Justia Montana Supreme Court Opinion Summaries

The case centers on criminal charges against an individual who was accused of sexual intercourse without consent, aggravated kidnapping, and robbery. The complaining witness, Andrade, and the accused had a prior association within a homeless encampment. A series of events led to the accused suspecting Andrade of theft. Months later, an encounter in a tent resulted in Andrade alleging that the accused kept her against her will, threatened, assaulted, and forced her to perform oral sex, and stole her wallet. The accused admitted to receiving oral sex but maintained it was consensual and denied the other charges. Forensic evidence and multiple witness testimonies were presented at trial.The Fourth Judicial District Court in Missoula County presided over a jury trial, during which the prosecution and several witnesses repeatedly referred to Andrade as “the victim.” The defense objected to this terminology, arguing it undermined the presumption of innocence and prejudiced the jury, but the court overruled these objections. Additionally, over defense objections, the court permitted the prosecution to elicit testimony about the accused’s request to his girlfriend to “wipe” his phone, which the prosecution used to suggest consciousness of guilt and criminal propensity.The Supreme Court of the State of Montana reviewed the case on appeal. It held that the pervasive reference to Andrade as “victim” was improper in a case where the existence of a crime and the credibility of the complaining witness were central, thereby undermining the presumption of innocence and the right to a fair trial. Further, the court found that admitting evidence about the phone-wiping request violated evidentiary rules, as it was irrelevant, unduly prejudicial, and constituted inadmissible character evidence. The Supreme Court reversed the convictions and remanded for a new trial. View "State v. Sandberg" on Justia Law

Centron Services, Inc., a debt collector, brought suit against Christopher and Alyson Hollewijn to recover on five separate medical debt accounts assigned to Centron by three different medical providers for services rendered between December 2020 and March 2022. The Hollewijns received billing statements from the providers, with one account in particular involving Bozeman Health and a hospital bill for services rendered on November 4, 2021. After insurance paid a portion of the bill and applied a unilateral “provider discount,” Bozeman Health billed the Hollewijns for the remaining balance. The Hollewijns, through their health plan, disputed the charge in writing 93 days after the first billing statement.The Hollewijns moved for summary judgment in the Montana Eighteenth Judicial District Court, Gallatin County, focusing only on the Bozeman Health account for November 4, 2021. The District Court granted summary judgment in their favor and dismissed the entire suit, finding that Centron could not establish an account stated as a matter of law. The court determined that the Hollewijns’ written objection to the bill was timely, defeating Centron’s claim.On appeal, the Supreme Court of the State of Montana held that the District Court erred in dismissing all five accounts when only one was addressed in the Hollewijns’ motion, as no evidentiary or legal showing was made for the other four. The Supreme Court also found that whether the Hollewijns’ 93-day delay in objecting to the Bozeman Health bill was unreasonable presented a genuine issue of material fact for the jury, not an issue to be resolved by summary judgment. The Supreme Court reversed the District Court’s order and remanded for further proceedings. View "Centron v. Hollewijn" on Justia Law

Police discovered illegal drugs and drug paraphernalia at Felicia Marie Hinkle’s residence, resulting in charges against her for criminal possession of dangerous drugs and drug paraphernalia. Her initial trial in Cascade County was scheduled for August 2023, but procedural errors in juror notification and empanelment led the Eighth Judicial District Court to vacate the trial. The court issued detailed instructions to correct the juror selection process and rescheduled the trial for November 2023. Before the new trial, Hinkle moved to discharge the jury panel, arguing two individuals on the panel had moved out of the county, and requested a hearing supported by her attorney’s affidavit.The Eighth Judicial District Court reviewed Hinkle’s motion and noted that the revised jury selection procedures had been implemented, referencing findings from a hearing held before Judge Kutzman in State v. Burden, where substantial compliance with statutory requirements was found. The court took judicial notice of the Burden proceedings and concluded that the inclusion of nonresident names in the jury pool was a predictable but non-prejudicial outcome of the process, and that the panel for Hinkle’s case was drawn in accordance with statutory requirements. The court denied Hinkle’s motion and did not conduct a hearing.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court erred by denying Hinkle’s motion without a hearing. Applying the substantial compliance standard from State v. Hillious, the Supreme Court held that technical deviations in jury selection statutes that do not affect the randomness or objectivity of the pool, nor a defendant’s right to a fair and impartial jury, do not warrant reversal or a hearing. The court affirmed the District Court’s decision, finding no substantial failure or prejudicial error in the jury selection process. View "State v. Hinkle" on Justia Law

