Justia Montana Supreme Court Opinion Summaries

The case involves Creative Games Studio LLC and Ricardo Bach Cater, who sued Daniel Alves for alleged breach of contract, breach of the implied covenant of good faith and fair dealing, constructive fraud, and deceit. The plaintiffs, who are co-founders of Creative Games Studio, a company that develops board games for online sale, accused Alves of collaborating with a competitor and using the company's funds and intellectual property for the competitor's benefit. Alves, a Brazilian citizen, was also a co-founder of the company. The plaintiffs filed the lawsuit in Montana, where the company is based.The District Court of the Thirteenth Judicial District, Yellowstone County, dismissed the case due to lack of personal jurisdiction over Alves. The court determined that exercising jurisdiction over Alves would not comply with constitutional requirements. Alves had moved to dismiss the complaint under M. R. Civ. P. 12(b)(2) for lack of personal jurisdiction or under the doctrine of forum non-conveniens.The Supreme Court of the State of Montana affirmed the lower court's decision. The court found that Alves did not consent to jurisdiction and that subjecting him to the jurisdiction of Montana courts would not comply with due process. The court noted that Alves' only connection to Montana was the fact that one of the plaintiffs resided there and established the company in the state. The court concluded that the plaintiffs failed to show that Alves either availed himself of the privileges of Montana law or that their claims arose out of Alves's actions in Montana. View "Creative Games v Alves" on Justia Law

The case involves a dispute between Missoula County and the Montana Department of Corrections (DOC) over the reimbursement rate for housing DOC inmates in county detention centers. The County and the DOC had entered into a contract in 2015, setting a reimbursement rate of $88.73 per day for each inmate. However, in 2015, the Montana Legislature capped the reimbursement rate at $69 per day. The County filed a lawsuit in 2020, alleging breach of contract, breach of the implied covenant of good faith and fair dealing, and unjust enrichment.The District Court granted summary judgment to the DOC, concluding that the County's contract claims were time-barred by a one-year statute of limitations. It also found that the County's tort claim for breach of the covenant of good faith was not supported by a special relationship and that the County could not recover under a theory of unjust enrichment.The Supreme Court of Montana affirmed the District Court's decision. It held that the one-year statute of limitations applied to the County's contract claims, rejecting the County's argument that an eight-year limitation period should apply. The court also agreed with the lower court that the County's tort claim for breach of the covenant of good faith was not supported by a special relationship. Finally, the court concluded that the County could not recover under a theory of unjust enrichment, as the County had not demonstrated that the DOC had reaped an inequitable gain. View "Missoula County v. Department of Corrections" on Justia Law

The case revolves around a dispute between Debra and Sidney Schutter (the Schutters) and the State of Montana Board of Land Commissioners (the Board) over the ownership of a water right, identified as Claim 13169. The Schutters use a groundwater well on their private property to irrigate four parcels of land, one of which is school trust land owned by the State of Montana. The Board objected to the Schutters' claim of exclusive ownership of the water right, asserting that the State holds an ownership interest in the portion of the water right used to irrigate the school trust land.The Montana Water Court granted summary judgment to the Board, adding the State as a co-owner of Claim 13169, but only for the portion of the claim appropriated to irrigate the school trust land. The Schutters appealed this decision, arguing that the Water Court erred in applying the precedent set in a previous case, Pettibone, and that no portion of Claim 13169 is appurtenant to the school trust land.The Supreme Court of the State of Montana affirmed the Water Court's decision. The court held that the portion of Claim 13169 used to irrigate the school trust land is appurtenant to that land and, therefore, the State is a co-owner of that portion of the right. The court also rejected the Schutters' argument that the Water Court erred in applying the Pettibone precedent, stating that the Schutters' reliance on the point of diversion as singularly controlling was misplaced. The court concluded that the Schutters used the school trust land they leased to qualify for and establish the parameters of Claim 13169, and without the ability to claim a beneficial use on the school trust land, the Schutters' claim to a water right would have been different, perhaps smaller. View "Schutter v. Board of Land Commissioners" on Justia Law

