Justia Montana Supreme Court Opinion Summaries

A driver was stopped by a county deputy after allegedly committing traffic violations that led the officer to suspect impaired driving. The officer noted possible signs of intoxication and requested that the driver submit to alcohol testing, which the driver refused. Under Montana’s implied-consent law, the officer seized the driver’s license and issued a notice of automatic six-month suspension. The next day, the driver petitioned for judicial review, arguing that the officer lacked sufficient suspicion for the stop and the test requests.The Eighth Judicial District Court set an evidentiary hearing, but delays resulted from a combination of the petitioner’s request for a continuance due to jury duty and procedural orders requiring both parties to file briefs before a hearing could be held. The petitioner filed a brief, but the State did not, leaving the hearing vacated. Before the court ruled, the six-month suspension expired and the license was reinstated. When the petitioner moved to reset the hearing, the State moved to dismiss the case as moot, arguing that the only relief available was the return of the license, which had already occurred. The District Court agreed and dismissed the petition as moot.The Supreme Court of the State of Montana reviewed whether the expiration of the suspension and reinstatement of the license rendered the case moot. The court held that the case was not moot because the petitioner’s timely challenge could still result in relief, such as removal of the suspension from his driving record and potential reimbursement of reinstatement fees. The court found that the statute contemplates judicial review even after the suspension period if the challenge was timely filed and pursued. The Supreme Court reversed the District Court’s dismissal and remanded the case for further proceedings. View "Kalafat v. State" on Justia Law

The defendant was arrested in October 2021 and charged with robbery and disorderly conduct. Initial proceedings raised concerns about his mental fitness, and he was evaluated at Montana State Hospital. Multiple evaluations between December 2021 and April 2023 determined that he was unfit to proceed, largely due to his refusal to take medication. In October 2022, the court authorized involuntary medication following a Sell v. United States hearing. By April 2023, the defendant was found fit to proceed, and at a subsequent hearing, he was arraigned and entered a plea of not guilty to both charges. In July 2023, a plea agreement was reached where the defendant pleaded guilty to attempted robbery in exchange for dismissal of the disorderly conduct charge.The Fourth Judicial District Court accepted the defendant’s guilty plea after confirming it was entered voluntarily, knowingly, and intelligently. At the change of plea hearing, the defendant expressed concern about a potential speedy trial violation and asked to have it noted for the record. The court acknowledged the statement but declined to accept briefing on the issue, and neither the defendant nor his counsel filed a motion or objected further. The defendant was subsequently sentenced to ten years, with credit for time served.On appeal, the Supreme Court of the State of Montana considered whether the lower court abused its discretion by refusing to accept briefing on the speedy trial issue and whether the issue was preserved for review. The Supreme Court held that by voluntarily and knowingly pleading guilty without first obtaining an adverse ruling on a timely filed motion, the defendant waived all nonjurisdictional defects, including claims of speedy trial violations. The Court also declined to review the claim under the plain-error doctrine, finding no manifest miscarriage of justice. The judgment was affirmed. View "State v. Hill" on Justia Law

Police investigated a domestic disturbance in December 2020 involving the appellant, who was subsequently charged in Yellowstone County, Montana, with his fourth DUI-related offense. The State later amended the charges to include DUI per se for operating a noncommercial vehicle with a blood alcohol concentration of 0.08 or more, fourth or subsequent offense. The appellant entered a plea agreement, pleading guilty to the amended charge in exchange for dismissal of the original DUI charge. At sentencing, both parties recommended specific incarceration and treatment conditions, and agreed to a $5,000 fine. The appellant requested that certain fees be waived due to his financial circumstances.The Thirteenth Judicial District Court accepted the plea, dismissed the original charge, and imposed the recommended sentence, including the mandatory-minimum $5,000 fine under § 61-8-731(1)(a)(iii), MCA (2019). The court also orally stated it would waive several fees. However, the written judgment subsequently entered required the appellant to pay a variety of fees and surcharges, contrary to the oral pronouncement. The appellant appealed, arguing that the mandatory fine was unconstitutional and that the imposition of fees conflicted with the oral pronouncement.The Supreme Court of the State of Montana reviewed the case. Guided by its recent decision in State v. Cole, the Court held that sentencing courts must consider a defendant’s ability to pay when imposing the mandatory-minimum fine and may suspend the portion a defendant is unable to pay. Because the District Court made no findings regarding the appellant’s ability to pay, the Supreme Court reversed the fine and remanded for further proceedings consistent with Cole. The Court also ordered the written judgment to be amended to conform to the fees waived in open court. View "State v. C. Horn" on Justia Law

