Justia Montana Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of sexual assault and sexual intercourse without consent. Defendant appealed, raising three allegations of error. The Supreme Court reversed, holding that the district court abused its discretion by allowing the State to elicit testimony from Defendant’s girlfriend and others who knew the couple regarding Defendant’s sexual habits. Further, the tainted evidence was inflammatory in nature and likely contributed to Defendant’s conviction. The district court further erred by permitting a primary investigator to act as both a representative of the State and a witness during trial. Remanded. View "State v. Nichols" on Justia Law

S.B.C. was a Naive American child whose biological parents were enrolled members of the Blackfeet Tribe (Tribe). When S.B.C. was approximately four months old he was removed from Mother’s care and placed with Foster Mother. The district court later terminated both Mother’s and Father’s parental rights and granted legal custody to Child Services with the right to consent to the adoption of S.B.C. The Supreme Court affirmed, holding that the district court (1) did not err by denying the Tribe’s motion to transfer jurisdiction to the Blackfeet Tribal Court; (2) did not abuse its discretion by terminating Father’s parental rights; and (3) did not abuse its discretion by terminating Mother’s parental rights. View "Matter of S.B.C." on Justia Law

After a jury trial, Defendant was convicted of accountability for robbery. Defendant was sentenced to thirty years imprisonment with ten years suspended and ordered to pay restitution in an unspecified amount. The Supreme Court affirmed in part and remanded in part, holding that the district court (1) properly instructed the jury on accountability for robbery; (2) did not err in denying Defendant’s motion to dismiss for insufficient evidence; and (3) erred in requesting that correctional authorities determine restitution upon Defendant’s release. Remanded for a determination of the amount of restitution Defendant owed for the victim’s medical expenses. View "State v. Hanna" on Justia Law

After a jury-waived trial, Defendant was found guilty of assault with a weapon and sentenced to twenty years with the Department of Public Health and Human Services. Defendant appealed, arguing that the district court (1) erred when it determined that he was not mentally fit to stand trial at a fitness proceeding in which he was not present, and (2) erred by failing to complete the initial appearance process. The Supreme Court affirmed, holding (1) Defendant was not prejudiced by his absence from the fitness proceeding; and (2) Defendant was not prejudiced by the district court’s failure to provide the advisories in Mont. Code Ann. 46-7-102. View "State v. White" on Justia Law

The Bixby family owned approximately one-third of Wyo-Ben’s class A stock. In 2011, Wyo-Ben’s shareholders voted to reclassify the shares to give class B shares the right to vote, which resulted in an overall decrease to the Bixby voting rights. The Bixby family dissented and, after the vote, sent a payment demand for all of their shares. Wyo-Ben, Inc. filed a petition seeking a declaration that the dissenters were not entitled to any payment for their class B shares and contesting the dissenters’ demand for a high value of the class A shares. The Bixbys, in turn, sought a declaration that they were entitled to payment for both classes of shares at the higher value. The Bixbys also counterclaimed, asserting that Wyo-Ben’s decision to dilute their voting rights constituted oppressive conduct. The district court dismissed the oppression claim and ruled that the Bixbys were not entitled to be paid for their class B shares under Montana’s dissenters’ right statute. The Supreme Court primarily affirmed, holding that the district court did not err in (1) dismissing the Bixbys oppression claim; (2) denying class B payments to all but one of the Bixby appellants; and (3) valuing the class A shares. View "Wyo-Ben, Inc. v. Bixby" on Justia Law

In 2008, William Corrigan filed for a divorce from his wife, Mary Helen Corrigan. The district court issued temporary restraining order (TRO) that prohibited William and Mary from changing the beneficiaries of any insurance. However, the TRO was never served on Mary. In 2012, William amended the terms of his IRA account with State Farm, removing Mary as beneficiary and naming his adult children as primary beneficiaries. After William died, Mary alerted State Farm that she would make an elective share claim on the IRA. Litigation ensued. The district court granted summary judgment to the adult children, concluding that the TRO was invalid. The Supreme Court affirmed, holding (1) because William did not serve Mary with the TRO in the three years allotted for service, the TRO was rendered ineffective, and therefore, William was not prohibited from amending his IRA; and (2) as a result, the district court did not err in finding that the adult children were the primary beneficiaries of the IRA account. View "In re Estate of Corrigan" on Justia Law

