Justia Montana Supreme Court Opinion Summaries

Central United Life Insurance Co. (CULI) purchased Judith Gleason’s cancer benefit insurance policy prior to Gleason’s death from breast cancer. Gleason’s Estate submitted notice of potential claims under the policy to CULI. CULI paid certain claims but denied payment for claims submitted outside the policy limit. The Estate contested the denial of the untimely-filed claims. The district court granted partial summary judgment for the Estate, ruling that CULI owed payment for the untimely-filed claims, provided it was not prejudiced by the late notice. After a trial, the jury found that CULI had violated the Montana Unfair Trade Practices Act (UTPA) but did not award damages and therefore did not consider whether CULI acted with malice. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the district court correctly applied the notice-prejudice rule; and (2) when an insurer is found to have violated the UTPA, a jury is not required to find compensatory damages beyond those for breach of the insurance contract before considering malice and punitive damages under the UTPA, and therefore, a new trial must be held on the issue of malice and punitive damages. View "Estate of Gleason v. Cent. United Life Ins. Co." on Justia Law

Catherine E.W. Hansen Trust (Hansen Trust), which was issued a tax lien and a tax deed on certain property, filed a complaint to quiet title to the tax deed. The district court granted summary judgment for Hansen Trust and declared the tax deed void as a matter of law, finding that Hansen Trust had not obtained the required property title guarantee and had not provided notice to parties listed in the title guarantee. The court subsequently directed payment of the tax lien and entered final judgment. The district court denied Hansen Trust’s post-judgment motions. The Supreme Court affirmed, holding that the district court (1) correctly granted summary judgment and declared the tax deed void after determining that Hansen Trust failed to provide adequate notice or obtain a property title guarantee; (2) did not err when it directed payment of Hansen Trust’s tax lien; and (3) did not err when it denied Hansen Trust’s post-judgment motions. View "Catherine E.W. Hansen Trust v. Ward" on Justia Law

Casey Kent, an adult, died from a head injury he suffered after falling while skateboarding in a residential planned unit development in Columbia Falls, Montana known as Cedar Point Estates. Casey was skateboarding along a paved walking path within the subdivision, and at the bottom of a twenty-four percent decline in the path, Casey fell and suffered his fatal head injury. Sara Kent, Casey’s widow, filed suit against the City of Columbia Falls and other entities involved in designing, developing, and constructing the development, alleging that the steepness of the path grade caused Casey’s fall and injury. Sara ultimately settled with all defendants except the City. The district court granted the City’s motions for summary judgment. The Supreme Court reversed, holding that the district court erred in barring Sara’s claims on the basis of the public duty doctrine. Remanded for a trial on the merits. View "Kent v. City of Columbia Falls" on Justia Law

Violet Quirin died in 2011. Prior to her death, Quirin had executed three wills in 2005, 2007, and 2010. In the first two wills Quirin divided her property equally between her two surviving daughters. However, in the 2010 will, Quirin made no provision for her daughters and instead divided her estate among several friends and charitable organizations. Following Quirin’s death, one of her daughters (“Daughter”) petitioned for formal probate of the will Quirin executed in 2007, claiming that Quirin lacked testamentary capacity when she signed the 2010 will. After a trial, the district court confirmed probate of the 2010 will, ruling that Daughter failed to show that Quirin lacked testamentary capacity. The Supreme Court affirmed the district court’s order confirming probate of the 2010 will, holding that the court did not err when it determined that Quirin possessed testamentary capacity at the time she executed the 2010 will. View "In re Estate of Quirin" on Justia Law

Appellant pleaded guilty to the charge of deliberate homicide. After the matter had been set for sentencing, Appellant sought the appointment of new counsel and also filed a motion for withdrawal of his guilty plea. The district court denied Appellant’s request for the appointment of new counsel and further denied his motion to withdraw his plea. The court then sentenced Appellant to life in prison. The Supreme Court remanded for further proceedings on a limited issue, holding that the district court failed to adequately inquire into Appellant’s complaint that defense counsel had rendered ineffective assistance of counsel. View "State v. Schowengerdt" on Justia Law

Judy Meek died after a fall at a business premises. Sharon Meek, as personal representative of Judy’s Estate (Meek), sued the business where the fall happened seeking damages for survival and wrongful death. The issue in this case arose from the district court’s decision on a pre-trial motion filed by one of the defendants to limit medical expense evidence. The court then granted summary judgment against Meek on that issue. Meek subsequently filed a petition for writ of supervisory control on the issue. The Supreme Court granted the petition and exercised supervisory control, holding that the district court’s order admitting only evidence of amounts the insurers paid to Meek’s health care providers violated Mont. Code Ann. 27-1-308. View "Meek v. Eighth Judicial Dist. Court" on Justia Law

After receiving treatment from St. Peter’s Hospital, Plaintiff filed suit alleging that the Hospital violated Montana anti-trust laws and the Montana Constitution by discriminating against her based on her lack of health insurance. After concluding that Plaintiff had standing, the district court awarded summary judgment to the Hospital, determining that uninsured persons are not a protected class under the Montana Constitution. The Supreme Court (1) affirmed the district court’s standing determination; but (2) reversed the court’s entry of summary judgment on the merits, holding that the determinations that the district court made in its summary judgment order did not resolve all of Plaintiff’s claims. Remanded. View "Gazelka v. St. Peter’s Hosp." on Justia Law

The Montana Public Service Commission determined that Whitehall Wind, LLC had not established a legally enforceable obligation during contract negotiations with NorthWestern Energy for the sale and purchase of electric energy generated by a proposed wind facility. The district court reversed, determining that NorthWestern’s refusal to negotiate created a legally enforceable obligation entitling Whitehall to a long-term avoided cost rate. The Supreme Court reversed the district court’s decision and order and remanded for reinstatement of the Commission’s order, holding that the Commission did not exceed its statutory authority in concluding that evidence of a utility’s refusal to negotiate, without more, is insufficient to establish that a qualifying facility has committed itself to the proposed project. View "Whitehall Wind, LLC v. Mont. Pub. Serv. Comm’n" on Justia Law

Mother and Father were married in Canada in 2010 and moved to Montana in 2013. Later that year, Mother and the parties’ child travelled to Canada and stayed there into 2014. Father filed a petition for dissolution with the Yellowstone County District Court in 2014 and asked the district court to resolve matters of Father’s parenting and custody. The district court dismissed for lack of jurisdiction the parenting and custody issues, concluding that Montana was not the child’s “home state” for purposes of Mont. Code Ann. 40-7-201. The Supreme Court affirmed, holding that the district court did not err by (1) refusing to hold a hearing prior to issuing its order; and (2) deciding that it lacked jurisdiction over the parenting and custody issues. View "In re Marriage of Sampley" on Justia Law

Petitioner was stopped for crossing the center line of a road with his vehicle. When Petitioner refused to perform a breath alcohol test he was arrested for driving under the influence of alcohol or drugs. Petitioner’s driver’s license was subsequently suspended. Thereafter, Petitioner petitioned the district court to reinstate his driver’s license. The district court denied the petition, concluding that Petitioner violated Mont. Code Ann. 61-8-328 when his vehicle “slightly crossed over the yellow center line.” The Supreme Court affirmed, holding that the district court did not err by deciding that Petitioner violated section 6-18-328 when he directed his vehicle across the yellow center line. View "Mitchell v. State" on Justia Law