Justia Montana Supreme Court Opinion Summaries

In this case, defendant Bradley Alan Stokes appealed his convictions from the Fourteenth Judicial District Court, Musselshell County, for both burglary and assault with a weapon. Stokes was charged with these crimes following an altercation at the home of Michael Benson, in which he used a crowbar to break into the residence and assaulted Benson with the crowbar. He was convicted of burglary and assault with a weapon, both felonies. There was agreement that Stokes could not be convicted of both charges, as the assault with a weapon charge was the predicate offense for the burglary conviction. The dispute concerned which of the convictions should be vacated and whether the case should be remanded for resentencing.The Supreme Court of the State of Montana reversed Stokes's conviction for assault with a weapon, as it was determined to be the predicate offense that merged into the principal offense of burglary. The court held that the assault with a weapon conviction should be vacated, following the precedent that when a criminal defendant is improperly convicted of two offenses arising from the same transaction, the remedy is to reverse the conviction for the lesser-included offense only and remand for resentencing. Therefore, the court remanded the case to the District Court to vacate the assault with a weapon conviction and for resentencing on the remaining burglary conviction. View "State v. Stokes" on Justia Law

Shawn Fowler, a former Montana state trooper, sued the Department of Justice, Montana Highway Patrol (MHP) alleging constructive discharge in violation of the Wrongful Discharge from Employment Act (WDEA). He also alleged breach of contract by the Montana Public Employees Association (MPEA) for declining his request to arbitrate. Fowler claimed that he was forced to retire due to a hostile work environment, which was mainly due to disciplinary action taken against him for mishandling two suspected DUI traffic stops in 2017. The MHP argued that Fowler, who was covered by a collective bargaining agreement (CBA), failed to exhaust the grievance procedures of the CBA before filing a lawsuit.The Supreme Court of the State of Montana reversed the judgment of the Sixth Judicial District Court, Park County. The Supreme Court held that an employee covered by a CBA can't bring a claim under the WDEA. The Court determined that Fowler’s alleged constructive discharge was covered by the CBA and he was required to exhaust the grievance procedures for a constructive discharge through the CBA. The Court found that Fowler did not grieve any of the events preceding his suspension, which he claimed contributed to his constructive discharge, and he resigned from employment prior to exhausting the grievance procedure of the CBA. The Court concluded that the District Court erred in denying the State’s two motions for summary judgment and reversed the judgment. View "Fowler v. Department of Justice" on Justia Law

The defendant, Jacob Palmer, was found guilty of felony Partner or Family Member Assault (PFMA) by the Eleventh Judicial District Court, Flathead County, following an incident where he attacked his girlfriend, K.Y., with whom he had been in a relationship for over a decade. During his trial, evidence was presented regarding prior altercations between Palmer and K.Y. Palmer appealed to the Supreme Court of the State of Montana, challenging the District Court's decision to admit this evidence.The issue before the Supreme Court of Montana was whether the District Court had abused its discretion by admitting evidence of Palmer's prior altercations with K.Y. in his PFMA trial. The Supreme Court held that the District Court had not abused its discretion. The court reasoned that the evidence of Palmer's previous altercations with K.Y. was relevant and admissible under Montana Rule of Evidence 404(b). The court explained that such evidence can provide context about the complex dynamics of domestic violence, including the cycle of abuse and the reasons why victims such as K.Y. might not immediately report the abuse or might be reluctant to discuss the abuse with law enforcement. The court further determined that the probative value of this evidence was not significantly outweighed by its potential prejudicial effect against Palmer. As such, the court affirmed the District Court's decision to admit the evidence and upheld Palmer's conviction. View "State v. Palmer" on Justia Law

The case involves an appellant, M.T.H., who was arrested for criminal endangerment after he pulled the steering wheel in his mother's vehicle while she was driving. M.T.H. was diagnosed with major depressive disorder and paranoid schizophrenia. Following his arrest, the State filed a petition for M.T.H.'s involuntary commitment to the Montana State Hospital (MSH) for up to three months. The District Court of the Twenty-First Judicial District, Ravalli County, ordered his commitment and authorized MSH to involuntarily administer medications to M.T.H. This led to an appeal to the Supreme Court of the State of Montana.The Supreme Court of Montana had two main issues to consider. The first issue was whether the District Court erroneously determined that a signed waiver constituted a sufficient record to commit M.T.H. The Supreme Court found that M.T.H.'s waiver and the District Court’s order committing him were sufficient to constitute an intentional and knowing waiver under the relevant statute. The court emphasized that the record reflected that M.T.H. understood his procedural rights and had a clear presence of mind to consider his position logically.The second issue was whether the District Court erroneously authorized MSH to administer involuntary medications to M.T.H. The Supreme Court held that the District Court erred in this aspect. It emphasized the importance of due process protections and noted that the State must demonstrate a need for involuntary medication before a court may authorize it. In this case, the State did not make this necessary showing. Therefore, the Supreme Court affirmed the District Court’s decision in part but reversed its decision to authorize involuntary medication for M.T.H. View "In re M.T.H." on Justia Law