The defendant was charged in three separate cases with felony offenses in Lake County, Montana, including driving under the influence for a fourth or subsequent offense. The State also sought to revoke a previously imposed suspended sentence in another DUI case. A global plea agreement was reached, and the Twentieth Judicial District Court conducted a combined sentencing hearing. The court imposed consecutive prison terms and, as relevant here, imposed a $5,000 fine for the felony DUI, which it fully suspended after considering the defendant’s financial situation. The written judgment also included a condition allowing the probation office to reinstate suspended fines and fees if the defendant failed to comply with probation terms.The defendant appealed, challenging only two aspects of the judgment: the legality of the $5,000 fine, and the condition permitting the probation office to reinstate suspended financial penalties. The State conceded that the delegation to the probation office was improper but otherwise defended the judgment. The defendant argued that the mandatory minimum fine was unconstitutional, relying on a recent Montana Supreme Court decision. The State countered that the statute at issue was not addressed in that case and urged affirmance.The Supreme Court of the State of Montana reviewed the case. The court held that, consistent with its more recent decision in State v. Cole, it is permissible for a sentencing court to impose the statutory $5,000 minimum fine for felony DUI, provided the court determines the defendant’s ability to pay and uses its authority to suspend the fine as appropriate. The court affirmed the imposition and suspension of the fine, finding the sentence lawful. However, the court held that the district court lacked authority to delegate to the probation office the power to reinstate suspended fines and fees. The case was remanded for entry of an amended judgment striking that condition. View "State v. Trombley" on Justia Law

A county board created a port authority in 2003 to encourage economic development, administering a business park on contaminated land formerly operated by a lumber company. In 2022, the port authority entered into agreements with a private company to clean up and potentially develop the property, culminating in the sale of 105 acres for $1.6 million, with a credit for cleanup costs. The plaintiff alleged that between May 2022 and April 2025, the port authority failed to provide adequate public notice of its meetings or opportunities for public participation regarding the land transactions, in violation of Montana’s open meeting and right to participate laws.The Nineteenth Judicial District Court, Lincoln County, reviewed a motion for a preliminary injunction, which sought to halt any actions pursuant to the port authority’s decisions during the contested period and to void the land sale and related contracts. The District Court denied the injunction, reasoning that the relief sought would not merely enforce open meeting laws but would invalidate completed transactions and disrupt the property’s new ownership and development. The court found that the plaintiff had not demonstrated a likelihood of success on the merits, particularly given the significant passage of time and changes to the property. The court did not resolve contested factual issues about notice or participation, nor did it make any final rulings on the underlying claims.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court manifestly abused its discretion in denying the preliminary injunction. The Supreme Court affirmed, holding that the District Court did not abuse its discretion because the plaintiff failed to establish all required elements for preliminary injunctive relief. The Supreme Court emphasized that the lower court had not decided the merits of the open meeting law claims and left those questions for future proceedings. View "Torgison v. Lincoln County" on Justia Law

