Justia Montana Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of two counts of felony sexual abuse of children for having engaged in sexually-related conduct online with a deputy sheriff who represented himself as a fourteen-year-old female. Defendant was arrested based on his potential plans to travel to Montana to meet the supposed fourteen-year-old in person. The Supreme Court affirmed Defendant's convictions, holding (1) Montana's sexual abuse of children statute does not violate the First Amendment and the Commerce Clause by sweeping too broadly; and (2) the district court properly authenticated extensive internet chat logs and properly admitted them into evidence, and the court's ruling did not unfairly prejudice Defendant. View "State v. Hantz" on Justia Law

After the district court adjudicated A.R.B. a youth in need of care, A.R.B. was placed in foster care with a Utah family. A.R.B.'s mother (Mother), who traveled from Utah to Montana to have her baby, filed a motion to relinquish jurisdiction from Montana to Utah, arguing (1) once Mother went to Utah and the Department placed A.R.B. with the Utah foster family, Montana no longer had exclusive, continuing jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act; and (2) the district court should decline to exercise jurisdiction because Utah constituted a more convenient forum. The district court denied Mother's motion to relinquish jurisdiction and terminated Mother's parental rights. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in declining to relinquish jurisdiction in this case; and (2) the district court was within its discretion in declining Mother's request to declare Montana an inconvenient forum. View "In re A.R.B." on Justia Law

In this water right adjudication, the Water Master concluded that the water right of Claimants, property owners, had been abandoned. Claimants filed an objection to the Water Master's report, arguing, among other things, that the Water Master's application of 79 Ranch v. Pitsch to their existing right was an impermissible retroactive application of the law. The Water Court ruled (1) 79 Ranch applied to Claimants' case; but (2) the Water Master erred in finding that Claimants had failed to produce sufficient evidence to rebut the presumption of intent to abandon. The Supreme Court affirmed, holding that the Water Court (1) correctly applied 79 Ranch analysis; and (2) correctly concluded that Claimants submitted sufficient evidence to rebut the presumption of abandonment. View "Heavirland v. State" on Justia Law

Bank and Lumber Company had business and financial relationships with Sawmill. A few years into its operation, Sawmill began experiencing serious financial difficulties. Sawmill defaulted on approximately $1.4 million in loan obligations to Bank and owed Lumber Company approximately $900,000. Proceedings were initiated in bankruptcy court and district court. While the cases were pending, Sawmill was destroyed by fire. Bank recovered approximately $980,000 from Sawmill's insurance proceeds. In a subsequent case between Bank and Lumber Company, the jury determined that neither Bank nor Lumber Company was entitled to recover damages from the other. The Supreme Court affirmed, holding that the district court did not abuse its discretion in refusing to admit into evidence a particular letter written by the Bank president. View "H.E. Simpson Lumber Co. v. Three Rivers Bank of Mont." on Justia Law

After a jury trial, Defendant was convicted of aggravated assault. The Supreme Court affirmed, holding (1) the district court did not err in refusing to dismiss the charges against Defendant when, after Defendant disclosed information and defense strategies to the State Medical Examiner, communication occurred between the Medical Examiner and the County Attorney; (2) the district court properly determined that the State's witnesses were not unnecessarily cumulative or unfairly prejudicial to Defendant; (3) the district court did not abuse its discretion when it determined that the State's evidence was not so prejudicial as to render the trial fundamentally unfair; (4) the district court did not abuse its discretion in denying Defendant's motion for a new trial on the grounds of prosecutorial misconduct; and (5) Defendant's counsel did not provide ineffective assistance. View "State v. Ugalde" on Justia Law

Dean and Nancy Ziehl contended that they owned a prescriptive easement over a portion of dock located on the Swan River that extended onto Gayle Pederson's property. The Ziehls argued that the easement allowed them to maintain and use the entire dock. The district court concluded that the Ziehls did not hold a prescriptive easement and ordered that the intruding portion of dock be removed and costs be awarded to Pederson. The Supreme Court affirmed, holding that the district court did not err by determining that the Ziehls failed to use the dock adversely for the required statutory period in order to obtain the prescriptive easement. View "Pedersen v. Ziehl" on Justia Law

Carol Miller, the owner of two adjacent parcels of real property, conveyed one of the parcels to the Biggerstaffs in 2005. In the conveyance, Miller purported to reserve an easement over the Biggerstaffs' parcel for the benefit of her retained parcel. In 2006, Miller conveyed her retained pracel to Yorlum Properties. Later, a dispute arose among Yorlum, the Biggerstaffs, and Lincoln County concerning the validity of the reserved easement. In 2011, Yorlum filed the instant action seeking to quiet title to its property and access rights. The district court granted summary judgment to Yorlum. The Supreme Court affirmed, holding (1) the easement over the Biggerstaffs' parcel was valid; (2) The Biggerstaffs and Lincoln County failed to establish any basis that Miller lacked title to convey to Yorlum; and (3) Yorlum's complaint was not barred by equitable principles. View "Yorlum Props., Ltd. v. Lincoln County" on Justia Law

After a jury trial, Defendant was convicted of two counts of attempted deliberate homicide. The Supreme Court affirmed Defendant's convictions and sentence, holding (1) the district court correctly denied Defendant's motion for a new trial based on juror misconduct; (2) the district court id not err by failing to inquire into Defendant's ineffective assistance of counsel claim and the voluntariness of his decision to represent himself; (3) the district court correctly concluded that Defendant was not deprived of his right to speedy trial; (4) the district court did not err by admitting evidence of Defendant's prior assault of his wife; (5) a jury instruction on mitigated deliberate homicide did not rise to the level of plain error; and (6) the district court properly imposed parole conditions. View "State v. MacGregor" on Justia Law

Heath and Vail Freyer, the parents of Alicia Freyer, were all riding in their vehicle, which was insured by State Farm, when the vehicle rolled over, causing Health's death. In Freyer I, the Court held that the subject policy provided coverage for Alicia's claim for derivative damages stemming from Health's death. After remand, State Farm paid the disputed coverage amounts. The Freyers then brought claims against State Farm for the wrongful denial of coverage for Alicia's derivative claims. The district court granted summary judgment to State Farm. The Supreme Court reversed in part and affirmed in part, holding that the district court (1) erred in concluding that State Farm had not breached the insurance contract when it failed to indemnify Vail for Alicia's derivative claims based on State Farm's "reasonable basis in law" defense; (2) properly granted summary judgment to State Farm on the common-law bad faith and breach of the covenant of good faith and fair dealing claims; and (3) did not err in granting summary judgment to State Farm on the Unfair Trade Practices Act claims. View "State Farm Mut. Auto. Ins. Co. v. Freyer" on Justia Law

While attending Wolf Point High School, Dalton Gourneau committed suicide in his home. Roxanne Gourneau, acting individually and on behalf of Dalton, filed a complaint against Wolf Point, the State, and the District Superintendent, alleging that Dalton's death was the direct and proximate result of Wolf Point's negligence. The district court granted summary judgment in favor of Wolf Point. The Supreme Court affirmed, holding that the record did not substantiate Roxanne's speculation that Wolf Point reasonably should have known Dalton's state of mind or that its conduct created a reasonable possibility of harm, and thus, Wolf Point owed no legal duty because Dalton's suicide was unforeseeable by Wolf Point. View "Gourneau v. Wolf Point Sch. Bd." on Justia Law