Justia Montana Supreme Court Opinion Summaries

Appellant entered Alford pleas to the felony offenses of aggravated kidnapping, aggravated assault, assault with a weapon, intimidation, and aggravated burglary. Appellant later moved to withdraw his Alford pleas, contending that his mental state at the time of the pleas precluded him from knowingly and voluntarily making a plea decision, he was innocent to the changes against him, and the district court's colloquy was insufficient to determine whether the pleas were knowingly and voluntarily made. The district court denied Appellant's motion. The Supreme Court affirmed, holding (1) Appellant failed to establish that there was good cause to allow him to withdraw his prior Alford pleas to the charges against him; and (2) the matter should be remanded to the district court for a determination of the total amount of restitution for the victim's future counseling costs. Remanded. View "State v. Peterson" on Justia Law

Appellant, a vocational agricultural teacher at a high school, served as faculty advisor for the school's chapter of the National FFA Organization. Appellant obtained a loan on behalf of the school FFA and opened a checking account into which she deposited the loan proceeds. Because Appellant did not deposit the funds in an account maintained by the school district, Appellant violated the school district financial policy and was suspended. Appellant then made out a check to herself to purportedly reimburse herself for expenses incurred in setting up a hay cutting business. The Board of Trustees subsequently terminated Appellant's employment. The Montana Department of Labor and Industry determined that Appellant was eligible to receive benefits, but a hearing officer concluded that Appellant had been discharged for misconduct and was ineligible to receive unemployment insurance benefits. The Board of Labor Appeals affirmed the determination. The Supreme Court affirmed, holding that Appellant's actions constituted misconduct, and she was therefore ineligible to receive unemployment insurance benefits. View "Roberts v. State Bd. of Labor Appeals" on Justia Law

This case involved L.A., who suffered from schizophrenia. Following her release from her previous commitment, the State filed a petition for involuntary commitment of L.A. After a trial, the jury concluded by special verdict that L.A. was suffering from a mental disorder, was unable to provide for her basic needs, and was a threat of injury to herself or others. The jury also found that if L.A.'s condition were left untreated, it would deteriorate. Following the verdict, the district court adopted an order of commitment and transport order prepared by the State that committed L.A. to the state hospital and approved involuntary medication if it was deemed necessary. The Supreme Court affirmed, holding that the district court did not err by (1) failing to make a detailed statement of facts in its post-trial disposition order; and (2) failing to detail the particular evidence upon which its findings and conclusions were based in authorizing L.A's involuntary medication. View "In re L.A." on Justia Law

Johnathon Alfson was injured when Jack McCoy rear-ended Alfson's truck. Because Alfson was unable to return to work he demanded that Allstate Property and Casualty Insurance Company, McCoy's insurer, pay his lost wages in advance of any settlement. Alfson then filed an action seeking a declaration requiring Allstate to issue advance payments for lost wages in the amount of $24,117. The district court granted summary judgment in Alfson's favor and issued a declaratory judgment requiring Allstate to advance pay Alfson's lost wages. The Supreme Court reversed, holding that because the district court considered and relied upon informal letters not supported by sworn affidavits or discovery responses, the court's grant of summary judgment in Alfson's favor and declaratory judgment based on that summary judgment grant were legally infirm. View "Alfson v. Allstate" on Justia Law

After police officers knocked on the door to Defendant's residence to ask for directions they confiscated forty plants of marijuana. Defendant pled guilty to criminal production or manufacture of dangerous drugs, a felony. Defendant appealed the denial of his motion to suppress the results of the search of his residence, arguing that because officers had no reason to enter his property, they were not lawfully in a place where they could see the marijuana in plain view. The Supreme Court (1) affirmed the district court's denial of Defendant's motion to suppress, as the officers were lawfully on Defendant's property, and thus their observations of the marijuana in plain view were an appropriate basis for the charges; but (2) reversed the district court's imposition of the cost of court-appointed counsel, as the amount of that cost exceeded the statutorily allowed amount. View "State v. Phillips" on Justia Law

