Justia Montana Supreme Court Opinion Summaries

Defendant pled guilty to felony criminal endangerment of the mother of his young children. The district court sentenced Defendant to the custody of the Department of Corrections for five years with two of those suspended and conditions of probation including the condition that Defendant not have contact with the victim or his two children unless the contact was voluntarily initiated by the victim and the children and approved by the probation and parole officer. The Supreme Court affirmed, holding that the condition did not represent an abuse of the district court’s discretion. View "State v. Robertson" on Justia Law

After five years of employment with Employer, Employee was terminated. Employee brought this action against Employer alleging wrongful discharge and seeking damages. After a hearing, the district court granted summary judgment in favor of Employer, concluding that substantial undisputed evidence supported Employer’s claim of good cause for termination. The Supreme Court affirmed, holding that the district court did not err in ruling as a matter of law that good cause existed for Employee’s discharge from employment under Mont. Code Ann. 39-2-904(1)(b) and that summary judgment in favor of Employer was appropriate. View "Davis v. Dep’t of Pub. Health & Human Servs." on Justia Law

After a jury trial, Defendant was convicted of three counts of assault on a peace officer. Defendant filed a motion for a new trial, alleging improper contact between the judge and the jury while the jury was deliberating. Specifically, Defendant argued that the judge committed reversible error by asking the jury about the status of its deliberations outside of the presence of Defendant and the public. The district court denied the motion. The Supreme Court affirmed, holding (1) the violation of Defendant’s right to presence was not reversible error; and (2) the closure did not impair the fairness of Defendant’s trial. View "State v. Northcutt" on Justia Law

In 1995, Defendant pled guilty to forgery and bail jumping. Defendant’s original sentence was a twenty-year commitment to the Department of Corrections (DOC) with ten years suspended. The district court’s sentence made Defendant subject to various conditions during the suspended portion of the sentence. In 1996, Defendant escaped from jail. In 2011, the Adult Probation and Parole Bureau learned that Defendant was serving a supervisory sentence in Oregon. The State subsequently filed a petition to revoke Defendant’s suspended sentence for violating the conditions of his suspended sentence. The district court revoked the suspended portion of Defendant’s sentence and sentenced Defendant to ten years in Montana State Prison (MSP). The Supreme Court vacated Defendant’s sentence, holding (1) the petition to revoke Defendant’s suspended sentence was properly filed before the period of suspension began; (2) Defendant was not denied due process by not signing the conditions of his probation, and the district court’s refusal to admit the documents related to that defense was harmless; but (3) the district court erred in sentencing Defendant to MSP rather than the DOC and in failing to give Defendant credit for time served while he was incarcerated awaiting extradition to Montana. Remanded. View "State v. Graves" on Justia Law

Prior to July 2011, St. Peter’s Hospital’s Medical Staff granted privileges to qualified, non-employee radiologists, including the physicians of Montana Interventional and Diagnostic Radiology Specialists, PLLC (MIDRS), a professional limited liability company whose members are engaged in the practice of radiology. In July 2011, the Hospital closed its radiology department to all non-employee physicians regardless of qualification. MIDRS brought this action against the Hospital, alleging intentional interference with prospective advantage and unfair trade practices. The district court granted the Hospital’s motion for judgment on the pleadings and dismissed the complaint as untimely, concluding that MIDRS filed its complaint outside of the applicable statutes of limitation. The Supreme Court reversed, holding that the accrual of MIDRS’ claims could not be determined from the pleadings alone and that further development of the record was necessary. View "Mont. Interventional & Diagnostic Radiology Specialists, PPLC v. St. Peter’s Hosp." on Justia Law

