Justia Montana Supreme Court Opinion Summaries

Defendant was convicted of deliberate homicide stemming from the shooting death of his former roommate. On appeal, Defendant contended that the district court erred by instructing the jury it was prohibited from considering Defendant's intoxication when rendering its verdict in accordance with Mont. Code Ann. 45-2-203 because the statute violated a criminal defendant's due process right to present a defense. The Supreme Court affirmed, holding that the instructions given by the court fully and fairly instructed the jury on the applicable law and did not prejudice Defendant's right to present a defense, and therefore, the district court did not abuse its discretion by giving the instruction to the jury. View "State v. Myran" on Justia Law

The State charged Defendant with DUI and two drug counts. The DUI count was charged as a felony because the State maintained that Defendant had three prior DUI convictions. Defendant had been convicted of DUI twice in Idaho and once in Montana. Defendant filed a motion to dismiss the felony DUI charge arguing that his two Idaho DUI convictions should not be counted because the Idaho DUI statute was not similar to Montana's DUI statute. The district court denied Defendant's motion to dismiss, determining that while the statutes were not precisely identical, they were similar because they had characteristics in common and were alike in substance. Thereafter, pursuant to a plea agreement, Defendant pled guilty to felony DUI, and the State dismissed the drug charges. The Supreme Court affirmed Defendant's conviction, holding that the district court did not err in determining that Idaho's DUI statute was similar enough to Montana's DUI statute to allow the enhancement of a Montana DUI to a felony. View "State v. Young" on Justia Law

After a trial, Defendant was convicted for driving under the influence. The Supreme Court affirmed the conviction, holding (1) the district court erroneously allowed the results of a horizontal gaze nystagmus and preliminary breath test to be admitted at trial without expert testimony to establish the reliability of the tests, but the cumulative evidence of Defendant's intoxication presented at trial overcame any reasonable probability that the indirect admission of the test results contributed to Defendant's conviction; and (2) the district court properly exercised its discretion in excluding cross-examination regarding Defendant's blood alcohol content at the time that Defendant had been driving. View "State v. Chavez-Villa" on Justia Law

Plaintiff filed a complaint against Defendants asserting that a tree on Defendants' property was a nuisance and trespass because it blocked Plaintiff's view. The district court dismissed the complaint for failing to state a claim upon which relief could be granted. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the district court properly granted Defendants' motion to dismiss Plaintiff's nuisance claim, as the naturally growing tree that obstructed Plaintiff's view did not constitute, as a matter of law, conduct that was "intentional, negligent, reckless, or ultrahazardous," "an inherently injurious act," or a condition which "obviously exposes another to probable injury;" but (2) the complaint adequately stated a legal claim for trespass because it alleged that the roots of Defendants' tree entered, remained on, and damaged Plaintiff's property. View "Martin v. Artis " on Justia Law

After Donald and Lora Wyrick filed for dissolution of their marriage, the district court struggled to resolve a convoluted child support arrangement that festered for nearly twenty years. Donald filed a motion for modification of child support in April 2009. Donald apparently signed an affidavit for his lawyer in October 2008 in support of the motion to modify child support, but Donald's lawyer failed to file the motion until April 2009. In December 2011, the district court determined it could not modify the amount of Donald's payments back to 2008 because Donald had failed to file his motion for modification until April 2009. The court ultimately ordered that Donald pay arrearages and concluded that he continued to owe child support. However, in an earlier order, the court declared that Donald owed no future obligation of child support to Lora and that Donald had overpaid child support. The Supreme Court (1) held that the district court lacked authority to extend the modification date to any date before April 2009, but (2) remanded the case because the district court offered no new finding of fact in its latter finding to support the change from its earlier finding. View "Wyrick v. Wyrick" on Justia Law

