Justia Montana Supreme Court Opinion Summaries

Defendant pleaded guilty to two counts of felony sexual assault. This appeal concerned Defendant’s motion to vacate his conviction and dismiss the charges. In his motion Defendant claimed that the district court lacked subject matter jurisdiction because the charges were not brought by a grand jury process and that Montana law did not allow a court to obtain jurisdiction over a felony without this process. The district court denied the motion. The Supreme Court affirmed, holding that the district court had subject matter jurisdiction under Montana’s Constitution and state law. View "Montgomery v. State" on Justia Law

During Plaintiff’s marriage dissolution proceedings, Nancy Smith served as guardian ad litem for Plaintiff’s children. After Plaintiff stopped paying bills to Smith, Smith assigned the unpaid bills to Collection Professionals, Inc. (CPI). CPI filed a complaint to collect the debt. Thereafter, Plaintiff filed this action alleging, among other claims, that Collection Professionals, Inc. (CPI) violated the Fair Debt Collection Practices Act (FDCPA) by attempting to collect a false debt. CPI counterclaimed for the amount owed for Smith’s services. The district court entered summary judgment in favor of CPI and Smith. The Supreme Court affirmed, holding that the district court (1) correctly awarded summary judgment to CPI on Plaintiff’s FDCPA claim because the FDCPA did not apply under the circumstances of this case; (2) correctly awarded summary judgment to Smith; and (3) correctly awarded CPI $7,408 in damages plus interest. View "Amour v. Collection Prof’ls, Inc." on Justia Law

After a hearing, the district court entered an order terminating Appellant’s rights to her four children. The court found that termination was appropriate because the children were previously adjudicated youths in need of care, a treatment plan approved by the court was not completed by Mother, and the conduct or condition rendering Mother unfit was unlikely to change in a reasonable time because of Mother’s drug problems. The court also concluded that termination was in the best interests of the children. The Supreme Court affirmed, holding (1) the treatment plan was appropriate when it did not require Mother to obtain a chemical dependency evaluation; (2) Mother’s counsel was not ineffective for failing to advocate for inclusion of a chemical dependency evaluation in the treatment plan; and (3) the district court acted within its discretion when it denied Mother’s request for transcripts of its in-chambers interviews with the children. View "In re T.N.-S." on Justia Law

GTL, Inc. filed suit against John Greytak and Tanglewood Investors Limited Partnership (collectively, Greytak) for non-payment of an obligation arising from a construction project. GTL was insured by Atlantic Casualty Insurance Company under a commercial general liability policy. Greytak filed counterclaims against GTL in the state court action. Atlantic sued GTL and Greytak in federal district court seeking a declaration that it was not required to defend GTL from Greytak’s counterclaims or to pay judgment because GTL had not provided timely notice as required by the policy language. GTL later defaulted. The federal district court granted Atlantic’s motion for summary judgment. The Court of Appeals certified a question of law to the Montana Supreme Court, which answered in the affirmative, holding that an insurer who does not receive timely notice according to the terms of an insurance policy must demonstrate prejudice from the lack of notice to avoid defense and indemnification of the insured. View "Atlantic Cas. Ins. Co. v. Greytak" on Justia Law

Plaintiff, a machinist employed by the BNSF Railway Company (BNSF), brought this action against BNSF alleging negligence under the Federal Employers’ Liability Act (FELA). After his lawsuit was filed, Plaintiff requested the production of videos of the work area where the alleged injury occurred. BNSF refused to provide the video footage alleging that it had been overwritten. After a trial, the jury found in favor of BNSF. The Supreme Court reversed, holding that the district court abused its discretion when it (1) declined to impose a meaningful sanction on BNSF for its destruction of evidence; and (2) instructed the jury as to BNSF’s duty of care in a FELA action. View "Mark Spotted Horse v. BNSF Railway Co." on Justia Law

