Justia Montana Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of felony robbery. Defendant appealed, arguing, among other things, that he was subject to pretrial punishment in violation of his due process rights as a result of a district court order issued following a “critical stage” hearing at which he was not present. The Supreme Court affirmed the conviction, holding (1) Defendant’s pretrial punishment claim was raised for the first time on appeal and is therefore dismissed; (2) sufficient evidence was presented at trial to support Defendant’s conviction; and (3) the district court did not err in ruling that Defendant’s reliance on the affirmative defense of justifiable use of force required Defendant to testify at his trial. View "State v. R.S.A." on Justia Law

When Donna Anderson failed to pay taxes assessed for her property, the Carbon County Treasurer (Treasurer) conducted a tax lien sale for the property. The County acquired the property when the tax lien failed to sell. Following Anderson’s failure to pay the taxes with a two-week period, Zinvest, LLC paid the taxes and costs to purchase the lien from the County. The Treasurer issued an assignment of tax sale certificate to Zinvest and notified Anderson of the transaction. Zinvest subsequently obtained a property title guarantee. After the redemption period ended and Anderson had failed to pay the delinquent taxes, Zinvest applied for a tax deed, which the Treasurer issued. Zinvest recorded the deed and initiated a quiet title action. Zinvest and Anderson both moved for summary judgment contesting whether the Treasurer had complied with the requirements of the tax deed statutes. After originally granting Zinvest’s motion, the district court vacated its judgment and granted Anderson’s motion for summary judgment. The Supreme Court affirmed, holding that the district court correctly entered judgment in favor of Anderson because the documents used in this transaction contained a number of errors that violated the tax deed statutes and created confusion in the property titling process. View "Zinvest, LLC v. Anderson" on Justia Law

At issue in this case was an easement created by a 1977 real estate Easement Agreement (Agreement). Pursuant to the Agreement, the Grantees installed a pipeline on the Grantor’s property. A new ditch was dug to connect the pipeline to an irrigation ditch known as “Enterprise Ditch.” Defendants eventually acquired the Grantor’s property, and Plaintiff acquired the Grantee’s property. Plaintiff asserted that it was a successor in interest and therefore enjoyed the benefits of the Agreement. Defendants contended that Plaintiff was an assignee under the Agreement and, therefore, that consent was needed for assignment of any rights. The district court granted partial summary judgment to Defendants. The Supreme Court affirmed, holding that the district court (1) was correct in concluding that the easement was in gross, rather than appurtenant; (2) did not err in determining that the Agreement required grantor’s consent to assignment and that Plaintiff had no rights under the Agreement absent a valid consent to assignment from Defendants; and (3) correctly found that Plaintiff did not establish a prescriptive easement in Enterprise Ditch. View "Bos Terra, LP v. Beers" on Justia Law

Jim Hein hired John Sott and his companies (collectively, Sott) to construct a log home for him and then, later, an addition to the home. Hein eventually filed a complaint against Sott alleging negligence, negligent misrepresentation, and violation of the Montana Consumer Protection Act (CPA). The district court dismissed Hein’s claims related to the construction of the home as time-barred and then dismissed Hein’s remaining claims on the ground that Hein had not provided expert evidence that Sott’s work was either defective or caused Hein damage. The Supreme Court affirmed, holding that the district court (1) correctly determined that Hein’s negligence and negligent misrepresentation claims arising from water damage to his home were barred by the statute of repose; (2) did not err in determining that Hein’s CPA claims for damages arising two years before Hein filed his complaint were barred by the statute of limitations but erred in determining that Hein’s CPA claims based on alleged deceptive acts or practices in the performance of repairs occurring less than two years before Hein filed his complaint were barred by the statute of limitations; and (3) erred in determining that Hein was required to produce expert evidence for his CPA claim arising from Sott’s billing for work on the addition. View "Hein v. Sott" on Justia Law

After a jury trial, the justice court convicted Defendant of the offense of acting as an outfitter without a license. The Supreme Court reversed and remanded for a new trial, holding that the justice court (1) abused its discretion in denying Defendant’s challenge for cause of a prospective juror; (2) the justice court did not abuse its discretion when it granted the State’s motion in limine prohibiting Defendant from presenting evidence to the jury regarding the circumstances surrounding suspension of his outfitters license; and (3) the justice court did not abuse its discretion in sentencing Defendant, as the sentence was legal under the applicable sentencing statutes. View "State v. Kebble" on Justia Law

