Justia Montana Supreme Court Opinion Summaries

Garrett Alan Lee, a 25-year-old, engaged in an online conversation with an undercover law enforcement officer posing as a 12-year-old girl. Lee discussed meeting the girl for sex and was apprehended by law enforcement when he arrived at the arranged location. He was charged with Sexual Abuse of Children under Montana law and pleaded guilty.The Thirteenth Judicial District Court sentenced Lee to 100 years at the Montana State Prison, with 65 years suspended, and imposed a 25-year parole restriction. Lee appealed, arguing that the mandatory 25-year parole restriction was unconstitutional and that the District Court violated his due process rights by considering information from a prior psychosexual examination not admitted into evidence.The Montana Supreme Court reviewed the case. The court held that Lee's constitutional and statutory arguments concerning the mandatory parole restriction were not properly before the court because he was not sentenced under the mandatory minimum provision. Instead, the District Court imposed the parole restriction under its discretionary sentencing power. The court also found that Lee's due process rights were not violated, as he had the opportunity to rebut or correct any information in the presentence investigation report, and the information was not materially false.The Montana Supreme Court affirmed the District Court's judgment, concluding that Lee's sentence was legal and within the statutory parameters. The court declined to review the constitutional and statutory claims related to the mandatory parole restriction and did not find plain error in the due process claim. View "State v. Lee" on Justia Law

Roger and Therese Hutchinson purchased rural property in Madison County, Montana, in 2016, which included an easement for access via a private road. They obtained a title insurance policy from Old Republic National Title Insurance Company. Disputes arose with Nugget Creek Ranch, the owner of the adjoining property, over the use and control of gates on the easement. In 2020, the Hutchinsons sued Nugget Creek, which counterclaimed for declaratory judgment, trespass, nuisance, negligence, slander, defamation, vexatious litigation, and reverse adverse possession. The reverse adverse possession claim was dismissed by the court.The Hutchinsons requested Old Republic to defend them against Nugget Creek's counterclaims, but Old Republic denied coverage, citing policy exclusions for disputes arising from the easement and for actions taken by the insured after the policy date. The Hutchinsons filed a lawsuit against Old Republic for breach of contract and unfair claim settlement practices. The District Court granted summary judgment in favor of Old Republic, finding no duty to defend because the policy excluded coverage for disputes related to the easement and for actions occurring after the policy date.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The court held that Old Republic had no duty to defend the Hutchinsons because the policy explicitly excluded coverage for disputes arising from the easement and for actions taken by the insured after the policy date. The court also noted that the policy did not cover tort claims or actions that occurred after the policy's effective date. Thus, the court concluded that Old Republic unequivocally demonstrated a lack of coverage under the policy. View "Hutchinson v. Old Republic" 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. Concerns about his patient care practices, including manipulation of DNR status, substandard care, and inappropriate chemotherapy treatments, led to an investigation by SPH’s Peer Review Committee (PRC) and Medical Executive Committee (MEC). External reviews from the University of Utah and the Greeley Company supported these concerns, prompting SPH to take corrective actions.The First Judicial District Court, Lewis and Clark County, denied Weiner’s motion for summary judgment and granted summary judgment to SPH, concluding that SPH was entitled to immunity under the Health Care Quality Improvement Act (HCQIA). The court found that SPH’s actions were taken in the reasonable belief that they were in furtherance of quality health care, after a reasonable effort to obtain the facts, and with adequate notice and hearing procedures.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court’s decision. The court held that SPH’s actions met the standards specified in the HCQIA, granting them immunity from damages. The court found that SPH acted reasonably in suspending and ultimately revoking Weiner’s privileges based on substantial evidence of substandard care and potential harm to patients. The court also determined that the imminent harm exception applied, justifying the lack of pre-suspension process for the initial actions. The court concluded that Weiner failed to rebut the presumption of immunity under the HCQIA, and SPH was entitled to immunity from damages for the claims addressed. View "Weiner v. St. Peter's" on Justia Law