Phoenix Capital Group Holdings, LLC, an oil and gas mineral rights investment firm, acquired mineral interests on two sections of real property in Richland County, Montana. The previous owner, Katherine Solis, had been approached multiple times by Kraken Oil and Gas LLC, an energy production company, to secure a lease of the mineral interests or to participate in drilling wells. Solis consistently refused to engage with Kraken. After Phoenix acquired the mineral interests, it expressed a desire to participate in the oil and gas production from the wells being drilled by Kraken. However, Kraken responded that the mineral interests had been deemed “non-consent” due to Solis’s lack of participation, and it was authorized to recover risk penalties.The Board of Oil and Gas Conservation of the State of Montana held a hearing and determined that Kraken had made unsuccessful, good faith attempts to acquire voluntary pooling in the spacing unit, and that Phoenix, as a successor in interest, was bound to Solis’s decision not to participate. The Board therefore determined that the mineral interests owned by Phoenix would be subject to forced pooling and that Kraken could recover risk penalties from Phoenix. Phoenix requested a rehearing from the Board, but that request was denied. Phoenix then filed a Complaint seeking injunctive relief from the Board decision in the Thirteenth Judicial District Court, Yellowstone County. The District Court issued an Order granting Kraken and the Board’s motions for summary judgment, and dismissing Phoenix’s Complaint.In the Supreme Court of the State of Montana, Phoenix appealed the District Court's decision. The Supreme Court affirmed the lower court's decision, holding that the Board correctly interpreted the statutory force-pooling requirements, and that its decision to force pool Phoenix’s mineral interests was reasonable. The court also held that Kraken’s letters to Solis constituted written demands that gave Solis the option to either participate or face assessment of risk penalties. The court concluded that risk penalties were imposed, not pursuant to the presumption in § 82-11-202(3), MCA (2021), but under § 82-11-202(2), MCA, which requires an owner pay risk penalties when “after written demand, [the owner] has failed or refused to pay the owner’s share of the costs of development or other operations . . . .” View "Phoenix Capital v. Board of Oil & Gas" on Justia Law

Shane Maggi, an inmate at Montana State Prison, was convicted of aggravated assault, assault with a weapon, and possession of a deadly weapon by a prisoner. The charges stemmed from an incident where Maggi and another inmate attacked Wesley Smith in his cell, causing puncture wounds and a fractured facial bone. At sentencing, the Third Judicial District Court, Powell County, declared Maggi a persistent felony offender and used that designation to impose a life sentence on the aggravated assault charge.The District Court's decision was appealed to the Supreme Court of the State of Montana. The appellant argued that the District Court erred in imposing a life sentence under § 46-18-220, MCA, for aggravated assault when Maggi had not previously been designated a persistent felony offender. The State had sought sentence enhancements related to the offenses being committed while Maggi was in official detention, including life imprisonment for the aggravated assault charge.The Supreme Court of the State of Montana agreed with the appellant's argument. The court held that a defendant must have been previously declared a persistent felony offender, prior to the defendant’s subsequent, present felony conviction for which the offender is being sentenced, to count as an aggravating circumstance. The court found that the District Court had incorrectly used its simultaneous designation of Maggi as a persistent felony offender to enhance his sentence for the same felony conviction. As such, the Supreme Court reversed the District Court's decision and remanded the case for a new sentencing. The court did, however, uphold the District Court's decision to order Maggi’s sentences to run consecutively to all prior sentences but his Powell County matter DC-20-30. View "State v. Maggi" on Justia Law

The case revolves around the defendant, Luke Strommen, who was charged with Sexual Intercourse Without Consent (SIWC) and Sexual Abuse of Children. The charges stemmed from allegations made by two women, one of whom claimed that she had an ongoing sexual relationship with Strommen when she was a minor. The other woman alleged that Strommen possessed digital images of her engaged in sexual activity when she was 17. Strommen pleaded not guilty to both charges.In the lower courts, the State of Montana sought to present the testimony of a sexual assault behavioral psychologist, Dr. Sheri Vanino, remotely via two-way video conferencing due to her unavailability to travel to Montana for the trial. The defense objected, asserting that personal in-court cross-examination was essential. The District Court granted the State's motion, allowing Dr. Vanino to testify remotely. The trial resulted in Strommen being found guilty of SIWC and sentenced to a 40-year prison term.In the Supreme Court of the State of Montana, Strommen appealed his conviction, arguing that the District Court erroneously allowed the State to present adverse expert testimony remotely via two-way video conferencing at trial. The Supreme Court agreed with Strommen, holding that the allowance of Dr. Vanino's remote testimony violated Strommen's fundamental right to personal face-to-face confrontation of adverse prosecution witnesses in the courtroom at trial, as guaranteed by the Sixth Amendment and Mont. Const. art. II, § 24. The court reversed Strommen's conviction and remanded the case for a new trial. View "State v. Strommen" on Justia Law

