Justia Montana Supreme Court Opinion Summaries

In the early morning of July 18, 2022, Deputy Anthony Jenson of the Lincoln County Sheriff’s Office observed a yellow Volkswagen GTI with Oregon plates at a gas station. The vehicle had been under surveillance since a Border Patrol stop on July 5, 2022. The Volkswagen exhibited suspicious behavior, such as abruptly pulling into another gas station without refueling and making a series of unusual turns. Detective Brandon Holzer, who was also monitoring the vehicle, eventually found it parked in the brush off a dirt road. Upon approaching the vehicle, Holzer detected the smell of burnt methamphetamine and other substances, leading to a search that uncovered drugs and paraphernalia.The Nineteenth Judicial District Court, Lincoln County, denied Herzog’s motion to suppress the evidence, concluding that Detective Holzer had a particularized suspicion to stop the vehicle. Herzog subsequently entered a plea agreement, pleading guilty to Criminal Possession of Dangerous Drugs while preserving her right to appeal the suppression ruling.The Supreme Court of the State of Montana reviewed the case, focusing on whether the District Court relied on clearly erroneous findings of fact in denying the motion to suppress. The court affirmed the lower court’s decision, finding that the District Court’s factual findings were supported by substantial credible evidence. The court held that the totality of the circumstances, including the vehicle’s evasive maneuvers and irregular parking, provided Detective Holzer with sufficient particularized suspicion to conduct a Terry stop. Thus, the evidence obtained from the search was admissible. View "State v. H. Herzog" on Justia Law

Christopher Lapointe was arrested on July 24, 2020, for driving under the influence (DUI) in Montana, with a blood alcohol content of .203. The State found that Lapointe had six prior DUI convictions in California and charged him with Felony DUI (fourth or subsequent offense) under Montana law. Lapointe moved to dismiss the felony charge, arguing that California's DUI statute was not sufficiently similar to Montana's DUI statute, and thus his prior California convictions should not count as prior convictions for felony enhancement purposes.The Eighteenth Judicial District Court of Gallatin County denied Lapointe's motion to dismiss on March 6, 2023, finding that his California convictions could be used for sentence enhancement. Lapointe pled guilty to Felony DUI but reserved the right to appeal the ruling on his motion. On April 24, 2023, the District Court sentenced him to 49 months with the Department of Corrections, with three years suspended.The Supreme Court of the State of Montana reviewed the case and held that California's DUI statute is sufficiently similar to Montana's DUI statutes to support a felony DUI charge. The court noted that both statutes define intoxication similarly and that the place of offense element in California's statute, which includes both public and private property, is sufficiently similar to Montana's requirement that the offense occurs on public ways. The court affirmed the District Court's order denying Lapointe's motion to dismiss the felony enhancement. View "State v. C. Lapointe" on Justia Law

Michael Reilly approached William G. Harris III, a developmentally disabled individual, to purchase his home for $30,000, significantly below its appraised value. Harris, unable to understand the value of money, signed the contract. Reilly attempted to finalize the sale but was informed by the Sheltered Workshop, where Harris was a client, of Harris's disability and was denied further contact with him. Harris passed away in December 2021, and Reilly sued Harris's Estate for specific performance of the contract. The Estate counterclaimed, alleging negligence, violations of the Montana Consumer Protection Act (CPA), and sought punitive damages.The Second Judicial District Court, Butte-Silver Bow County, dismissed Reilly's complaint without imposing sanctions and denied the Estate's request for treble damages and attorney fees. The jury awarded the Estate $28,900 in compensatory damages and $45,000 in punitive damages. Reilly moved to dismiss his complaint just before the trial, which the District Court granted, but the Estate objected, seeking sanctions for the late dismissal. The District Court did not rule on the objection. The jury found Reilly exploited Harris and violated the CPA, awarding damages accordingly. The District Court later denied the Estate's request for treble damages and attorney fees, citing the substantial jury award as sufficient.The Supreme Court of the State of Montana reviewed the case. It held that the District Court abused its discretion by dismissing Reilly's complaint without imposing sanctions, given the late timing and the Estate's incurred costs. However, it affirmed the District Court's denial of treble damages and attorney fees under the CPA, agreeing that the jury's award was substantial. The Supreme Court affirmed the compensatory and punitive damages awarded to the Estate and remanded the case to the District Court to award the Estate its full costs and attorney fees incurred before Reilly's motion to dismiss. View "Harris Estate v. Reilly" on Justia Law

