Justia Montana Supreme Court Opinion Summaries

At dispute in this case was a home inspection Don Hall performed of a home purchased by Gregory Hall. Gregory brought this action against Don, the seller of the home, and two real estate brokers, alleging that Defendants failed to disclose material defects in the property. The district court entered summary judgment in favor of all defendants with the exception of Don on the grounds that Gregory received a disclosure statement and had imputed knowledge of the defects. The district court entered default judgment against Don after determining that Don had not filed a sufficient answer to the complaint. After a writ of execution was issued, Don requested that the default judgment be set aside and later sought to claim exemptions. The district court denied the requests. The Supreme Court reversed the order of the district court striking Don’s motion to set aside default judgment, holding that, under the circumstances of this case and in the interests of justice, Don was entitled to relief from judgment. Remanded. View "Hall v. Hall" on Justia Law

After a bench trial, Defendant was found guilty of driving under the influence (DUI) per se, fourth-offense, a felony. Before sentencing, Defendant moved to dismiss the felony DUI charge or, alternatively, to amend the charge to a misdemeanor, alleging in her supporting affidavit that her 2003 DUI conviction was constitutionally inform because she was not told that she had a right to an attorney, and therefore, the 2003 DUI could not be used to enhance her current DUI charge to a felony. The district court denied Defendant’s motion to dismiss after an evidentiary hearing. The Supreme Court affirmed, holding that the district court did not err in concluding that Defendant could not submit an affidavit without being subject to cross-examination as to the affidavit’s contents, and therefore, Defendant suffered no prejudice from the district court compelling her to testify. View "State v. Johnson" on Justia Law

The predecessor in interest to dck Worldwide Holdings, Inc. (together, Worldwide) entered into a contract with Spanish Peaks Lodge, LLC to serve as the general contractor for for a construction project. Spanish Peaks procured financing with the predecessor in interest to CH SP Acquisition LLC (together, CHSP), and CHSP took a mortgage against Spanish Peaks’ development property. When Spanish Peaks breached the parties’ contract Worldwide filed a construction lien claiming the unpaid portion of the contractor’s fee and the amount Worldwide owed to a subcontractor, Allied Steel, Inc. Allied Steel also filed a construction lien for unpaid services and materials. Allied Steel, Spanish Peaks, and Worldwide entered into a settlement agreement, and CHSP and Worldwide reached a partial settlement under which Worldwide released all of its claims against CHSP except for those at issue on appeal. The district court concluded that the unpaid portion of the contractor’s fee and the subcontractor’s fee were both secured by Worldwide in the amount of $5,476,277 and $661,767, respectively, and lienable as a matter of law. The Supreme Court reversed, holding that the district court (1) erred by concluding that the unpaid portion of the contractor’s fee was lienable; and (2) erred by concluding that the subcontractor’s fee remained alienable after Allied Steel settled its claim. View "dck Worldwide Holdings Inc. v. CH SP Acquisition LLC" on Justia Law

In 2011, the Legislature enacted the Montana 24/7 Sobriety Program Act, which permits a court, as a condition of pretrial release of an individual accused of a drunk driving offense, to require the individual to submit to twice-daily alcohol breath tests. The justice court in this case ordered Defendant to participate in the 24/7 Sobriety Program as a condition of his release on bond. Defendant missed three tests while enrolled in the program and was charged with criminal contempt for the missed tests. Defendant pleaded nolo contendere to the contempt charges. Defendant appealed to the district court and moved to dismiss the contempt charges. The district court granted the motion and concluded that the 24/7 Program was unconstitutional. The Supreme Court affirmed in part and reversed in part, holding (1) the breath tests required by the 24/7 Sobriety Program constitute a search, but the search does not violate proscriptions against unreasonable searches; and (2) court-ordered enrollment in the 24/7 Program does not impose pretrial punishment or violate provisions against excessive bail, but the court is required to condition pretrial release on participation in the program only after conducting an individualized assessment to determine if each defendant is an appropriate candidate for the program. Remanded. View "State v. Spady" on Justia Law

At dispute in this case was the Crow Water Compact - an agreement among the United States, the Crow Tribe, and the State - which recognizes a Tribal Water Right of the Crow Tribe and its members in a number of sources of water that abut or cross the Crow Indian Reservation in Montana. Here, a group of Crow tribal member Allottees - persons who hold interests in parcels of former Tribal land mostly created by the General Allotment Act - objected to the Compact in the Water Court, claiming that the United States breached its fiduciary duties to the Allottees by failing to protect their water rights in the Compact and failing to adequately represent them in Compact proceedings. The Water Court dismissed the Allottees’ objections. The Supreme Court affirmed, holding that the Water Court (1) applied the proper legal standard of review in dismissing the Allottees’ objections; (2) did not exceed its jurisdiction by dismissing the Allottees’ action rather than staying consideration of the Compact pending resolution of the Allottees’ action in federal district court; and (3) did not err in determining that the Allottees have rights to a share of the Crow Tribal Water Right and that the United States adequately represented the Allottees during the Compact negotiations. View "In re Crow Water Compact" on Justia Law