A group of plaintiffs, including former members of the Montana Board of Regents, faculty organizations, student groups, and individual students, challenged the constitutionality of three bills passed by the Montana Legislature in 2021. The bills in question were HB 349, which regulated student organizations and speech on campus; HB 112, known as the "Save Women's Sports Act," which required sports teams to be designated as male, female, or coed based on biological sex; and § 2 of SB 319, which revised campaign finance laws and regulated the funding of certain student organizations. The plaintiffs argued that these bills infringed on the constitutional authority of the Board of Regents to supervise, coordinate, manage, and control the Montana University System.The District Court of the Eighteenth Judicial District, Gallatin County, granted the plaintiffs' motion for summary judgment, declaring HB 349, HB 112, and § 2 of SB 319 unconstitutional. The court also denied the plaintiffs' request for attorney fees. Both parties appealed this order.The Supreme Court of the State of Montana affirmed the District Court's decision. The court found that the plaintiffs had standing to bring their claims and that the challenged bills were unconstitutional. The court also upheld the District Court's denial of the plaintiffs' request for attorney fees, as the justices could not reach a majority opinion on this issue. View "Barrett v. State" on Justia Law

The case revolves around the petitioner, Tom Nichols, also known as Nikki, who is currently serving a prison sentence for sex crimes against children. Nikki, a transgender woman in the process of transitioning, filed a petition for a sealed-record name change, arguing that an open-record proceeding could jeopardize her safety due to her gender identity.The District Court of the Third Judicial District initially denied Nikki's petition. The court's decision was based on the fact that Nikki failed to demonstrate probable cause that her safety was at risk, a requirement under Section 27-31-201, MCA, for a petition to proceed on a sealed-record basis. The court also had to be satisfied that the petitioner was not attempting to avoid debt or hide a criminal record.Upon appeal, the Supreme Court of the State of Montana affirmed the lower court's decision. The Supreme Court noted that district courts have broad discretion to grant or deny a petition for a sealed-record name change. The Supreme Court would only reverse a district court decision if it was arbitrary or exceeded the bounds of reason, resulting in substantial injustice. In this case, the Supreme Court found that Nikki failed to provide specific instances of abuse or explain why an open-record proceeding would change her circumstances at the Montana State Prison. Furthermore, Nikki did not provide any support for the alleged risk of harm from members of the public. Therefore, the Supreme Court concluded that the District Court did not abuse its discretion when it determined the evidence was insufficient to support Nikki’s petition. View "In re Name Change of Nichols" on Justia Law

This case involves a dispute between neighbors Matthew Olds and Mark Huelskamp, which escalated into an altercation on July 18, 2018. The details of the incident are contested, with Olds alleging that Huelskamp pointed a gun at him and punched him in the nose, while Huelskamp claims that Olds spat in his face and threatened him, leading Huelskamp to defensively strike Olds. Olds filed a civil suit against Huelskamp for negligence, assault, battery, actual malice, and negligent infliction of emotional distress.The case was initially scheduled for trial in May 2020, but due to the COVID-19 pandemic, the trial was postponed multiple times. During this period, Huelskamp decided to present an expert witness, Shawn Paul, and disclosed this in September 2020. Olds objected to this, arguing that the disclosure was untimely and that Paul lacked the requisite training and experience to testify. The District Court initially allowed Paul to testify, but reversed this decision on the second day of trial, ruling that the disclosure was untimely.The jury found Huelskamp guilty of assault and battery, awarding Olds $13,700 in compensatory damages and $75,000 in punitive damages. The District Court later reduced these amounts to $13,700 and $10,500 respectively, and also reduced Olds' claimed attorney fees from $105,869 to $91,300. Huelskamp was thus ordered to pay Olds a total of $115,500.In the Supreme Court of the State of Montana, the court found that the District Court had abused its discretion by excluding Huelskamp's expert witness from testifying. The court noted that Huelskamp had disclosed the expert witness over 13 months prior to trial, giving Olds sufficient time to prepare for cross-examination. The court therefore reversed the District Court's decision and remanded the case for a new trial. View "Olds v. Huelskamp" on Justia Law

The case revolves around Kyle Severson, who was convicted for mitigated deliberate homicide after shooting Tyler Hayden. Severson, his girlfriend, her sister, and his daughter were at a convenience store when Hayden and Dalton Watson arrived. Hayden approached Severson's car, and Severson shot him, claiming he feared Hayden would harm him or his daughter. Severson was charged with deliberate homicide and later found guilty of mitigated deliberate homicide, resulting in a forty-year prison sentence.Severson appealed his conviction, arguing that the District Court erred in denying his motion to dismiss based on the State's failure to disclose favorable evidence and that the cumulative effect of errors in the District Court denied him a fair trial. The undisclosed evidence included law enforcement investigative reports of a burglary at Severson's home and the contents of Watson's cell phone.The Supreme Court of the State of Montana concluded that the cumulative effect of errors in the proceedings denied Severson his constitutional rights to a fair trial and due process. The court found that the prosecutor's misconduct and the State's failure to disclose certain evidence had a direct bearing on the credibility of the witnesses at trial. The court reversed Severson's conviction and remanded the case for a new trial. View "State v. Severson" on Justia Law