Justia Montana Supreme Court Opinion Summaries

The case involves a water rights dispute on Indian Creek in Madison County, Montana. William Fraser claimed a senior stock use water right in Indian Creek, which Bradley Livestock, LC contested. Fraser's claim is based on historical use dating back to the late 1800s when his predecessor, William Tiernan, acquired ranchland and water rights in the Ruby Valley. The dispute arose when Fraser sought enforcement of his water right, and the Water Commissioner refused, leading Fraser to file a complaint.The Fifth Judicial District Court certified Fraser’s complaint to the Montana Water Court to resolve the water distribution controversy. The Water Court issued an order decreeing Fraser’s stock use claim as senior to Bradley’s irrigation rights in Indian Creek. Bradley appealed, arguing that the Water Court misinterpreted a 1905 District Court decree and that Fraser’s chain of title was broken, thus invalidating his claim.The Supreme Court of the State of Montana reviewed the case. The court affirmed the Water Court’s decision, holding that Fraser has a valid stock use right with an April 20, 1866 priority date. The court found that the chain of title supporting Fraser’s claim was unbroken and that the Water Court correctly interpreted the historical evidence. The court also upheld the Water Court’s interpretation of the 1905 decree, which limited Fraser’s right to make a call on junior appropriators after July 15 unless he could show that curtailment would result in water reaching his property in beneficial amounts. The court concluded that this limitation only applies to appropriators addressed in the 1905 decree. View "Bradley Livestock v. Fraser" on Justia Law

Dr. Thomas C. Weiner, an oncologist, had his medical staff membership and clinical privileges revoked by St. Peter’s Health (SPH) in 2020. Prior to this, Weiner had initiated litigation (Weiner I) against SPH, alleging wrongful termination, civil conspiracy, and due process violations. During Weiner I, he requested an administrative hearing under SPH Bylaws, leading SPH to seek a stay, which was denied. Weiner was allowed to amend his complaint once but was denied a second amendment to include claims related to the administrative review process.The First Judicial District Court, Lewis and Clark County, denied Weiner’s motion to file a second amended complaint in Weiner I, citing untimeliness and potential prejudice to SPH. Subsequently, Weiner filed a new lawsuit (Weiner II) in June 2022, asserting claims similar to those he sought to add in Weiner I. SPH moved to dismiss Weiner II, arguing it was an impermissible collateral attack and constituted claim-splitting. The District Court dismissed Weiner II based on res judicata, reasoning that Weiner could have included his new claims in Weiner I and that the denial of his motion to amend was a final judgment on the merits.The Supreme Court of the State of Montana reviewed the case and affirmed the dismissal of Weiner II, but on different grounds. The court held that the District Court erred in applying res judicata because the denial of the motion to amend in Weiner I was not a final judgment on the merits. However, the Supreme Court concluded that Weiner II was properly dismissed under the doctrine of claim-splitting, which prevents parties from maintaining multiple lawsuits based on the same transaction or series of connected transactions. The court emphasized that claim-splitting aims to promote judicial economy and prevent duplicative litigation. View "Weiner v. St. Peter's Health" on Justia Law

The case involves a dispute between Judge Kerry L. Burman, the Glendive City Judge, and Mayor Deb Dion of Glendive, Montana. Judge Burman petitioned for a writ of mandamus to reinstate Mary York to her position as Clerk of Glendive City Court after Mayor Dion terminated York's employment. The termination occurred following a disagreement over the justification for York's attendance at a training conference. York was terminated without notice and escorted out of the court, leaving unfinished work and causing operational disruptions.The District Court initially ordered York's interim reinstatement pending further review. Judge Burman argued that Mayor Dion's actions violated state statute, the court's holding in Carlson v. City of Bozeman, and the constitutional doctrine of separation of powers. Respondents contended that Mayor Dion had the statutory authority to terminate York, who was still in her probationary period, and that the court's operations were not significantly impaired.The Supreme Court of the State of Montana reviewed the case. The court determined that the matter was more appropriately characterized as an application for a writ of prohibition rather than mandamus. The court found that Mayor Dion's actions disrupted the court's operations and violated § 3-1-111, MCA, which grants courts the authority to control their ministerial officers. The court held that the executive's authority to hire or fire employees must be exercised in a manner that does not impair the court's ability to conduct its business.The Supreme Court of Montana granted the petition for a writ of prohibition, arresting Mayor Dion's action of terminating York's employment. The court emphasized the need for coordination between branches of government to avoid such disruptions. View "Burman v. City of Glendive" on Justia Law