The Supreme Court of the State of Montana was tasked with determining whether the Municipal Court had sufficient evidence to enter a permanent order of protection against the appellant, Alda Bighorn. Bighorn was prohibited from having contact with her grandchild, L.D.F.S, unless supervised, due to allegations made by L.D.F.S's mother, Camille Fritzler. Fritzler alleged that Bighorn had taken L.D.F.S to a family gathering while intoxicated and seeking narcotics, and was planning to enroll L.D.F.S with a Native tribe to gain custody over her. These allegations were not corroborated by any witness testimony or other evidence, but the Municipal Court granted a permanent order of protection against Bighorn. Bighorn appealed this decision, and the District Court affirmed the Municipal Court's ruling.The Supreme Court of the State of Montana reversed the lower courts' decisions, ruling that the Municipal Court had abused its discretion by granting the permanent order of protection without any substantial, credible evidence supporting Fritzler's allegations. The Supreme Court noted that hearsay allegations may be sufficient to support issuing a temporary order of protection, but not a permanent one. Furthermore, the court deemed it improper for the lower court to issue a visitation order for a grandparent in a protection order proceeding, stating that grandparent visitation should be established by filing a petition under the relevant statute. The case was remanded to the Municipal Court to vacate and rescind the permanent order of protection against Bighorn. View "Fritzler v. Bighorn" on Justia Law

Duane Burchill was convicted of two counts of robbery, one count of conspiracy to commit deceptive practices, and one count of possession of dangerous drugs in 2017. Following his conviction, Burchill filed a petition for postconviction relief, asserting that his counsel provided ineffective assistance by failing to object to the prosecutor’s misconduct during his trial. The Supreme Court of the State of Montana affirmed the denial of Burchill's petition for postconviction relief.Burchill's claim of ineffective assistance centered on two main arguments. First, he argued that the prosecutor repeatedly asked him to comment on the credibility of other witnesses by asking "were they lying" questions. Second, he alleged that the prosecutor posed questions suggesting his personal opinion that Burchill's testimony was not truthful.The court, however, found that the "were they lying" questions were not improper because they had probative value in evaluating the credibility of a defendant who is claiming that everyone else is lying. The court also disagreed that the prosecutor had expressed personal opinions on Burchill's credibility. The court concluded that the prosecutor's questions were within the scope of permissible questions allowed on cross-examination. Therefore, the court found that Burchill's counsel's failure to object did not constitute ineffective assistance.The court did not find it necessary to address Burchill's claim of prejudice due to the failure of his counsel to object, as it had already determined that his counsel's performance was not deficient. Thus, Burchill's petition for postconviction relief was denied. View "Burchill v. State" on Justia Law

In Montana, a group of plaintiffs, including Forward Montana, Leo Gallagher, Montana Association of Criminal Defense Lawyers, and Gary Zadick, challenged two amendments to Senate Bill 319 (SB 319) on the grounds that they violated Article V, Section 11 of the Montana Constitution. The amendments, added in the final days of the legislative session without public comment, expanded the bill's scope beyond its initial focus on campaign finance to include regulations on political activities on college campuses and judicial recusal requirements. The District Court found that the amendments violated the Single Subject Rule and Rule on Amendments of the Montana Constitution, and permanently enjoined their enforcement. However, the court declined to award attorney fees to the plaintiffs under the private attorney general doctrine, reasoning that the case was a "garden-variety" constitutional challenge.Upon appeal, the Supreme Court of the State of Montana disagreed, reversing and remanding the decision regarding attorney fees. The court held that the plaintiffs had satisfied all three factors required for attorney fees under the private attorney general doctrine: the societal importance of the public policy vindicated by the litigation (constitutional limitations on legislative power), the necessity for private enforcement and the burden on the plaintiffs, and the large number of people standing to benefit from the decision. Despite the District Court's finding that the case was a "garden-variety" constitutional challenge, the Supreme Court determined that the Legislature's willful disregard of constitutional duties and legislative rules and norms in adopting these amendments justified the award of attorney fees. The case was remanded to the District Court for calculation of attorney fees. View "Forward Montana v. State" on Justia Law

