Justia Montana Supreme Court Opinion Summaries

Plaintiffs Dorothy Harris and Tedeen Holbert were injured in separate automobile accidents caused by third-party tortfeasors. Plaintiffs were treated at Billings Clinic and St. Vincent Healthcare (Providers) for their injuries. Both Harris and Holbert were members of health plans administered by Blue Cross Blue Shield (BCBS), which entered into a preferred provider agreement (PPA) with the Providers pursuant to which Providers accepted payment from BCBS at a discounted reimbursement rate for certain medical services for BCBS insureds. Plaintiffs subsequently filed a complaint against Billings Clinic, asserting breach of contract and constructive fraud claims and requesting compensatory damages equal to the difference between the amount the third-party insurers paid to the Providers and the reduced reimbursement rates under the PPA with BCBS. Harris also filed similar claims against St. Vincent Healthcare. The district courts dismissed the claims for failure to state a claim upon which relief can be granted. The Supreme Court affirmed, holding that the district court did not err in determining that the Providers were entitled to collect from third-party insurers payment for the full amount of the billed charges for the medical treatment provided to Plaintiffs. View "Harris v. St Vincent Healthcare" on Justia Law

Defendant pled guilty to felony DUI offenses and associated offenses, including two misdemeanor offenses. After Defendant began serving his period of probation, the State filed a petition to revoke Defendant's probation based upon his violation of certain conditions of probation. The district court issued a bench warrant for Defendant's arrest, but Defendant had absconded from supervision. Eight years later, the State petitioned the district court to quash the original arrest warrant and to issue a new warrant for Defendant's arrest. Defendant was subsequently arrested and sentenced. Defendant appealed, arguing that the eight-year delay between the initial arrest warrant and his actual arrest violated his right to due process. The Supreme Court remanded for resentencing, as the district court may have imposed a longer period of imprisonment than allowed. View "State v. Sullivant" on Justia Law

Defendant was charged with criminal possession of dangerous drugs with intent to distribute and was appointed counsel. A jury subsequently found Defendant guilty of criminal possession with intent to distribute. The Supreme Court affirmed, holding (1) the district court's pre-trial inquiry into Defendant's complaint about his counsel was adequate, and the court did not abuse its discretion by declining to further consider Defendant's complaints in a hearing; (2) the district court did not err in denying Defendant's motion for a new trial; and (3) the case was remanded so that the district court may conform the written judgment to the oral pronouncement of sentence, which conditioned any assessment of fees upon Defendant's future ability to obtain work if released on parole. View "State v. Hammer" on Justia Law

After a jury trial, Defendant was found guilty of felony DUI and driving without a valid driver's license. Defendant subsequently filed a motion to vacate his convictions primarily on the grounds that he had not received a probable cause hearing within forty-eight hours of his arrest. The district court denied Defendant's motion. The Supreme Court affirmed, holding that Defendant waived his right to complain that nineteen days was an unreasonable time for the State to initiate filing charges in the district court by failing to object or file a motion to dismiss before his trial. View "State v. Haller" on Justia Law

After Edwin and Linda divorced, Linda obtained a New Jersey judgment ordering Edwin to pay $695,477 in unpaid alimony, unpaid child support, medical expenses, and attorney fees and costs. Linda subsequently filed a motion seeking to satisfy the New Jersey judgment with Edwin's interest in a Nevada limited liability corporation (BMR) licensed to do business in Montana and with assets in Montana. A writ of execution was issued against Edwin, and thereafter, the district court issued a charging order and an order for the appointment of a receiver, for foreclosure of the lien, and for the sale of BMR's property. Edwin subsequently filed a motion for relief from the charging order and order for the appointment of the receiver foreclosure of the lien, which the district court denied after concluding that Edwin's arguments were waived because he had foregone earlier opportunities to challenge the two orders on the bases he asserted. The Supreme Court affirmed, holding (1) the district court correctly applied the law of the case doctrine to deny Edwin's motion; and (2) because Edwin's appeal was vexatious and filed for the purposes of delay, costs and fees assessed should be solely levied against Edwin. Remanded. View "Jonas v. Jonas" on Justia Law