Defendant was found guilty of two counts of deliberate homicide. The presentence investigation report (PSI) recommended that Defendant be given two consecutive 100-year sentences and that the cost of appointed counsel be assigned to Defendant. The district court accepted the PSI recommendations. Defendant objected to the cost of appointed counsel, arguing that she was indigent. The Supreme Court affirmed, holding (1) the district court adequately questioned Defendant regarding her ability to pay the costs of appointed counsel; (2) the district court determined that Defendant had or would have the ability to pay the costs of appointed counsel; (3) Defendant’s constitutional right to a jury trial was not undermined by requiring her to pay the costs of appointed counsel; and (4) the absence of an itemization of costs of appointed counsel was not properly preserved for appeal. View "State v. Gable" on Justia Law

While in the course and scope of his employment with Employer, Plaintiff suffered serious injuries. Plaintiff recovered workers’ compensation insurance benefits in the amount of $207,147. Plaintiff subsequently brought this action against Employer, alleging that Employer was an uninsured employer under the Workers’ Compensation Act at the time of the accident. The district court granted summary judgment in favor of Employer, concluding that Employer was an insured employer under the Act and was therefore entitled to tort immunity pursuant to Mont. Code Ann. 39-71-411. The Supreme Court affirmed, holding that the district court did not err in concluding that Employer was an insured employer under the Act and therefore was entitled to tort immunity. View "Stokes v. Golden Triangle, Inc." on Justia Law

Plaintiffs were laborers who worked on the construction and rehabilitation of two multi-family housing projects. Plaintiffs filed this wage and hour action and moved for certification of a proposed class including all laborers, tradesmen, and craftsmen who worked for Monfric, Inc., the general contractor, or its subcontractors and who were not paid prevailing wages during the construction and rehabilitation of the housing projects. The district court denied Plaintiffs’ motion for class certification, concluding that Plaintiffs failed to demonstrate numerosity of the proposed class. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it concluded that Plaintiffs failed to establish that their proposed class was so numerous as to make joinder of its remaining members in a single action impracticable. View "Morrow v. Monfric" on Justia Law

Julie filed with the district court a dissolution petition that included a marital asset distribution proposal in which William would be awarded ownership of the couple’s real property on Hobson Street in Butte, Montana. On March 16, 2012, the district court held a final dissolution hearing at which William made certain statements regarding the real property at issue. The court largely adopted Julie’s proposed distribution of assets and, on April 3, 2012, issued its final decree of dissolution. The district court denied William’s motion for relief from judgment. The Supreme Court reversed. On remand, the district court concluded that William’s 2012 statements regarding the appraisal values of the Hobson Street house constituted judicial admissions and, therefore, all evidence related to the house’s condition obtained after the March 16, 2012 hearing was properly excluded. The Supreme Court reversed, holding (1) the district court erred in ruling that William’s statements made during the March 2012 dissolution hearing constituted judicial admissions; and (2) the district court erred in precluding William from presenting evidence relating to the value of the real property at issue based upon these alleged judicial admissions. Remanded so as to allow the parties to present their respective evidence and arguments with respect to the Hobson Street property. View "In re Marriage of Steyh" on Justia Law

The Butte Local Development Corporation (BLDC) filed a complaint against Masters Group International alleging that Masters had failed to pay its obligations under a loan agreement, as modified. Masters filed a third-party complaint against Comerica Bank, alleging, among other claims, that Comerica breached a Forbearance Agreement. A jury found Masters liable to BLDC for $275,251 and found Comerica liable to Masters for a total of $52,037,593, which included punitive damages. The Supreme Court reversed the judgment against Comerica, holding (1) the district court did not abuse its discretion by implicitly denying Comerica’s severance motion; (2) the district court erred in applying Montana law despite the existence of a contractual Michigan choice-of-law provision, and had the district court properly applied Michigan law, Masters’ tort claims would not have been permitted to go to the jury as stand-alone tort claims, and the jury’s award of $10.5 million in punitive damages must be vacated; (3) the law of both Montana and Michigan supports the district court’s decision to submit the companion questions of contract formation and waiver to the jury; and (4) the district court abused its discretion by allowing Troubled Asset Relief Program (TARP) evidence to be presented to the jury. Remanded for a new trial on the contract claims applying Michigan law. View "Masters Group Int’l v. Comerica Bank" on Justia Law