Justia Montana Supreme Court Opinion Summaries

James Edward Meuret II was sentenced to two years with the Department of Corrections, all time suspended, for criminal possession of dangerous drugs. Meuret appealed, arguing that his attorney at the District Court rendered ineffective assistance of counsel (IAC) and requested the court to vacate the judgment and allow him to withdraw his plea of no contest. The case arose from a traffic stop on July 22, 2019, where police found methamphetamine and paraphernalia in Meuret's vehicle after arresting him on an outstanding warrant.Initially, Meuret was represented by Casey Moore from the Office of State Public Defender (OPD). Meuret pleaded not guilty to both charges but reserved the right to file a motion to suppress evidence, which was never filed. On the morning of his trial, Meuret decided to enter a plea of nolo contendere to the drug possession charge in exchange for the dismissal of the paraphernalia charge. He acknowledged waiving his constitutional rights and expressed no issues with his counsel. Later, Meuret considered withdrawing his plea, but no motion was filed by the deadline. A new attorney, Mark Epperson, was assigned and filed a motion to suppress evidence instead of a motion to withdraw the plea, which the District Court rejected as untimely.The Montana Supreme Court reviewed the case and applied the two-pronged test from Strickland v. Washington to assess IAC claims. The court found that the record did not sufficiently demonstrate the reasons behind Moore's and Epperson's actions. The court noted that IAC claims require a developed record, which was lacking in this case. Consequently, the court affirmed the District Court's judgment but allowed Meuret the option to pursue his IAC claims through a petition for postconviction relief. View "State v. Meuret" on Justia Law

In January 2013, Christopher Michael Kepler drove the wrong way on Interstate 90, causing a head-on collision that resulted in the death of Patricia Graves and injuries to her husband, Benjamin Graves. Kepler, who is schizophrenic, was found to have marijuana and methamphetamine in his system at the time. He was charged with deliberate homicide, negligent homicide, felony assault with a weapon, felony criminal endangerment, and driving on a suspended license. Kepler pleaded guilty to negligent homicide and two counts of criminal endangerment in exchange for the dismissal of other charges. He was sentenced to 40 years with 20 years suspended, under the supervision of the Montana Department of Health and Human Services (DPHHS).The District Court of the Third Judicial District initially committed Kepler to the Montana State Hospital for evaluation. Later, he was placed on supervised release under specific conditions, including abstaining from marijuana. In 2021, the State filed a petition to revoke Kepler’s suspended sentence, citing violations such as absconding to Arizona, failing to reside at his approved residence, and not maintaining contact with his probation officer. The District Court found that Kepler had violated his release conditions and posed a danger to himself and others due to his mental illness and substance abuse.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s decision to revoke Kepler’s suspended sentence. The Court held that the revocation was supported by substantial evidence, including Kepler’s failure to follow treatment recommendations and his continued use of marijuana. The Court concluded that Kepler’s actions made him a danger to himself and others, justifying the revocation of his conditional release. View "State v. Kepler" on Justia Law

The case involves a dispute over a bridge constructed by John Dimar over the Clearwater River to provide better access to a subdivision where all parties reside. Dimar built the bridge at his own expense and later sought to restrict access to it, prompting neighboring lot owners to file a lawsuit for declaratory relief to access the bridge and to avoid sharing in the construction costs. The plaintiffs argued that the 1994 Easement Agreement granted them access rights without the obligation to share in the construction costs.The Fourth Judicial District Court of Missoula County granted summary judgment in favor of the plaintiffs, ruling that the 1994 Easement Agreement allowed them access to the bridge and that they were not responsible for the construction costs. The court also issued a preliminary injunction requiring Dimar to provide keys to the bridge to the plaintiffs and emergency responders. Dimar appealed, arguing that the easement did not cover the bridge and that the plaintiffs should share in the construction costs.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decision. The court held that the 1994 Easement Agreement was clear and unambiguous in granting the plaintiffs access to the bridge. The court also found that Dimar was estopped from contesting the validity of the easement due to his previous litigation in the River Watch case, where he had argued for the easement's validity. Additionally, the court ruled that the plaintiffs were not unjustly enriched by using the bridge without sharing in the construction costs, as the 1994 Easement Agreement explicitly stated that any improvements made without a prior written agreement would be at the expense of the improver. View "Beck v. Dimar" on Justia Law