This was Defendant's second appeal to the Supreme Court. In the prior appeal, the Court affirmed Defendant's conviction of two counts of felony sexual assault and remanded the case for resentencing. The district court subsequently granted Defendant's petition for postconviction relief on the grounds of ineffective assistance of counsel and prosecutorial misconduct. In this interlocutory appeal, Defendant challenged the district court's order denying his motion to dismiss the criminal charges for which the State intended to re-prosecute him on double jeopardy grounds. The Supreme Court affirmed, holding that Defendant's constitutional right to be free from double jeopardy did not prohibit the State from re-prosecuting him after his conviction was overturned by the postconviction court's determination of prosecutorial misconduct and ineffective assistance of counsel. View "State v. Duncan" on Justia Law

A jury convicted Defendant of aggravated burglary and sexual intercourse without consent. Defendant argued on appeal that his convictions should be reversed because his standby counsel had a conflict of interest, the district court erred by modifying the jury instructions regarding aggravated burglary during jury deliberations, and his counsel was ineffective for failing to obtain an independent medical expert. The State conceded reversible error on the instruction issue and requested that Defendant's conviction for aggravated burglary be vacated on that basis. The Supreme Court reversed Defendant's conviction for aggravated burglary and affirmed Defendant's conviction for sexual intercourse without consent, holding (1) Defendant's standby counsel did not have an active conflict of interest that required reversal of Defendant's sexual intercourse without consent conviction; and (2) because the record did not fully explain why an independent medical examination or expert was not ultimately obtained by Defendant's counsel, Defendant's claim that his counsel rendered ineffective assistance by failing to obtain a medical expert could not be reviewed on appeal. View "Longjaw v. State" on Justia Law

After a five-day trial, a jury decided that Appellee Bull River Country Store Properties, LLC was not negligent in connection with Appellants' claim that it sold water-contaminated diesel fuel. Appellants appealed the district court's order denying their motion for a new trial. The Supreme Court affirmed, holding (1) under the circumstances, Plaintiff could not demonstrate prejudice from Bull River's reliance on the settled-party defense authorized by 27-1-703 MCA, and therefore, the Court did not need to address the constitutionality of the statute; (2) Appellant waived his right to argue on appeal that the district court erred when it allowed Bull River to question Appellant about his unrelated insurance claims; (3) the district court did not abuse its discretion when it denied Appellant's motion for a new trial based on Bull River's insurance-related arguments; and (4) Appellant was not entitled to a new trial on the ground of juror misconduct. View "Horn v. Bull River Country Store Props., LLC" on Justia Law

Plaintiffs were employees of Defendant Kalispell Regional Medical Center (KRMC). Defendant Northwest Healthcare Corporation (NWHC) was the parent corporation of the remaining defendant entities. This case arose out of a dispute over the discontinuation of a sick leave buy-back program. Defendants appealed the order of the district court granting Plaintiffs' motion for class certification. The Supreme Court affirmed, holding (1) the district court properly determined that the named Plaintiffs had standing to bring claims against defendants they did not directly work for because the juridically linked Defendants were operating under a common scheme; and (2) the district court did not abuse its discretion in certifying the class under Mont. R. Civ. P. 23(a) and (b). View "Chipman v. Nw. Healthcare Corp." on Justia Law

Plaintiff owned and operated a ranch with an 18,000 square-foot lodge. Defendant was a custom manufacturer of high-end wood flooring from whom Plaintiff brought wood flooring while building the lodge. After it was installed, the wood flooring began buckling and had to be replaced. Plaintiff sued Defendant for negligent misrepresentation, breach of an implied warranty of suitability for a particular purpose, and violation of the Montana Unfair Trade Practices and Consumer Protection Act (MCPA). The jury returned a verdict in Defendant's favor on all of Plaintiff's claims. The district court then granted Defendant attorney fees as the prevailing party under the MCPA. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion when it found good cause to amend the scheduling order to allow Defendant's late disclosure of an expert witness; and (2) did not err when it awarded Defendant attorney fees under the MCPA. View "B Bar J Ranch, LLC v. Carlisle Wide Plank Floors, Inc." on Justia Law