Two individuals who are transgender women, one living in Montana and the other in Alaska, challenged recent Montana laws and administrative policies that restrict the ability to amend the sex designation on birth certificates and driver's licenses. These state actions, enacted in response to legislative changes, allow amendments to these documents only in limited circumstances such as clerical errors, not to reflect a person’s gender identity. The plaintiffs argued that these restrictions forced them to carry identification that does not match their gender identity, resulting in concrete harms such as disclosure of their transgender status during routine activities and difficulties in verifying their identity.The case was filed in the First Judicial District Court of Lewis and Clark County. The plaintiffs sought declaratory and injunctive relief, alleging violations of equal protection, right to privacy, and prohibition against compelled speech under the Montana Constitution, as well as violations of the Montana Administrative Procedure Act. The District Court found that the plaintiffs had standing, demonstrated concrete and particularized injuries, and satisfied all four factors required for a preliminary injunction. The court concluded that the policies likely violated Montana’s Equal Protection Clause by discriminating against transgender individuals on the basis of sex, and that the plaintiffs were likely to suffer irreparable harm without relief. The District Court preliminarily enjoined enforcement of the challenged state policies as applied to amending birth certificates and driver’s licenses.The Supreme Court of the State of Montana reviewed whether the plaintiffs had standing and whether the District Court manifestly abused its discretion in granting the preliminary injunction. The Supreme Court affirmed the District Court’s order. It held that the plaintiffs had standing and that the District Court did not abuse its discretion in concluding that the state policies likely constitute unconstitutional sex discrimination under Article II, Section 4 of the Montana Constitution, warranting preliminary injunctive relief. View "Kalarchik v. State" on Justia Law

Two families owned adjacent lots in a five-lot subdivision in Gallatin County, Montana. The land, formerly a horse pasture, was subdivided in 2006. As a condition of subdivision approval, the Montana Department of Environmental Quality (DEQ) required the developer to abandon certain small irrigation ditches crossing the lots, except for one on the east boundary. These requirements were recorded with the subdivision’s plat and were to be referenced in all future property transfers. Despite these requirements, the disputed ditch continued to carry water across several lots, including those eventually purchased by the plaintiffs.After purchasing their lots, the plaintiffs used the ditch water for irrigation, believing they had rights to the ditch based on representations by previous owners and realtors. Years later, the DEQ and local health authorities notified subdivision owners that the continued existence of the ditch violated the terms of the subdivision approval and related sanitation regulations. To comply, the defendants installed culverts, which were approved by authorities. The plaintiffs then sued, claiming the installation of culverts interfered with their implied ditch easement.The case was first reviewed by the Montana Eighteenth Judicial District Court, which granted summary judgment for the defendants. The District Court found that the plaintiffs had no ditch easement—implied or otherwise—because the recorded conditions for subdivision approval required abandonment of the ditches. The court further determined that any intent to allow continued ditch use, necessary for an implied easement, was negated by these recorded conditions.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s rulings. The Supreme Court held that the plaintiffs did not hold an implied easement by existing use, as the circumstances and recorded subdivision restrictions demonstrated no intent to continue the ditch’s use. The Supreme Court also upheld the award of attorney fees and costs to the defendants and remanded for determination of additional fees incurred on appeal. View "Dolan v. Guenther" on Justia Law