Frank Hallberg rented an apartment from Steve Schmitz in Helena. Schmitz sent Hallberg a 30-day notice to vacate, and upon inspecting the apartment on July 12, 2021, Schmitz found 20-30 holes in the walls. Schmitz took photos and called the police, who also documented the damage. Hallberg was charged with Criminal Mischief Damage to Rental Property.The Municipal Court scheduled an omnibus hearing, which Hallberg attended without his attorney. The hearing was rescheduled multiple times, and neither Hallberg nor his attorney appeared at the final rescheduled hearing. Consequently, the court set a bench trial for April 15, 2022, which was held on December 14, 2022. The court found Hallberg guilty and ordered him to pay $1,226.45 in restitution. Hallberg appealed to the District Court, arguing he was denied a jury trial, the evidence was insufficient, and the restitution amount was incorrect. The District Court affirmed the Municipal Court's decision, stating Hallberg waived his right to a jury trial by not objecting and that the restitution amount was supported by Schmitz’s testimony.The Supreme Court of the State of Montana reviewed the case. It held that Hallberg waived his right to a jury trial by failing to object to the bench trial. The court found sufficient evidence to support Hallberg’s conviction based on the testimonies and photographic evidence presented. The court also upheld the restitution amount, finding it was not clearly erroneous as it was supported by Schmitz’s testimony regarding repair costs. The Supreme Court affirmed the District Court’s decision. View "City of Helena v. Hallberg" on Justia Law

In August 2022, Cole Levine moved from New Mexico to Missoula, Montana, to attend law school. On August 18, 2022, a woman identified as M.H. was sexually assaulted in an alley. During the incident, the assailant took M.H.'s phone but dropped another phone, which was later identified as belonging to Levine. Following an investigation, Levine was charged with several offenses, including attempted sexual intercourse without consent and aggravated assault. On October 3, 2022, the District Court issued a search warrant to Verizon Wireless for data related to Levine's phone, which was stored on servers outside Montana.Levine filed a motion to suppress the data obtained from the warrant, arguing it was an illegal extraterritorial warrant. The Fourth Judicial District Court agreed, ruling that Montana courts did not have jurisdiction to issue such a warrant to an out-of-state entity. The court relied on the reasoning from United States v. Webb and found that the good-faith exception to the exclusionary rule did not apply, declaring the warrant void ab initio. Consequently, the court granted Levine's motion to suppress the evidence obtained from the warrant.The Supreme Court of the State of Montana reviewed the case and reversed the District Court's decision. The Supreme Court held that the Secure Communications Act (SCA) grants Montana district courts jurisdiction to issue search warrants for electronic communications stored by out-of-state third parties. Additionally, Montana law under § 46-5-605(3)(a), MCA, provides an independent basis for such jurisdiction. The Supreme Court concluded that the District Court had jurisdiction to issue the search warrant and erred in granting Levine's motion to suppress. The case was remanded for continuation of proceedings. View "State v. Levine" on Justia Law

Law enforcement responded to the defendant's home after his ex-girlfriend reported that he had threatened suicide during a phone call. The officers, aware of his history of alcohol abuse and mental health issues, entered his home without a warrant after he failed to respond to their attempts to contact him. Inside, an officer shot the defendant, believing he was armed. The defendant was charged with Assault on a Peace Officer.The District Court of the Third Judicial District denied the defendant's pretrial motions to dismiss and suppress evidence obtained from the warrantless entry. The court also denied his motion for a new trial based on an alleged Brady violation, where the defendant claimed the State failed to disclose that the officer who shot him had been shot at in a prior incident. The jury found the defendant guilty.The Supreme Court of Montana reviewed the case and affirmed the lower court's decisions. The court held that the officers' warrantless entry was justified under the community caretaker doctrine, given the exigent circumstances of a potential suicide. The court also found no Brady violation, as the undisclosed evidence about the officer's prior incident would not have changed the trial's outcome. The court concluded that the officers acted reasonably in their entry and subsequent actions, and the defendant's conviction was upheld. View "State v. Case" on Justia Law

Anthony Cordero, a student at Montana State University (MSU) during the Spring 2020 semester, sued MSU for prorated reimbursement of his tuition and fees after the university transitioned to online learning due to the COVID-19 pandemic. Cordero claimed that MSU breached an express contract to provide in-person education and services. He also asserted claims for breach of implied contract, unjust enrichment, due process violation, violation of the takings clause, and inverse condemnation.The First Judicial District Court of Lewis and Clark County dismissed four of Cordero’s six claims, including the implied contract and unjust enrichment claims, under M. R. Civ. P. 12(b)(6). The court granted summary judgment in favor of MSU on the remaining claims, including the express contract claim, and denied Cordero’s motion to certify the case as a class action. The court found that Cordero did not identify a specific, bargained-for promise by MSU to provide in-person education and that he had no compensable property interest in the tuition and fees paid.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decisions. The court held that there was an express contract between Cordero and MSU, but it did not include a specific promise to provide in-person education. The court found that MSU had the right to change its regulations and policies, including transitioning to online learning during emergencies. The court also affirmed the dismissal of the implied contract and unjust enrichment claims, noting that an implied contract cannot exist when an express contract is present. The court concluded that MSU did not breach its contractual duties regarding tuition and fees, as it maintained campus facilities and services to the extent possible during the pandemic. View "Cordero v. Montana State University" on Justia Law

