiffs’ respective properties. Plaintiffs claimed that they were unaware of any claim of public right of access over either branch of Modesty Creek Road at the time they purchased their respective properties. The district court concluded that Modesty Creek Road’s lower branch was a statutorily created road, that a public prescriptive easement established Modesty Creek Road’s upper branch as a public road, and that the prescriptive easement had not been extinguished by reverse adverse possession. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) did not err in concluding that Modesty Creek Road’s lower branch was statutorily created; but (2) erred in concluding that the public prescriptive easement the court found on Modesty Creek Road’s upper branch was not extinguished by reverse adverse possession. View "Letica Land Co., LLC v. Anaconda-Deer Lodge County" on Justia Law

Debtor filed for Chapter 7 Bankruptcy. Debtor claimed an Individual Retirement Account (IRA) he inherited from his mother upon her death as exempt property from the bankruptcy estate. The Trustee of the case objected to Debtor’s claim of exemption. The United States Bankruptcy Court for the District of Montana certified a question to the Supreme Court regarding whether a Debtor may claim an exemption in an IRA pursuant to Mont. Code Ann. 25-13-608(1)(e). The Supreme Court answered the question in the negative, holding that, under Montana’s liberal construction of exemptions, a debtor may not claim an exemption to an inherited IRA under section 25-13-608(1)(e). View "In re Golz" on Justia Law

Todd Kiser initiated this action by filing a form complaint against Noel Kiser and Marie McDowell alleging that Noel and Marie owed him a sum of money arising out of an asserted agreement among them regarding their father’s nursing care and cremation costs. The small claims court entered judgment in favor of Todd. Noel and Marie appealed the judgment to the district court. The district court dismissed the appeal, reasoning that the brief filed by Noel and Marie had been untimely filed. The Supreme Court reversed, holding that the district court erred in dismissing the appeal on the basis of the briefing deadline imposed in the inapplicable Municipal Court Appellate Rules. Remanded to the district court for reinstatement of Noel and Marie’s appeal and for further proceedings. View "Kiser v. Kiser" on Justia Law