The case involves Petitioner Victoria Deschamps who sought a writ of supervisory control over the Twenty-First Judicial District Court, Ravalli County, in Montana due to the court's denial of her request to waive court costs and fees for inability to pay. Deschamps filed a petition for dissolution with a proposed parenting plan in the District Court and also filed a Statement of Inability to Pay Court Costs and Fees, requesting waiver of the filing fee. However, the District Court denied her fee waiver stating that her statement was incomplete.Deschamps submitted another statement which was again denied by the District Court. She then moved the court for reconsideration of its denial, explaining that she had checked boxes on the form indicating that she received certain benefits and thus did not need to include additional information, as stated on the form. This motion was also denied.Deschamps petitioned the Supreme Court of the State of Montana for supervisory control, arguing that the District Court erred in denying her request to waive court costs and fees. The Supreme Court held that the District Court erred as a matter of law by requiring Deschamps to provide information beyond that which the Department of Justice requires. The court concluded that the District Court was incorrect when it deemed Deschamps’s fee waiver application “incomplete” because she completed the form by checking the boxes for specific benefits and signing the declaration.The Supreme Court accepted and granted Deschamps' petition for a Writ of Supervisory Control and remanded the matter to the District Court for the purpose of granting Deschamps’ request for waiver of court costs and fees and allowing her case to proceed without payment of filing fee. View "Deschamps v. 21st Judicial District Court" on Justia Law

In the state of Montana, William James Rupnow Jr., a licensed bail bondsman, was accused of criminal offenses after he tried to apprehend a client, Victorianne Dahl, who had violated her bail conditions. Dahl had consistently been late with payments and had violated other conditions of her release. Rupnow resorted to using pepper spray in his attempt to detain Dahl, leading to the State charging him with felony assault with a weapon and aggravated assault. Rupnow was ultimately acquitted on the aggravated assault charge, but the jury could not reach a verdict on the assault with a weapon charge. In response, Rupnow filed a lawsuit against the Montana State Auditor and Commissioner of Insurance, Mike Winsor, Jennifer Hudson, and XYZ government subdivision, alleging malicious prosecution, abuse of process, and violation of his rights under the Montana Constitution. The defendants requested the case be dismissed based on prosecutorial immunity, a motion which the District Court granted. Rupnow appealed the decision, arguing that as a bail bondsman, he had the authority to arrest Dahl without a warrant.The Supreme Court of the State of Montana reviewed the case and affirmed the lower court's decision to dismiss Rupnow's case. The Court found that Montana's statutory scheme for pre-trial release, or bail, did not provide bail bondsmen with an unfettered right to remit a bail bond client to jail without an outstanding warrant. The Court reasoned that the legislature did not intend to grant bail bondsmen arrest authority that far exceeded that of law enforcement officers. Therefore, Rupnow did not have the authority to arrest Dahl without a warrant, meaning there was probable cause to charge Rupnow with the crimes he was accused of. The Court concluded that Rupnow's claims of malicious prosecution and abuse of process failed as a matter of law. View "Rupnow v. State Auditor" on Justia Law

In this case, the Supreme Court of the State of Montana addressed a dispute over a settlement agreement regarding the sale of a house and the subsequent release of construction-related claims. Daniel Perl and Sandra Perl (collectively, "the Perls"), who are the plaintiffs and appellants, entered into discussions with Christopher Grant and other related parties (collectively, "the Grants"), who are the defendants and appellees. The Perls had purchased a home from the Grants and later became dissatisfied with the construction quality. After negotiations, the parties, through text messages, appeared to reach an agreement wherein the Grants would buy back the property for $2.8 million, and the Perls would release all claims related to the house's construction. However, the Perls later objected to several terms in the formal documents prepared by the Grants' attorney and disputed the existence of an enforceable settlement agreement.The lower court, the Eleventh Judicial District Court, Flathead County, granted the Grants' motion for summary judgment and denied the Perls' cross-motion for partial summary judgment. The lower court held that there was indeed an enforceable settlement agreement.The Supreme Court of the State of Montana affirmed the lower court's decision. The Supreme Court found that the parties' text messages satisfied the statute of frauds and constituted an enforceable settlement agreement. The court pointed out that the text messages contained all the essential elements of a contract, including the parties, the subject matter, a reasonably certain description of the property, the purchase price, and mutual assent. The court also found that the Perls' objections to non-material terms in the formal documents did not invalidate the settlement agreement. Therefore, the Supreme Court affirmed the lower court's decision to grant the Grants' motion for summary judgment and deny the Perls' cross-motion for partial summary judgment. View "Perl v. Grant" on Justia Law