After a jury trial, Defendant was convicted of two counts of sexual assault and sentenced to concurrent 100 year sentences, with fifty years of each sentence suspended. The Supreme Court affirmed, holding that Defendant's trial counsel did not render ineffective assistance in (1) failing to object to the admission of certain incidences of hearsay testimony by various witnesses, as the testimony either fell among the hearsay exceptions provided for in the Montana Rules of Evidence or defense counsel may have had strategic reasons for not objecting; and (2) stipulating to the admission of multiple items of evidence that Defendant alleged contained otherwise inadmissible hearsay evidence, as Defendant's allegations implicated questions of trial strategy that exceeded the scope of the record. View "State v. Mederos" on Justia Law

Defendant pleaded no contest to one count of felony criminal endangerment pursuant to a plea agreement. Prior to sentencing, Defendant filed a motion to withdraw his plea, which the district court denied. The district court then imposed a ten-year suspended sentence. Defendant filed a motion to withdraw his plea, arguing that the district court failed to establish a sufficient factual basis for his no contest plea, and therefore, there was doubt as to whether Defendant entered his plea voluntarily. The Supreme Court affirmed, holding that the district court did not err by denying Defendant's motion to withdraw plea, as the district court established a sufficient factual basis for the offense, Defendant was made aware of the consequences of the plea, and the plea was made voluntarily. View "State v. Jackson" on Justia Law

Thomas Warner filed a complaint against Robert and Rebecca Hanke for conversion and negligence after Robert Hanke asserted ownership over some personal property Warner was storing on the Hanke's property. At the time the action was filed, Robert and Rebecca Hankes maintained home insurance coverage from a subsidiary of Horace Mann Insurance Company. The Hankes filed a claim with Horace Mann to request a defense against Warner's suit. Horace Mann filed a declaratory judgment action requesting a determination whether the insurance policy required Horace Mann to defend the Hankes. The district court concluded that Horace Mann did not owe coverage to the Hankes for the Warner dispute. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court (1) properly determined that the Hankes' insurance policy failed to cover the Warner dispute; (2) correctly determined that Horace Mann's decisions to provide a defense and to pay the settlement of Warner's claims nevertheless allowed Horace Mann to pursue reimbursement for the Hankes' share of the settlement; and (3) abused its discretion in awarding attorney's fees to Horace Mann. View "Horace Mann Ins. Co. v. Hanke" on Justia Law

Defendants, an attorney and a law firm, structured a tax-deferred exchange for Plaintiffs, a husband and wife and the cattle ranch they owned. It was later determined that the exchange did not qualify for deferred tax treatment under 26 U.S.C. 1031, resulting in significant tax liability for Plaintiffs. Defendants filed an action against Defendants for professional negligence, breach of fiduciary duty, breach of contract, breach of the implied covenant of good faith and fair dealing, and misrepresentation. The district court granted summary judgment to Defendants on all claims on grounds that Plaintiffs' claims were time barred. The Supreme Court reversed, holding (1) Plaintiffs' tort claims were timely filed, and the issue of whether Plaintiffs' timely filed their misrepresentation claim was a question of material fact to be resolved by a jury; (2) Plaintiffs properly stated a claim for breach of contract and the claim was not time barred; and (3) the district court erred in granting Defendants a protection order to prevent discovery of alleged work product and attorney-client communications, as further analysis and fact finding were necessary to determine which documents were discoverable and which qualified for work product or attorney-client protection. Remanded. View "Draggin' Y Cattle Co., Inc. v. Addink" on Justia Law

C.R. Weaver formed Mikart Transport, LLC in January 2011. At that time, the articles of organization named Weaver and Michael Smith as members or managers. In March 2011, Smith submitted a credit application with Tri-County Implement, Inc. After Smith failed to pay Tri-County for work it performed on two vehicles, including a Volvo semi-truck titled in Weaver's name, Tri-County refused to release the Volvo from its possession pursuant to its asserted agisters' lien on the vehicle. Weaver subsequently filed a complaint against Tri-County. In response, Tri-County filed a counterclaim against Weaver and a third-party complaint against Mikart. The district court entered judgment against Mikart, ordering it to pay for the work it performed, and awarded Tri-County attorney fees and costs. The court also held Mikart, Smith, and Weaver jointly and severally liable for these amounts. The Supreme Court reversed the portion of the district court's imposition of personal liability on Weaver for the work performed on the two vehicles, as there was no basis to hold Weaver individually liable for the obligations of Mikart to Tri-County. Remanded. View "Tri-County Implement, Inc. v. Weaver" on Justia Law