Police stopped the defendant’s vehicle after connecting it to a recent trespass and burglary. The investigation led to charges of felony criminal possession of dangerous drugs and misdemeanor possession of drug paraphernalia. The case proceeded to a jury trial. During jury selection, defense counsel questioned potential jurors about the presumption of innocence and the defendant’s right not to testify. Prospective juror M.W. expressed that, while he would prefer the defendant to rebut the State's evidence, he could acquit if the State’s case was weak and acknowledged the presumption of innocence. Defense counsel moved to strike M.W. for cause, arguing his statements raised concerns about his impartiality.The Twenty-First Judicial District Court, Ravalli County, denied the motion to strike M.W. for cause, finding M.W. had not expressed a fixed bias and could be fair. Haacke used a peremptory challenge to remove M.W. The jury ultimately found Haacke guilty, and the District Court imposed concurrent suspended sentences. Haacke appealed, arguing the court erred by not removing M.W. for cause, relying on Montana law that a juror should be excused if their state of mind raises serious doubts about impartiality.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in denying the challenge for cause. The Court held that, under the totality of the circumstances, M.W.’s statements did not amount to a fixed bias or raise a serious question about his ability to be impartial. The Court found no abuse of discretion by the District Court and affirmed Haacke’s conviction. The main holding is that the District Court did not err in refusing to strike M.W. for cause, as the record did not compel a finding of serious doubt about his impartiality. View "State v. Haacke" on Justia Law

A group of petitioners proposed a constitutional amendment, designated as Ballot Issue 8 (BI-8), which would add a new section to the Montana Constitution. This amendment would explicitly recognize a fundamental right to initiative and referendum and set forth procedural protections to ensure the timely, impartial, and unburdened exercise of those rights. BI-8 also contains limits on governmental interference, including a prohibition on the use of government resources to support or oppose ballot measures. The Attorney General determined that BI-8 was legally insufficient, arguing it violated the Montana Constitution’s separate-vote requirement by effecting multiple, unrelated constitutional changes. The Attorney General also appended a fiscal statement to BI-8, based on speculative litigation costs, despite the fiscal note indicating zero fiscal impact.The Montana Attorney General’s legal-sufficiency determination was challenged in the Supreme Court of the State of Montana under its original jurisdiction. The main arguments centered on whether BI-8 improperly combined multiple unrelated constitutional subjects and whether the Attorney General had statutory authority to append a fiscal statement when the fiscal note showed no fiscal impact.The Supreme Court of the State of Montana held that BI-8 constituted a single constitutional amendment because its provisions were closely related and collectively served to define and protect the right to initiative and referendum. The Court explained that procedural protections and government-resource limitations were integral components of the proposed right, not separate constitutional subjects. The Court further held that the Attorney General lacked authority to append a fiscal statement since the fiscal note did not indicate a fiscal impact. As a result, the Court reversed the Attorney General’s determination, struck the fiscal statement, and ordered the Attorney General to prepare ballot statements for submission to the Secretary of State. View "Kendrick v. Knudsen" on Justia Law

The case concerns a series of events beginning with a brief acquaintance between the defendant and a Helena, Montana resident, who had recently purchased a vehicle. The resident reported the vehicle stolen two days after the purchase. The following day, the resident’s son witnessed the defendant in possession of the vehicle, which led to a chase ending in a crash that caused property damage. The defendant fled on foot and entered a nearby home without permission, where he was eventually found and apprehended by law enforcement.The State charged the defendant with Criminal Mischief, Burglary, and later, Bail Jumping after he failed to appear for court proceedings. The trial was delayed for approximately 18 months, during which a key witness, the homeowner who discovered the defendant in his house, relocated to Washington State and faced significant family and health-related responsibilities. Because of these circumstances, the State sought and obtained permission from the First Judicial District Court, Lewis and Clark County, for the witness to testify at trial via two-way videoconferencing, over the defendant’s objection. The jury found the defendant guilty on all charges.On appeal, the Supreme Court of the State of Montana reviewed whether the district court violated the defendant’s right to confrontation under the Sixth Amendment and the Montana Constitution by allowing live, remote testimony. The Supreme Court held that the district court did not err, explaining that case-specific findings demonstrated that remote testimony furthered an important public policy, considering the witness’s caretaking responsibilities and the travel burden. The court clarified that the “Craig test” for remote testimony does not require a showing of unavailability or a good-faith prosecutorial effort to secure in-person testimony if the witness is otherwise available by video. The defendant’s conviction was affirmed. View "State v. Johnson" on Justia Law

The case concerns a defendant who was caring for his girlfriend’s three-year-old daughter when the child sustained severe injuries, including internal bleeding and a subdural hematoma. The defendant initially claimed the injuries resulted from fleeing gunfire while the child was unrestrained in his car, but investigation revealed he had fired at his own vehicle. The child’s condition was critical, resulting in transfer to a specialized hospital. After these events, the defendant was arrested for violating his supervised release in federal court and was held in federal custody before state charges for aggravated assault were filed.The Thirteenth Judicial District Court, Yellowstone County, oversaw the defendant’s criminal proceedings. There were significant delays between the filing of charges and the eventual trial. Some of these delays stemmed from the defendant’s time in federal custody, repeated substitutions of defense counsel at his request, and motions he filed shortly before his scheduled trial dates. The court held that most of the delay was attributable to the defendant’s own actions, not to the prosecution or systemic issues.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court erred in denying the defendant’s motions to dismiss based on alleged violations of the Interstate Agreement on Detainers (IAD), unnecessary delay in his initial appearance, and his constitutional right to a speedy trial. The Supreme Court held that the IAD did not apply because the defendant was not serving a term of imprisonment when the writ was issued and no detainer was lodged. The Court also found there was no unnecessary delay in his initial appearance, and no speedy trial violation occurred, as the majority of delays were attributable to the defendant. The Supreme Court affirmed the District Court’s judgment. View "State v. Redd" on Justia Law