A group of Bozeman residents challenged a zoning provision within the City’s Unified Development Code (UDC), claiming they were not given sufficient notice regarding the City’s consideration of an amendment. The amendment, part of a general replacement of the UDC adopted in 2018, reclassified Greek housing into a new “group living” category, allowing fraternities and sororities in certain residential zones. The residents, who began experiencing disturbances from a nearby fraternity house in early 2022, filed a complaint against the City in October 2022, asserting that the notice provided for the zoning change was insufficient.The Eighteenth Judicial District Court of Gallatin County granted summary judgment in favor of the residents, declaring the Greek housing reclassification void ab initio due to insufficient notice. The court reasoned that the City’s notice did not adequately inform the public about the specific change and its impact on the community. The court also held that the residents’ claims were not time-barred under § 2-3-114(1), MCA, because the provision was void from the beginning, and thus the statute of limitations did not apply.The Supreme Court of the State of Montana reversed the District Court’s decision. The Supreme Court held that § 2-3-114(1), MCA, which requires challenges to agency decisions to be filed within 30 days of when the person learns or reasonably should have learned of the decision, applied to this case. The Court concluded that the residents’ action was untimely because they filed their complaint more than 30 days after they became aware of the zoning change in April 2022. The Supreme Court remanded the case for entry of judgment in favor of the City. View "Johnson v. City of Bozeman" on Justia Law

In 2003, Joshua Duane Wolfblack was charged with burglary and theft in Flathead County, Montana. He pled guilty to felony theft, and the burglary charge was dismissed. He received a ten-year sentence with five years suspended. In 2010, Wolfblack was charged with felony sexual intercourse without consent in Lewis and Clark County, pled guilty, and received another ten-year sentence with five years suspended. Subsequently, his 2003 theft sentence was revoked, and he was given a five-year suspended sentence to run consecutively to his 2010 sentence.The District Court of the Eleventh Judicial District, Flathead County, revoked Wolfblack’s 2010 theft sentence in 2022, imposing a five-year term. Wolfblack appealed, arguing the court lacked authority to impose a consecutive sentence upon revocation. The District Court had denied his motion to dismiss, reasoning that the sentences were presumed to run consecutively under Montana law.The Supreme Court of the State of Montana reviewed the case. The court held that under § 46-18-203, MCA, the District Court did not have the authority to impose a consecutive sentence upon revocation that extended the original sentence. The court emphasized that sentencing upon revocation is governed by § 46-18-203, MCA, not § 46-18-401, MCA, which applies to initial sentencing. The court found that the District Court’s imposition of a consecutive sentence violated the statutory limits, as it effectively increased the term of the original sentence. Consequently, the Supreme Court reversed the District Court’s judgment, vacated the sentence, and dismissed the proceedings. View "State v. Wolfblack" on Justia Law

Robert Frisk owns property at 1196 Swan Hill Drive, Bigfork, Montana, and John and Lori Thomas own the neighboring property at 1194 Swan Hill Drive. The properties share a common driveway and a water well located on Frisk’s property. Disputes arose over the width of the easement for the driveway and access to the water well, leading Frisk to file a lawsuit seeking a declaration of an easement and an injunction against Thomas. Thomas counterclaimed for breach of contract regarding the water well agreement and trespass due to Frisk’s fence and house encroaching on their property.The Montana Eleventh Judicial District Court granted Frisk a prescriptive easement over 15 feet of the existing roadway and an equitable easement for the encroaching portion of Thomas’s property. The court dismissed Thomas’s breach of contract claims but affirmed his right to access the water well, imposing additional restrictions on this access due to the parties' animosity. Thomas appealed the decision.The Supreme Court of the State of Montana reviewed the case and found that Montana law does not recognize the creation of an equitable easement. The court held that Frisk must remove his fence and gate from Thomas’s property but allowed the house to remain due to its de minimis encroachment. The court affirmed the additional restrictions on the water well agreement, finding them reasonable and consistent with the agreement’s terms. The decision was affirmed in part and reversed in part. View "Frisk v. Thomas" on Justia Law