The North Central Montana Regional Water Authority (the Authority) was created in 2000 through an interlocal agreement among several municipalities and county water and sewer districts. The Town of Kevin, a small municipality with fewer than 175 residents, did not sign the original agreement but signed several later documents attempting to join the Authority. The Town later sought to sever ties with the Authority, which resisted these attempts. On May 29, 2020, the Town sued the Authority, seeking a declaratory judgment under the Uniform Declaratory Judgment Act (UDJA) that it was not, and never had been, a member of the Authority, and also sought attorney fees.The Twelfth Judicial District Court held a bench trial and issued an order on November 10, 2022, declaring that the Town was not a member of the Authority and granting other relief. Subsequently, the Town filed a motion for attorney fees under the UDJA. On March 30, 2023, the District Court found that equitable factors supported awarding attorney fees to the Town, noting the significant disparity in resources between the Town and the Authority. The Authority appealed this order.The Supreme Court of the State of Montana reviewed the case. The court affirmed the District Court's decision, holding that the UDJA provides a legal basis for awarding attorney fees between governmental entities when appropriate. The court found that the parties were not similarly situated, as the Town had significantly fewer resources compared to the Authority. The court also applied the "tangible parameters test" and concluded that the Authority possessed what the Town sought, it was necessary for the Town to seek a declaration, and the declaratory relief was necessary to change the status quo. Therefore, the District Court did not abuse its discretion in awarding attorney fees to the Town. The Supreme Court affirmed the award of attorney fees to the Town. View "Town of Kevin v. North Central Montana Regional Water Authority" on Justia Law

In this case, the plaintiff, Shandor S. Badaruddin, was sanctioned by the Nineteenth Judicial District Court, Lincoln County, for his conduct as defense counsel in a criminal trial involving his client, Kip Hartman, who faced multiple felony charges related to securities and insurance fraud. The trial was conducted under strict time constraints due to the COVID-19 pandemic, and the court allocated equal time for both the prosecution and defense. Badaruddin was accused of mismanaging his allotted time, leading to a mistrial declaration by the District Court.The District Court found that Badaruddin had deliberately delayed the trial, which led to the mistrial. Consequently, the court imposed monetary sanctions amounting to $51,923.61 against Badaruddin for the costs associated with the trial. Badaruddin appealed the sanctions, arguing that he was not given adequate notice of the court's concerns and that his actions were not deliberate but rather a result of the challenging circumstances.The Supreme Court of the State of Montana reviewed the case and noted that the U.S. District Court had previously ruled that the mistrial declaration was erroneous. The U.S. District Court found that Badaruddin's actions did not constitute deliberate delay and that his efforts to manage the trial time were competent. The U.S. District Court's ruling was affirmed by the U.S. Court of Appeals for the Ninth Circuit, which held that Hartman could not be retried due to double jeopardy protections.Given the federal court's findings, the Supreme Court of Montana concluded that there was no basis for the sanctions under § 37-61-421, MCA, as there was no multiplication of proceedings. The court reversed the District Court's sanction order, determining that the costs incurred were not "excess costs" as defined by the statute. View "Badaruddin v. 19th Judicial District" on Justia Law

Cody Joseph Vernon Flesch was arraigned on a charge of bail jumping in Yellowstone County District Court. During the hearing, the court was informed of an existing detention order from Powell County. Despite Flesch's objections and claims of having posted bond, the court confirmed the detention order and set a new bond for the bail jumping charge. As the court was issuing the bond amount, Flesch attempted to flee the courtroom but was quickly restrained by officers.The Thirteenth Judicial District Court denied Flesch's motion to dismiss the charge of attempted escape, determining that a reasonable person would have understood they were being remanded based on the Powell County order. The court also denied the State's motion in limine to preclude Flesch from arguing that he was not subject to official detention, leaving it as a question of fact for the jury. Flesch was subsequently found guilty of attempted escape by a jury and sentenced to seven years in prison.The Supreme Court of the State of Montana reviewed the case. The court held that the State's charging documents provided sufficient facts to establish probable cause that Flesch was subject to official detention when he attempted to flee. The court affirmed the lower court's decision, stating that the definition of "official detention" includes constructive restraint and that Flesch's actions fell within this scope. Additionally, the court found that Flesch waived his claim that Judge Harada should have disqualified herself, as he did not raise the issue in a timely manner and failed to demonstrate actual bias or prejudice. The Supreme Court affirmed the District Court's denial of Flesch's motion to dismiss and upheld his conviction. View "State v. Flesch" on Justia Law

In October 2018, law enforcement responded to a motel room in Missoula, Montana, where they found Kaleb Williams injured and Megan McLaughlin and Jason Flink deceased, all having been shot. Preston Csoo Rossbach, along with Jonathan Whitworth and Ty Butler, had driven to Missoula to confront Raven Lamere over allegedly bad drugs. They picked up LaBenza Charlo, who arranged drug deals, and went to Lamere’s motel. When Lamere was not present, they left but returned shortly after. Whitworth, carrying a gun, shot the room’s occupants, and Rossbach allegedly directed the shooting and stabbed the victims. Rossbach was later arrested and charged with multiple offenses, including deliberate homicide.The Fourth Judicial District Court in Missoula County tried Rossbach. During voir dire, the court denied Rossbach’s challenge to remove a prospective juror for cause, leading him to use a peremptory challenge. The jury heard testimony from various witnesses, including jailhouse informants who testified under cooperation agreements. The jury convicted Rossbach of two counts of deliberate homicide, assault with a weapon, tampering with evidence, and two counts of intimidation. Rossbach filed a motion for acquittal or a new trial, which the District Court denied.The Supreme Court of the State of Montana reviewed the case. It held that the District Court did not abuse its discretion in denying the challenge for cause of the prospective juror, as the juror’s responses did not demonstrate bias. The court also found no violation of Rossbach’s confrontation rights, as he was allowed sufficient cross-examination of the informants. The evidence was deemed sufficient to support the conviction for deliberate homicide under the felony-murder rule. Lastly, the court found no Brady violation warranting a new trial, as the late-disclosed letter did not significantly impact the informant’s credibility. The Supreme Court affirmed the District Court’s rulings and Rossbach’s conviction and sentence. View "State v. Rossbach" on Justia Law