Mother was the biological parent of four children, including J.W. Before J.W. was born, a Colorado court terminated Mother's rights to two of her children. After Mother gave birth to J.W. and J.W. was removed from Mother's custody, a Montana district court found it was in the best interests of J.W. to terminate Mother's parental rights. The district court reasoned that reunification efforts were unnecessary because Mother had her parental rights to her other children terminated, and the circumstances related to those terminations were "identical" to mother's unfit parenting of J.W. Mother appealed, arguing that her previously unfit parenting in Colorado should not provide a basis for terminating her parental rights to J.W. The Supreme Court affirmed, holding that the district court (1) did not err by failing to conduct a permanency plan hearing; and (2) did not err by concluding that the circumstances surrounding Mother's prior terminations in Colorado were relevant to her parenting of J.W. View "In re J.W." on Justia Law

After a jury trial, Defendant was convicted of felony sexual assault and sentenced to forty years imprisonment. The district court imposed a restitution obligation of $1,583 with an ongoing obligation to the extent the victim required additional or ongoing treatment. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the district court did not abuse its discretion in denying Defendant's for-cause challenge of a prospective juror; (2) the district court did not abuse its discretion in admitting a forensic interviewer's opinion testimony; (3) the district court properly admitted the victim's prior consistent statements; and (4) the district court erred in imposing a restitution obligation that was not for a "specified amount." Remanded to the district court to set a specified amount for restitution for future costs. View "State v. Champagne" on Justia Law

On July 25, the State charged Defendant with partner or family member assault (PFMA), alleging that the pending charge was a felony. Defendant pled not guilty on August 18. On October 26, the district court dismissed the felony charge. The State then filed a misdemeanor PFMA charge against Defendant. On November 15, Defendant pled not guilty to the misdemeanor charge. The case was set for trial on May 5. Defendant filed a motion to dismiss for failure to provide a speedy trial, alleging that the State failed to bring his case to trial within six months of his initial plea on the dismissed felony PFMA charge. Defendant's motion to dismiss was denied, and Defendant pled guilty to the reduced charge of disorderly conduct, a misdemeanor. The Supreme Court affirmed, holding that the district court (1) correctly concluded that Defendant's not guilty plea to the felony PFMA charge was irrelevant in determining whether Defendant's right to a speedy trial had been violated; and (2) correctly concluded that Defendant's right to a speedy trial had not been violated when he filed his motion to dismiss less than six months after pleading not guilty to the misdemeanor PFMA charge. View "State v. Case" on Justia Law

A plane owned by Metro Aviation crashed in Montana, killing two passengers. Metro filed suit under against the United States in a U.S. district court in Montana, alleging negligence by FAA air traffic controllers. Metro asserted alternative claims of indemnity and contribution seeking to recover settlement amounts paid by Metro to the passengers' estates. The case was subsequently transferred to a U.S. district court in Utah. The United States moved for partial summary judgment on Metro's indemnity and contribution claims, asserting that under Utah and Montana law, the claims were barred. The federal Utah court concluded that Montana law applied but that the law in this area was unsettled. The Montana Supreme Court accepted the court's certified questions about these questions of law and answered, (1) Metro could not seek contribution from the United States with respect to the estate of one passenger, whose claim was settled without any litigation having been filed; (2) Metro could not seek contribution from the United States with respect to the estate of the second passenger because Metro settled with the estate prior to trial without joining the United States as a party; and (3) Metro was not entitled to indemnity from the United States. View "Metro Aviation, Inc. v. United States" on Justia Law

Husband and Wife separated in 2010, after which Wife filed a petition for dissolution of marriage. The district court (1) determined that any interest Husband might receive from his mother's trust did not impact the marital estate; (2) determined that the marital home should be sold and the proceeds split between the parties; and (3) determined that each party should be responsible for their own student loan debt and business loans. Wife appealed. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by excluding Husband's interest in his mother's trust from the marital estate; (2) the district court equitably distributed the marital estate; and (3) Husband was not entitled to attorney's fees and costs on appeal. View "In re Marriage of Parker" on Justia Law