Robert and Tina George filed a complaint against Curtis and Jean Bowler arising from injuries Robert sustained on Defendants’ property. Robert was employed as a warehouse manager for Carpets Plus when he was injured. Robert filed suit against the Bowlers in their individual capacities as the property owners and general contractors of the warehouse alleging that the Bowlers failed to provide a safe place to work in violation of the Montana Occupational Safety and Health Act. The Bowlers pleaded the Workers’ Compensation Act’s (WCA’s) exclusivity provision as an affirmative defense, arguing that, as corporate directors, they were co-employees of Robert at Carpets Plus and were thus exempt from suit for Robert’s workplace injuries. The district court concluded that the Bowlers were immune from suit under the WCA’s exclusivity provision because they were acting in their capacities as corporate officers of Carpets Plus at the time they were alleged to have failed to provide a Carpets Plus employee with a safe place to work. The Supreme Court affirmed, holding that because the Bowlers were acting within the course and scope of their employment for Carpets Plus at all relevant times, they were protected from suit by the exclusivity provision of the WCA. View "George v. Bowler" on Justia Law

In 2013, the Montana Commissioner of Political Practices (COPP) issued a decision finding sufficient evidence that Ronald Murray had violated Montana’s campaign practices laws during the 2010 primary election and that civil adjudication of the violations was warranted. COPP forwarded the sufficiency decision to the Lewis and Clark County Attorney for consideration. Murray filed an action for declaratory relief in the Gallatin County District Court seeking a determination that Jonathan Motl, in his capacity as the COPP, violated Mont. Code Ann. 13-37-124 by referring the sufficiency decision to the Lewis and Clark County Attorney rather than the Gallatin County Attorney. Thereafter, the COPP filed a complaint against Murray in the Lewis and Clark County District Court (the “enforcement action”) alleging the various campaign finance and practice violations in the sufficiency decision. The district court in Gallatin County dismissed Murray’s declaratory relief action for lack of a justiciable controversy. The Supreme Court affirmed, holding that the district court did not abuse its discretion in dismissing Murray’s declaratory relief action, as Murray had an adequate alternative remedy available to him in that he may assert in the enforcement action issues sought to be declared as a defense in the declaratory action. View "Murray v. Motl" on Justia Law

In 2013, Defendant was charged with five counts of felony criminal endangerment and two counts of felony assault on a peace officer. Defendant later pleaded guilty to the charges. In 2014, the State filed a motion asking the court to set a sentencing hearing. Defendant filed a motion to dismiss for lack of a speedy trial. The district court denied Defendant’s motion and sentenced him to a total of thirty years imprisonment. Defendant appealed, arguing that his right to a speedy trial was violated by pre-trial and pre-sentencing delays. The Supreme Court affirmed, holding (1) the State did not violate Defendant’s right to a speedy trial through excessive pre-trial delay; and (2) although the sentencing delay was perhaps excessive, the State did not violate Defendant’s due process rights through sentencing delay. View "State v. Maloney" on Justia Law

Farmers Cooperative Canal Company (FCCC) was incorporated in 1897 for the purpose of appropriating, transporting, and using irrigation water from the Teton River. FCCC acquired two water rights with priority dates of 1895 and 1897. FCCC constructed two reservoirs, Harvey Lake Reservoir in 1913 and Farmers Reservoir in 1942. Using its reservoirs, FCCC began to store portions of the water diverted to it during the year, which allowed it to release water as needed throughout the year. Based on its rights and these practices, FCCC filed statements of claim for its 1895 and 1897 rights, claiming use of the two reservoirs as part of those rights. Teton Cooperative Reservoir Company (TCRC) objected to FCCC’s claims, arguing that FCCC’s reservoirs were not part of its 1895 or 1897 rights and, instead, were new, independent appropriations not entitled to the priority dates of either claim. The Water Court concluded that the reservoirs could be used as part of the 1895 and 1897 rights because they did not expand the period of diversion, volume, or flow rate of those rights. The Supreme Court affirmed, holding that the Water Court correctly concluded that FCCC’s reservoirs did not expand FCCC’s water rights and that the reservoirs could be included in FCCC’s 1895 and 1897 rights. View "Teton Coop. Reservoir Co. v. Farmer Coop. Canal Co." on Justia Law

After a hearing, the district court committed E.A.L., who had been diagnosed with schizophrenia and antisocial personality traits, to the Montana State Hospital for ninety days. The Supreme Court affirmed, holding (1) the district court’s finding that E.A.L. posed an imminent threat of harm to himself or others was not clearly erroneous; (2) even if the district court erred by basing findings of fact on statements made in the State’s petition for commitment, the error was harmless; and (3) there was a sufficient basis for the district court to commit E.A.L. View "In re E.A.L." on Justia Law