Nicole Lee Hunt was observed by Detective Nicholas Monaco of the Ravalli County Sheriff’s Office driving a vehicle without license plates. Monaco had prior intelligence linking Hunt and her residence, Apartment 1, to drug activity, specifically methamphetamine trafficking. During the traffic stop, Hunt exhibited signs of nervousness, had glassy red eyes, and made inconsistent statements about her activities. Monaco expanded the stop into a drug investigation, conducted a canine sniff, and found a package containing methamphetamine in Hunt’s vehicle.The Twenty-First Judicial District Court, Ravalli County, denied Hunt’s motion to suppress the evidence obtained from the search, finding that Monaco had particularized suspicion to expand the traffic stop into a drug investigation. During the trial, Hunt testified that she knew the package contained drugs but claimed it belonged to her dealer, Trent Parker, and denied any intent to distribute. The State called Katrina Conway as a rebuttal witness, who testified that Hunt had previously sold her methamphetamine. The District Court allowed this testimony, concluding that Hunt’s testimony opened the door to evidence of her prior bad acts. The jury found Hunt guilty of felony criminal possession of dangerous drugs with intent to distribute.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court’s denial of Hunt’s suppression motion, agreeing that there was particularized suspicion to justify the expanded investigation. However, the Supreme Court found that the District Court erred in allowing Conway’s rebuttal testimony, as Hunt’s cross-examination responses did not open the door to such evidence. The Supreme Court reversed Hunt’s conviction and remanded the case for a new trial. View "State v. N. Hunt" on Justia Law

The defendant returned home after a period away and, while intoxicated, became upset upon discovering his brother’s marijuana plants in his basement. After confronting his brother, the defendant visited a neighbor’s house, where he found the neighbor’s daughter and another individual, Bill, using methamphetamine. Concerned that the neighbor, recently released from prison, could get into trouble, the defendant confronted those present. A verbal altercation escalated, resulting in the defendant punching Bill unconscious. Upon regaining consciousness, Bill struck the defendant with a hammer, leading to a physical struggle involving the defendant’s son and friend. The group retreated outside, but Bill followed, allegedly threatening to kill the defendant and his family. The defendant’s son retrieved a gun, which the defendant used to shoot and kill Bill after warning him to stop approaching.The Twentieth Judicial District Court, Sanders County, presided over the trial. The defense did not object to the jury instructions regarding self-defense and the use of force to prevent a forcible felony, and stipulated to the remaining instructions. The jury found the defendant guilty of deliberate homicide with a dangerous weapon. The defendant appealed, arguing that the District Court erred by not providing a specific defense of others instruction and that his counsel was ineffective for not requesting one.The Supreme Court of the State of Montana reviewed the case. It held that the District Court did not abuse its discretion in instructing the jury, as the instructions given adequately covered the law regarding self-defense and defense of others through the “forcible felony” instruction. The Court also found no ineffective assistance of counsel, as there was a plausible justification for counsel’s actions and no reasonable probability that a different instruction would have changed the outcome. The judgment was affirmed. View "State v. C. Rossbach" on Justia Law

Former students of the University of Montana filed a class action lawsuit against the university, alleging mishandling of student loan reimbursement payments. They claimed that the university's contract with Higher One Holdings, Inc. subjected them to excessive bank fees and unlawfully disclosed their personal information without consent. The university had contracted with Higher One from 2010 to 2015 to process student loan reimbursements, which involved issuing debit cards and charging various fees.The District Court of the Fourth Judicial District in Missoula County certified three classes of plaintiffs but was later partially reversed by the Montana Supreme Court, which upheld the certification of two classes and reversed the third. The case proceeded to a jury trial, where the jury found in favor of the university, concluding that it did not breach its fiduciary duty, violate privacy rights, or unjustly enrich itself.The Supreme Court of the State of Montana reviewed the case on appeal. The students raised several issues, including the admissibility of evidence regarding their banking practices, the testimony of the university's expert witness, the university's closing arguments, the admission of a fee comparison chart, and the refusal of a burden-shifting jury instruction. The court found that the District Court did not abuse its discretion in its evidentiary rulings, including allowing the university to present evidence about students' banking practices and admitting the fee comparison chart. The court also held that the expert witness's testimony was permissible and that the university's closing arguments did not prejudice the students' right to a fair trial.Ultimately, the Supreme Court of Montana affirmed the District Court's judgment in favor of the University of Montana, upholding the jury's verdict. View "Knudsen v. U. of M." on Justia Law

Brandon James Caldwell and Jenny Lynn Caldwell were married in 2008 and later moved to Montana. They separated in June 2020, and Jenny filed for dissolution of marriage, proposing a parenting plan for their three minor children. The District Court issued several interim parenting plans but did not finalize one. The couple reached a Property Settlement Agreement in April 2021, agreeing to divide their assets, including two homes. Disputes arose over the appraisal of their marital home in Highwood, Montana, leading to further court proceedings.The District Court of the Eighth Judicial District, Cascade County, held multiple hearings and allowed a second appraisal of the Highwood property, despite Brandon's objections. The court found the initial appraisal undervalued the property and ordered a new appraisal to ensure an equitable division of assets. The final decree, issued in March 2024, included the second appraisal's value but did not incorporate a final parenting plan, which was an oversight.The Montana Supreme Court reviewed the case. It affirmed the District Court's decision to allow a second appraisal and use its value for property division, finding no abuse of discretion. The court emphasized the need for accurate property valuation to achieve equitable distribution. However, the Supreme Court remanded the case for the District Court to issue a final parenting plan based on the existing record, as required by Montana law. The final decree was otherwise affirmed. View "Marriage of: Caldwell" on Justia Law