A Montana limited liability company and its sole member obtained a $450,000 loan secured by real property from a lender affiliated with New York-based entities. The loan documents included a promissory note, guaranty, and deed of trust, all referencing the lender as Axos Bank, though the servicing and assignment of the loan eventually resided with the lender’s subsidiaries. The loan imposed a high annual interest rate, and after the company defaulted, the property was sold. The borrower alleges it paid more than twice the loan amount and asserts that the lender’s arrangement with Axos Bank was a scheme to avoid Montana’s usury laws.The borrowers sued in the Montana Eighteenth Judicial District Court, seeking, among other relief, a declaration that the lender—not Axos Bank—was the true lender and subject to Montana usury law. The lender moved to dismiss and compel arbitration under the arbitration provisions in the loan documents. The District Court considered extrinsic evidence, including the borrower’s declaration, and found that the arbitration provisions conflicted with bold, capitalized jury trial waiver language, resulting in ambiguity. The District Court determined that the borrower had not knowingly, voluntarily, and intelligently waived its constitutional right of access to the courts, denied the motion to compel arbitration, and the lender appealed.The Supreme Court of the State of Montana reviewed the District Court’s denial of the motion to compel arbitration de novo. The Supreme Court affirmed, holding that the loan documents were ambiguous due to conflicting provisions regarding dispute resolution, and that such ambiguity prevented the borrower from giving the required knowing, voluntary, and intelligent consent to arbitrate and waive constitutional rights. As a result, the arbitration provisions were held unenforceable, and the District Court’s denial of the motion to compel arbitration was affirmed. View "Bluebird v. World Business Lenders" on Justia Law

Two water users on Mill Creek in Montana claimed rights to divert and use water based on historical court decrees. Their claims, filed in the 1980s as part of Montana’s general water rights adjudication, asserted periods of use that were broader than those described in a 1964 district court decree, the Petrich Decree, which had granted rights to “surplus” water in Mill Creek from May 1 to approximately July 15. The claimants’ filings instead asserted periods stretching from as early as April 1 to as late as October 1. After the Montana Water Court issued a preliminary decree for Basin 43B, Trout Unlimited, a conservation organization, objected, contending that the claimants overstated their periods of use.The Water Court consolidated the objections and granted Trout Unlimited partial summary judgment, limiting the claimants’ decreed periods of use to May 1 through July 15, as reflected in the Petrich Decree. The claimants then requested the generation of “implied claims” for water use outside this period, arguing they had historically used water beyond those dates. The Water Court generated implied claims with later priority dates for those additional periods but made them junior to other existing rights. Both sides appealed: Trout Unlimited challenged the creation of implied claims, and the claimants challenged Trout Unlimited’s standing and the summary judgment.The Supreme Court of the State of Montana affirmed the Water Court’s ruling that Trout Unlimited had standing to object and upheld the limitation of the decreed periods of use to May 1–July 15. However, it reversed the Water Court’s generation of implied claims, finding that the claimants had not met their burden to show sufficient evidence of pre-1973 historic use outside the decree and that other water users lacked adequate notice. The Court remanded for further proceedings, requiring notice and specific factual findings regarding any implied claims. View "Petrich Family Limited Partnership v. Trout Unlimited" on Justia Law

The defendant, while incarcerated in a tribal detention facility, suffered from serious mental health conditions and was awaiting his regularly scheduled medication. When a detention officer arrived to retrieve cleaning supplies, the defendant threw water on him, leading to a physical altercation. The officer, with assistance from others, subdued the defendant, who was then moved to a more secure cell. Still without his medication, the defendant began harming himself, prompting officers to use a restraint chair. During the process of securing him, the defendant kicked one officer in the face, causing pain but no need for medical treatment. The defendant was subsequently charged and convicted by a jury of felony assault on a peace officer.The Twentieth Judicial District Court, Lake County, presided over the trial and sentencing. At sentencing, the judge commented on the defendant's failure to take responsibility, his decision to go to trial, and the resources expended as a result. The judge imposed a 24-year sentence in the Montana State Prison. The defendant appealed, arguing that his sentence was illegally enhanced due to his exercise of constitutional rights, and also sought review of alleged police misconduct under the plain error doctrine.The Supreme Court of the State of Montana reviewed the case. It held that the District Court erred by basing the sentence, at least in part, on the defendant's exercise of his constitutional rights to remain silent, avoid self-incrimination, and have a jury trial. The Court vacated the sentence and remanded for resentencing before a different judge. The Supreme Court also declined to exercise plain error review regarding the alleged police misconduct, finding no manifest miscarriage of justice or fundamental unfairness warranting reversal of the conviction. The conviction was affirmed, but the sentence was vacated and remanded. View "State v. Matt" on Justia Law