Lisa Cole appealed the Eighteenth Judicial District Court, Gallatin County’s decision that precluded her from inheriting the estate of her deceased minor child, M.A.C., who died intestate. M.A.C. tragically died in a car accident in March 2020. At the time, M.A.C. and her brother Mythias were living with their half-sister Samara. Lisa, their natural mother, had not been in contact with her children for some time and had not provided financial support. The insurance company sought to distribute a settlement to M.A.C.'s estate but found no estate had been opened. Attempts to contact Lisa were unsuccessful, leading to the appointment of a personal representative for the estate.The District Court appointed Sunny Yocom as the personal representative after a hearing. The estate petitioned to preclude Lisa from inheriting, citing her refusal to support M.A.C. Lisa opposed the petition and sought to remove Yocom as the personal representative. The court held an evidentiary hearing where Lisa did not appear but was represented by her attorney. Testimonies from family members and school personnel, along with evidence from the Social Security Administration, supported the claim that Lisa had not supported M.A.C. and had misused her survivor benefits.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s decision. The court held that § 72-2-124, MCA, precluded Lisa from inheriting because she had refused to support M.A.C. The court found substantial evidence supporting the District Court’s findings, including testimonies and SSA letters. The court also upheld the denial of Lisa’s motion to appear remotely and her challenges to Yocom’s appointment, finding no merit in her arguments. View "In re Estate of M.A.C." on Justia Law

Scott and Karen Larsen purchased two adjoining lots in the McGuiness Tracts subdivision in the late 1980s, intending to build a house and retire there. Keith and Danielle Sayers, who bought a lot in the same subdivision in 2012 and another adjoining lot in 2016 or 2017, built a freestyle motocross course on their properties. The Larsens, disturbed by the noise and dust from the motocross activities, sent a cease-and-desist letter to the Sayerses, which was ignored. Consequently, the Larsens filed a lawsuit seeking injunctive relief for breach of restrictive covenant, nuisance, and trespass. The Sayerses counterclaimed for intentional infliction of emotional distress.The Second Judicial District Court held a bench trial and ruled that the Sayerses' motocross activities did not violate the restrictive covenants of the subdivision, denying the Larsens' claims for injunctive relief and nuisance. However, the court granted the Larsens' request to enjoin Keith from hitting golf balls onto their property. The court also denied the Sayerses' counterclaim for intentional infliction of emotional distress. The Larsens' motion for attorney’s fees was not ruled upon by the District Court.The Supreme Court of the State of Montana reviewed the case and concluded that the Sayerses' freestyle motocross course constitutes a breach of the restrictive covenants limiting the use of the property to residential or agricultural purposes. The court reversed the District Court's ruling on this basis and remanded the case for the District Court to award the Larsens reasonable attorney’s fees as the prevailing party. The Supreme Court affirmed the District Court's determination that Keith's ramp-building activities did not violate the covenants' restriction against commercial activity. View "Larsen v. Sayers" on Justia Law

Joseph Eugene Garcia was charged with multiple counts of sexual intercourse without consent and sexual abuse of children, involving the repeated rape of an underage boy, C.C., over five years. On the day of the trial, Garcia entered an Alford plea to a single amended charge of felony sexual assault, and the State agreed to drop the original charges and recommend a sentence of forty years, with twenty years suspended. The plea agreement did not address the sex offender tier level designation.The District Court ordered a presentence investigation (PSI) and a psychosexual evaluation (PSE), which were completed by Dr. Robert Page. Dr. Page recommended a tier level 1 sexual offender designation, indicating a low risk of re-offense. However, he noted limitations in the risk assessment tools and suggested that additional victims were likely. At the sentencing hearing, the State presented testimony from several witnesses, including Sergeant Kaylin Cunningham, who provided evidence of Garcia's grooming tactics and possession of items used to manipulate and control his victims. Victim impact statements from C.C. and his mother expressed concerns about Garcia's future risk to children.The District Court sentenced Garcia to forty years in prison, with twenty years suspended, and designated him as a tier level 2 sexual offender, citing the extensive use of grooming tactics and the likelihood of multiple victims. Garcia appealed, arguing that the District Court improperly considered evidence beyond the psychosexual evaluation report in determining his tier level designation.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 interpreted the statute, which allows the court to consider a broad range of information, including victim impact statements and other relevant evidence, when designating a sexual offender tier level. The Court found no abuse of discretion in the District Court's designation of Garcia as a tier level 2 sexual offender. View "State v. Garcia" on Justia Law

GBSB Holding, LLC (GBSB) is the developer of Baker 80, a proposed subdivision adjacent to Whitefish Hills Village (WHV) in Flathead County. GBSB sought to use WHV roads as the primary access to Baker 80, which was opposed by Flathead County, Whitefish Village, LLC, and the WHV Homeowners Association. GBSB also challenged the abandonment of a portion of Brady Way, a county road within WHV, by Flathead County.The Montana Eleventh Judicial District Court prohibited GBSB from using WHV roads as the primary access to Baker 80. The court concluded that the public access easements on WHV roads did not include primary access for Baker 80 residents. Additionally, the court found that Flathead County did not exceed its jurisdiction in abandoning a portion of Brady Way.The Supreme Court of the State of Montana reviewed the case. The court affirmed the District Court's decision, holding that the public access easements on WHV roads were easements in gross, benefiting the public at large and not specifically Baker 80 residents. The court determined that the scope of the public access easements did not extend to primary access for Baker 80. The court also upheld the District Court's conclusion that Flathead County did not exceed its jurisdiction in abandoning a portion of Brady Way, as the abandonment process complied with statutory requirements and substantial evidence supported the Board's decision. View "GBSB Holding v. Flathead County" on Justia Law