Plaintiff was a veteran suffered from service-connected physical conditions, including a seizure disorder, and he had a service dog that alerted him to oncoming seizures. When staff at the C’Mon Inn, a hotel in Bozeman, Montana, staff refused to allow Plaintiff to register because he was accompanied by his service dog, Plaintiff called 911 and complained that the hotel was discriminating against him by refusing him entry, three Bozeman Police Department officers responded. The officers told Plaintiff he would have to leave but informed Plaintiff that he could file a complaint if he wished. Plaintiff filed this action against the Bozeman Police Department contending that the responding officers violated the Human Rights Act when they “aided, abetted and facilitated” the hotel’s discrimination against him. The district court granted summary judgment to the Bozeman Police Department. The Supreme Court affirmed, holding that there was no evidence that the officers aided or abetted C’Mon Inn’s conduct. View "Hansen v. Bozeman Police Dep’t" on Justia Law

Defendant was charged with two counts of attempted deliberate homicide. Before trial, Defendant moved to suppress statements he made while in custody, arguing that he was never informed of his right to remain silent and that all questioning by law enforcement should have ceased when he asked for an attorney. The district court denied the motion to suppress. Defendant was subsequently convicted on both counts of attempted homicide. The Supreme Court affirmed, holding that the district court did not err when it (1) denied Defendant’s motion to suppress, as the statements he made after he was in custody, after he requested an attorney, and before he was notified of his Miranda rights were spontaneous; and (2) denied Defendant’s motion to exclude one of the victims of the crime from the courtroom. View "State v. Braulick" on Justia Law

Marian Davis lost control of her vehicle and struck a vehicle driven by Amy Locke. At the time of the accident, Davis was insured by Safeco Insurance Company under a policy with a $100,000 per person coverage. Davis died from her injuries. Locke, who also sustained injuries, filed a claim for damages against Davis’s estate. Prior to trial, Safeco paid Locke $16,306 for her past medical expenses. After a trial, the jury awarded Locke $400,000 in compensation for her injuries. The Estate appealed, and Safeco intervened. The Supreme Court affirmed in part and vacated and remanded in part, holding that the district court (1) abused its discretion in denying the Estate’s motion to alter or amend the judgment because Locke was precluded from recovering against the Estate more than the $100,000 insurance limitation; and (2) did not abuse its discretion when it made findings and conclusions that effectively bound Safeco to a judgment in a case in which Safeco was not a named party, was not represented by counsel, and did not appear. View "Locke v. Estate of Davis" on Justia Law

M.K.S., who had a long history of treatment for schizophrenia and other mental health illnesses, was regularly subject to community commitments and hospitalizations. In 2013, M.K.S. stipulated to a six-month community commitment. Before the commitment was set to expire, the State filed a renewed petition for commitment. After a commitment hearing, the district court found that M.K.S. posed a danger to herself based on her recent suicidal threats and that a commitment to the Montana State Hospital was necessary to guarantee her safety. The Supreme Court affirmed based on the plain error doctrine, holding that because of a professional person’s failure to file a statutorily-required written report in M.K.S.’s civil commitment proceeding, M.K.S.’s right of due process was implicated in the proceedings. However, M.K.S. failed to demonstrate that the absence of a written report substantially impacted this right in a manner that would leave unsettled the fundamental fairness of the proceedings, compromise the integrity of the judicial process, or create a manifest miscarriage of justice. View "In re M.K.S." on Justia Law

Appellants were the owners of multi-unit apartment buildings located in Montana and the property management companies that managed Owners’ apartment complexes during the time relevant to this suit. Appellees were current or former tenants of Owners’ apartment complexes who signed leases for those apartments through the property management companies. Appellees filed a complaint on behalf of themselves and other unnamed plaintiffs alleging that certain provisions included in the leases were prohibited by law. The district court granted Appellees’ motion for class certification. The Supreme Court affirmed, holding that the district court did not abuse its discretion by certifying the class under Mont. R. Civ. P. 23(b)(3). View "Worledge v. Riverstone" on Justia Law