In 2011, Debora Smith filed a petition for dissolution of her marriage to Glenn Smith. After a trial, the district court entered an order dissolving the parties’ marriage and distributing their marital estate. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the district court abused its discretion by ordering the division of Glenn’s social security benefits; (2) the district court abused its discretion in determining the maintenance award to Debora; (3) because questions of equitable distribution and spousal maintenance were intertwined, the district court may reconsider these issues and the calculation of the equalization payment to the extent necessary to enter a revised decree; and (4) the district court did not abuse its discretion by awarding Debora a 2006 SeaDoo watercraft vehicle. View "Smith v. Smith" on Justia Law

The parties in this case owned adjoining parcels of land adjacent to Rock Creek in Carbon County. Plaintiffs brought this action in 2008, alleging that Defendants interfered with Plaintiffs’ water right by erecting a pond, engaging in significant construction activities, and placing rip-rap and fill in wet areas without protecting the flow of water onto Plaintiffs’ property. After a bench trial, the district court granted judgment in favor of Defendants, concluding that Defendants had not interfered with Plaintiffs’ water right, that Defendants could only prove their case through expert testimony, which the court previously excluded, and that Defendants’ activities on Plaintiffs' property did not unreasonably interfere with Plaintiffs’ water rights. The Supreme Court reversed the district court’s judgment in favor of Defendants and the award of attorney fees against Plaintiffs, holding (1) the district court erred in granting Defendants’ motion in limine to exclude Plaintiffs’ expert witnesses from testifying at trial; and (2) because the experts were wrongfully excluded, the result of the trial was tainted and must be reversed. View "Sharbono v. Cole" on Justia Law

Defendant pleaded nolo contendere to robbery, assault with a weapon, and burglary. The district court sentenced Defendant to prison and imposed numerous conditions on his partially suspended term. In the sentencing order, the district court specified that Defendant’s firearms in the possession of the sheriff were to be sold and applied to the cost of Defendant’s incarceration in a county detention center. The Supreme Court reversed, holding that the district court did not have the authority to order the sale of Defendant’s firearms and to apply the proceeds against Defendant’s incarceration costs. View "State v. Lee" on Justia Law

The town of Opportunity is a rural community east of a former copper smelter operated by the Anaconda Company. Between 1884 and 1980, the smelter emitted smoke and fumes containing arsenic and other toxic materials, and particles of these materials settled on the surrounding lands. In 2008, Appellants, property owners in and around the town, filed this action seeking damages for the cost of restoring their properties to their original state. Atlantic Richfield Company (ARCO), the successor in interest to the Anaconda Company, moved for summary judgment on statute of limitations grounds. The district court granted summary judgment for ARCO on all claims. The Supreme Court affirmed in part and reversed and remanded in part, holding (1) application of the continuing tort doctrine based on environmental contamination does not require evidence of that the contamination is migrating; (2) Appellants’ claims of continuing nuisance and trespass are not time-barred if a finder of fact determines that the contamination is reasonably abatable; (3) the district court properly granted summary judgment to ARCO on Appellants’ claims of unjust enrichment and constructive fraud; and (4) the district court applied the incorrect statute of limitations to Appellants’ claim of wrongful occupation. View "Christian v. Atlantic Richfield Co." on Justia Law

Insurer issued an insurance policy to Insured covering his truck. When Insured did not pay the premium amount to renew his policy by the deadline of May 1, Insurer sent Insured a notice of expiration and cancellation summary but offered to reinstate Insured’s coverage without interruption if he would pay the premium by May 18. Insurer wrote a check that was not received by Insured until May 24. On May 14, After Insurer sent the notice of expiration and before Insured’s payment had arrived, Insured was involved in an automobile accident resulting in the total loss of his truck. Insurer denied coverage for the accident, and Insured filed a complaint alleging breach of contract and requesting declaratory relief. The district court determined that there was no automobile insurance policy in effect at the time of Insured’s accident, and therefore, Insurer had no contractual duty to indemnify Insured for his losses. The Supreme Court affirmed, holding that the district court did not err by concluding that Insurer properly cancelled the insurance policy for nonpayment of the renewal premium. View "Finn v. Dakota Fire Ins. Co." on Justia Law