Thomas Steiger and Hope VanDelden have two minor children, G.L.M.S. and T.L.S. Thomas filed a Petition for Establishment of a Permanent Parenting Plan in October 2016, which was granted in May 2017 after Hope did not respond or attend the hearing. The plan allowed the children to reside primarily with Thomas and have contact with Hope on alternating weekends, holidays, and up to 14 days of vacation each year. Hope filed a motion to amend the parenting plan in October 2017, claiming Thomas had reduced her parenting time. Thomas’s mother and stepfather also petitioned to intervene, asserting their grandparenting time had been decreased.In October 2023, Hope filed a motion to proceed with mediation to address the parenting plan. After unsuccessful mediation, she filed another motion to amend the plan in January 2024, claiming Thomas did not allow the children to spend additional time with her. Thomas opposed the motion, asserting there was no change in circumstances to warrant an amendment. The District Court set an in-chambers interview with the oldest child, G.L.M.S., but did not hold an evidentiary hearing before granting Hope’s motion to amend the parenting plan in July 2024.The Supreme Court of the State of Montana reviewed the case. The court held that the District Court erred by not holding a hearing on the motion to amend the parenting plan, as required by Montana law unless the motion is denied for lack of adequate cause. The Supreme Court reversed the District Court’s order and remanded the case for a hearing to determine if the statutory criteria for amending the parenting plan were met and to amend the plan in the best interests of the children. View "In Re G.L.M.S. and T.L.S." on Justia Law

Ronald L. Golas was charged with driving under the influence of alcohol (fourth or subsequent offense), operating a motor vehicle while his license was suspended, and failure to carry proof of insurance. These charges stemmed from a one-vehicle crash where Golas was found with an open can of beer and a high alcohol concentration. He had prior DUI convictions and a suspended license. Golas pleaded not guilty and was released on bail with conditions. However, he failed to appear at pretrial conferences and had several positive alcohol tests, leading to a motion to revoke his release and the issuance of a bench warrant.The trial date was rescheduled multiple times due to various issues, including Golas's failure to resolve the outstanding warrant. Eventually, Golas was taken into custody, and a new trial date was set. He filed a motion to dismiss for lack of a speedy trial, which was denied. Golas later requested a change-of-plea hearing and entered a plea agreement, pleading guilty to the felony DUI charge in exchange for the dismissal of the other charges. He was sentenced to 24 months in the Department of Corrections and a consecutive 5-year suspended term in the Montana State Prison.The Montana Supreme Court reviewed the case and held that Golas waived his right to appeal the denial of his motion to dismiss for lack of a speedy trial by not specifically reserving this right in his plea agreement. The court found that Golas's plea was voluntary and intelligent, and there were no jurisdictional defects. Consequently, the court affirmed the District Court's decision. View "State v. Golas" on Justia Law

David Damon pleaded guilty to felony incest and was sentenced to fifty years in prison with ten years suspended. His parole eligibility was contingent upon completing Phases I and II of the prison's sex offender treatment program. After ten years without being enrolled in Phase II, Damon filed a motion to modify his sentence to allow participation in an external residential treatment program. The Eighth Judicial District Court denied his motion, citing a lack of authority to modify the judgment. Damon appealed.The Cascade County District Court initially sentenced Damon in February 2014 after he pleaded guilty to one count of felony incest, dismissing two other charges as part of a plea agreement. Damon was designated a Tier II sex offender and required to complete specific treatment phases before being eligible for parole. In 2017, the Montana Legislature mandated the Department of Corrections (DOC) to adopt evidence-based programs, leading to the replacement of the SABER program with the SO-ICPM program in 2023. Damon argued that the elimination of the SABER program left him unable to meet his sentence requirements and sought modification to attend a residential program.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decision. The court held that the District Court lacked the legal authority to modify Damon's sentence, as the DOC's programming changes did not render the sentence factually erroneous. The court noted that the new SO-ICPM program provided equivalent treatment to the SABER program, allowing Damon to fulfill his sentence requirements. The court also clarified that any request for placement in a residential treatment program must be made through the DOC, not the court. Thus, the District Court's denial of Damon's motion was upheld. View "State v. Damon" on Justia Law