In the early morning of January 2, 2020, Whitefish Police responded to a report of a vehicle collision in an apartment complex parking lot. Witness Clint Slosson observed a truck hitting a parked car, and the driver, later identified as Joshua Zumwalt, appeared intoxicated. Officers found the truck registered to Zumwalt and located his apartment. After knocking and observing movement inside, Zumwalt eventually answered the door and agreed to step outside, where officers conducted a DUI investigation, leading to his arrest.The Municipal Court denied Zumwalt's motion to suppress evidence obtained from the officers' observations, ruling that the officers did not violate his reasonable expectation of privacy. Zumwalt was convicted of DUI, and his appeal to the Eleventh Judicial District Court was unsuccessful. He argued that the search was unlawful and that the prosecution improperly elicited expert testimony without proper foundation.The Supreme Court of the State of Montana reviewed the case. It held that the officers did not conduct an unlawful search as they remained in common areas of the apartment complex where Zumwalt had no reasonable expectation of privacy. The court also found that the officers' actions were minimally intrusive. Regarding the expert testimony, the court agreed that the foundation for the officers' opinions on Zumwalt's intoxication level was insufficient. However, it deemed this error harmless due to the overwhelming evidence of Zumwalt's intoxication, including witness testimony, video evidence, and field sobriety tests. The court affirmed the lower court's decision, upholding Zumwalt's DUI conviction. View "City of Whitefish v. Zumwalt" on Justia Law

Shane Clark Johnson was charged with deliberate homicide in 2013 for the death of his brother, Travis. The jury could not reach a verdict on deliberate homicide but convicted Johnson of negligent homicide with a dangerous weapon. On appeal, the Montana Supreme Court reversed and remanded for a new trial. The State again charged Johnson with deliberate homicide but amended the charge to negligent homicide after Johnson filed a motion to dismiss on double jeopardy grounds. The second jury found Johnson guilty of felony negligent homicide and that he used a weapon in the commission of the offense.In the first trial, Judge Daniel Boucher allowed Johnson to present a defense of justifiable use of force, but limited evidence about Travis’s violent behavior and other specific acts. Johnson testified that Travis attacked him, leading to a struggle over a gun, which resulted in Travis’s death. The jury convicted Johnson of negligent homicide. On remand, Judge Matthew J. Cuffe presided over the second trial. Johnson did not present a self-defense theory but argued the shooting was accidental. The prosecutor’s closing arguments included comments on the State’s charging decisions and the lack of evidence that Travis was suicidal, which Johnson’s counsel did not object to at trial.The Montana Supreme Court reviewed the case and affirmed the conviction. The court found that the prosecutor’s comments were permissible and did not warrant a mistrial. The court also declined to exercise plain-error review for the unobjected comments about the State’s charging decisions. Johnson’s ineffective assistance of counsel claims were deemed not record-based and more appropriate for postconviction relief. The court held that the District Court legally imposed a consecutive weapon enhancement sentence in addition to the persistent felony offender sentence. View "State v. Johnson" on Justia Law

Jesse Rehbein and Danielle Buck are the natural parents of two children, L.M.A.R. and N.R.R. In January 2018, the Department of Child and Family Services removed the children from their care due to concerns including neglect of medical and educational needs, substance abuse, and domestic violence. The children were placed with their grandparents, Doug and Annette Rehbein, who have cared for them since March 2018. Jesse and Danielle made some efforts to improve their situation, including therapy and drug testing, but the grandparents were appointed as guardians in February 2019.The Eleventh Judicial District Court, Flathead County, issued an Amended Final Parenting Plan on September 6, 2023, granting the grandparents a third-party parental interest. Jesse and Danielle objected, arguing that the court should have applied the grandparent visitation statute (§ 40-9-102, MCA) rather than the third-party parental interest statute (§ 40-4-228, MCA). The District Court found that the grandparents met the requirements under § 40-4-228, MCA, and granted them a parental interest, allowing Jesse and Danielle unsupervised visitation every other weekend.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The Court held that the District Court correctly applied § 40-4-228, MCA, as the Montana Legislature allows grandparents to seek third-party parental status under this statute. The Court found clear and convincing evidence that Jesse and Danielle engaged in conduct contrary to the child-parent relationship and that the grandparents had established a child-parent relationship with the children. The Court also noted that the fitness of the natural parents is not a consideration under § 40-4-228, MCA, when granting a third-party parental interest. The decision to grant the grandparents a third-party parental interest was affirmed. View "In re the Parenting Plan of L.M.A.R and N.R.R." on Justia Law