After a bench trial, Defendant was found guilty of assault with a weapon and sentenced to twenty years with the Department of Public Health and Human Services. Defendant appealed, arguing that the district court erred by determining that he was not mentally fit to stand trial at a hearing in which he was not present and by failing to complete the initial appearance process. The Supreme Court affirmed, holding (1) even if Defendant was improperly excluded from the proceeding at which his fitness to proceed was determined, his absence from the proceeding did not render the result unjust or unfair; and (2) Defendant was not prejudiced by the district court’s failure to provide the advisories in Mont. Code Ann. 46-7-102. View "State v. White" on Justia Law

In 2011, Cahill Seeds, Inc. (Cahill) began planning the construction of a new seed washing plant and submitted requests for electric service to Montana-Dakota Utilities (MDU) and Sheridan Electric Co-op, Inc. MDU subsequently upgraded its transmission and distribution systems near Cahill, which allowed MDU to provide three-phase Wye power to Cahill. MDU then began providing three-way Wye power to Cahill. In 2013, Sheridan filed a complaint alleging that MDU violated the Montana Territorial Integrity Act (MTIA) when it extended power to Cahill. The district court found that Sheridan had the right to serve Cahill under the priority provisions of the MTIA. Specifically, the court found that the 1.33 mile distance from Sheridan’s three-phase Wye transmission line to Cahill gave Sheridan priority over MDU, whose three-phase Wye line was 6.5 miles away. The Supreme Court affirmed, holding that Mont. Code Ann. 69-5-105(1) unambiguously granted priority to Sheridan because it had the line nearest to Cahill and the distribution system capacity to serve Cahill. View "Sheridan Elec. Coop, Inc. v. MT-Dak Utils." on Justia Law

In 2003, the marriage of Tonia Marez and David Marshall was dissolved by decree. For the next decade, the parties were involved in a bitter dispute over the parenting of their minor daughter. In 2013, after the daughter reached the age of fourteen, David moved to hold Tonia in contempt for failure to comply with the parenting plan. Tonia subsequently moved to hold David in contempt for failure to pay child support. David then moved for sanctions against Tonia for filing numerous pleadings with the intent to “harass, cause unnecessary delay, and needlessly increase the cost of litigation.” The district court granted David’s motion for contempt, denied Tonia’s motion for contempt, and imposed sanctions against Tonia. The Supreme Court (1) affirmed the order finding Tonia in contempt and the order refusing to find David in contempt, as the record supported the district court’s conclusions; and (2) declined to address the merits of the sanctions against Tonia, as the award of sanctions was not yet a final judgment because it did not include a necessary determination of the amount of costs and attorney fees awarded. View "In re Marriage of Marez" on Justia Law

Plaintiff, who leased commercial property from Defendant, filed a complaint with the Montana Human Rights Bureau, alleging that Defendant violated the Montana Human Rights Act (MHRA) by sexually harassing her. The Montana Human Rights Commission ruled that Plaintiff could proceed with her claim because the MHRA “prohibits unlawful discrimination in commercial property transactions, as well as all other real estate transactions.” The district court vacated the Commission’s decision and reinstated the hearing officer’s, ruling that the Commission violated Defendant’s right to due process by analyzing Plaintiff’s action under the MHRA’s real estate provisions. The Supreme Court remanded, directing the district court to resolve the issue that formed the alternate basis for Defendant’s challenge to the Commission’s decision - whether the MHRA’s real estate provisions applied to Plaintiff’s commercial lease. On remand, the district court ruled that the MHRA’s real estate provisions prohibit discrimination in commercial real estate transactions. The Supreme Court affirmed, holding that the MHRA applies to Plaintiff’s commercial lease. View "Bates v. Neva" on Justia Law