Planned Parenthood of Montana and Dr. Samuel Dickman challenged three laws passed by the 2021 Montana Legislature regulating abortion care. The laws included a 20-week ban on abortions (HB 136), restrictions on medication abortions and requirements for informed consent (HB 171), and a mandate for providers to offer patients the opportunity to view an ultrasound and listen to a fetal heart tone before an abortion (HB 140).The Thirteenth Judicial District Court granted a preliminary injunction against the enforcement of these laws, which was affirmed by the Montana Supreme Court. Following discovery, the District Court granted summary judgment to the plaintiffs, concluding that the laws violated the Montana Constitution's guarantees of individual privacy, equal protection, and free speech. The court permanently enjoined the enforcement of all three laws.The Montana Supreme Court reviewed the case and affirmed the District Court's decision. The Court held that the 20-week ban on abortions (HB 136) violated the right to privacy because it prohibited pre-viability abortions and was not justified by a compelling state interest. The Court also found that the restrictions on medication abortions and the informed consent requirements (HB 171) infringed on the right to privacy and free speech, as they imposed unnecessary burdens on patients and providers without addressing a bona fide health risk. Lastly, the Court held that the mandate to offer patients the opportunity to view an ultrasound and listen to a fetal heart tone (HB 140) violated the right to privacy by interfering with the patient-provider relationship without a compelling state interest.The Montana Supreme Court affirmed the District Court's judgment, permanently enjoining the enforcement of the challenged laws. View "Planned Parenthood v. State" on Justia Law

K.B. (Mother) appealed the Thirteenth Judicial District Court's order terminating her parental rights to her daughter, P.E.W., arguing that the Montana Department of Public Health and Human Services Child and Family Services Division (Department) failed to engage in active efforts to assist her in reunifying with her Indian child, and that the District Court wrongly approved a non-Native American foster placement for P.E.W., in violation of the Indian Child Welfare Act (ICWA).The District Court had removed K.B.'s children, B.J.B. and P.E.W., from her care due to allegations of physical neglect and abuse. The Department filed a petition for emergency protective services, adjudication as youth in need of care, and temporary legal custody. The court adjudicated P.E.W. as a youth in need of care, granted temporary legal custody to the Department, and determined that ICWA applied. The Department developed a treatment plan for K.B., but she failed to comply consistently. The Department made extensive efforts to assist K.B., including providing transportation, financial assistance, and facilitating visitations. Despite these efforts, K.B. struggled with chemical dependency, unstable housing, and compliance with treatment programs. The District Court extended temporary legal custody multiple times and ultimately terminated K.B.'s parental rights, finding that the Department had made active efforts as required by ICWA and that continued custody by K.B. would likely result in serious emotional or physical damage to P.E.W.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The court held that the Department had made active efforts to reunify K.B. with her child, as required by ICWA, and that the District Court did not abuse its discretion in terminating K.B.'s parental rights. The court also found that good cause existed to deviate from ICWA's placement preferences due to the lack of suitable ICWA-compliant placements and the specialized needs of P.E.W. View "In re P.E.W." on Justia Law

The case involves the termination of a mother's parental rights to her child due to her ongoing struggles with substance abuse, domestic violence, and instability. The Department of Public Health and Human Services petitioned for emergency protective services and temporary legal custody of the child, who was already living with the paternal grandmother. Despite the mother’s participation in various treatment programs, she failed to maintain sobriety and stability, leading to the Department's petition to terminate her parental rights.The Thirteenth Judicial District Court, Yellowstone County, held a contested termination hearing and subsequently issued an order terminating the mother's parental rights while denying the petition to terminate the father's rights. The mother appealed, arguing that the termination of her rights was not in the child's best interests, especially since the father's rights were not terminated.The Supreme Court of the State of Montana reviewed the case, focusing on whether the District Court abused its discretion in terminating the mother's parental rights while continuing reunification efforts with the father. The court found that the District Court made sufficient findings and conclusions to support its decision under the relevant statute, which allows for the termination of parental rights if the parent has not complied with or successfully completed a court-ordered treatment plan and if the parent's condition is unlikely to change within a reasonable time.The Supreme Court affirmed the District Court's decision, concluding that the termination of the mother's parental rights was supported by clear and convincing evidence and was in the child's best interests, regardless of the father's situation. View "In re B.J.B." on Justia Law