The Montana legislature enacted a law, HB 937, and associated administrative rules that imposed new licensure and regulatory requirements specifically on abortion clinics, which were defined as facilities providing abortion-inducing drugs or performing surgical abortions to at least five patients per year. These requirements did not apply to clinics that provided identical medications and procedures exclusively for miscarriage management. Plaintiffs, including two clinics and a nurse practitioner, challenged the law and rules, arguing that they violated the equal protection and privacy rights guaranteed by the Montana Constitution. They asserted that these new requirements could force them to cease providing abortion care, thereby restricting their patients’ access to such services.After the plaintiffs filed their complaint, the First Judicial District Court, Lewis and Clark County, initially granted a temporary restraining order and later a preliminary injunction, preventing enforcement of HB 937 and the associated rules. The District Court found that the plaintiffs were likely to succeed on their equal protection claim, that irreparable harm was likely absent an injunction, that the balance of equities favored the plaintiffs, and that an injunction was in the public interest. The court determined that the law treated similarly situated providers—those giving identical care for either miscarriage or abortion—differently solely based on the purpose of the treatment. The court applied strict scrutiny, finding that the state had not demonstrated a compelling interest or that the law was narrowly tailored.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s preliminary injunction. The Supreme Court held that HB 937 and the rules likely violate the Montana Constitution’s guarantee of equal protection by subjecting abortion providers to unique, burdensome licensing requirements not imposed on providers of identical miscarriage care, thus likely infringing on the fundamental right to privacy. The Court concluded that the plaintiffs met all four elements required for a preliminary injunction and affirmed the lower court’s order in its entirety. View "All Families v. State" on Justia Law

The defendant was charged with operating a motor vehicle with a blood alcohol concentration of .08% or greater (DUI per se), first offense, in the City of Whitefish, Montana. He pleaded guilty pursuant to a plea agreement that recommended a fine and surcharge, but also requested the court consider his ability to pay and suspend the fine if warranted. At sentencing, the defendant, then 73 years old, testified about his limited financial means, relying solely on Social Security income. The Municipal Court, while sympathetic, imposed the statutory $600 minimum fine, finding it lacked discretion to suspend it, but waived the surcharge.The defendant appealed to the Eleventh Judicial District Court, which affirmed the Municipal Court’s decision. On further appeal, the Montana Supreme Court, in a prior decision (City of Whitefish v. Curran, 2023 MT 118), found that the Municipal Court had the authority to consider alternatives to full payment of the fine and remanded for consideration of such alternatives. On remand, the Municipal Court held a new hearing, again reviewed the defendant’s financial circumstances, and suspended the $600 fine in its entirety, conditioned on the defendant’s completion of court-ordered alcohol education.The Supreme Court of the State of Montana reviewed the case. It held that the applicable sentencing statutes require sentencing courts to determine a defendant’s ability to pay fines and allow courts to suspend mandatory minimum fines to the extent a defendant cannot pay. The Supreme Court found that the Municipal Court complied with these statutory requirements by considering the defendant’s ability to pay, imposing the statutory fine, and then suspending it. The Supreme Court affirmed the District Court’s order upholding the Municipal Court’s sentence and judgment. View "City of Whitefish v. Curran" on Justia Law

A group of business and industry associations challenged the Montana Attorney General’s March 6, 2026 determination that Proposed Ballot Measure No. 10 was legally sufficient to proceed in the initiative process. Ballot Measure No. 10 sought to amend state law by defining “artificial persons” and excluding “political spending power” from the rights granted to such entities. The challengers argued that the measure was facially unconstitutional because it restricted political speech, was vague, and improperly conditioned benefits on the waiver of constitutional rights.The challenge was brought directly to the Supreme Court of the State of Montana under its original jurisdiction. The Attorney General had performed only a procedural review, declining to address the measure’s substantive constitutionality due to a prior order by the First Judicial District Court in Ellingson v. State, which had enjoined the statutory provision that would have allowed such substantive review. The petitioners requested the Supreme Court to require the Attorney General to review the measure’s constitutionality and to reverse his finding of legal sufficiency.The Supreme Court of the State of Montana held that the Attorney General does not have authority to consider the substantive constitutionality of proposed ballot initiatives during legal sufficiency review under current law and precedent. The Court reaffirmed that pre-election constitutional challenges to initiatives are generally disfavored, as the people have a constitutional right to use the initiative process. Because Ballot Measure No. 10 had not yet qualified for the ballot, the Court declined to address the merits of the constitutional arguments, finding such review would be advisory. The Court denied and dismissed the petition, and also denied as moot motions to intervene and to file amicus briefs. View "Montana Mining Assn. v. Knudsen" on Justia Law