Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the determination of the district court granting Hill County, Montana, and Blaine County, Montana summary judgment on the standalone claims brought by the Estate of A.J. Longsoldier, Jr. for negligence and denying its cross-motion for partial summary judgment on liability, holding that remand was required for further proceedings.Longsoldier died in 2009 while in Hill County's custody. In the first appeal, the Supreme Court affirmed the determination that neither Blaine County, where Longsoldier was arrested, nor Hill County discriminated against Longsoldier on the basis of race or disability. In the second appeal, the Supreme Court reversed the ruling that Hill County could be held vicariously liable for the negligence of the hospital where Longsoldier was treated during his detention. In this third appeal, the Supreme Court reversed in part and remanded the case, holding that the district court (1) erred in determining that the Estate's negligence claim against Hill County was barred by principles of issue preclusion; (2) erred in ruling that the Estate may not pursue a negligence claim against Blaine County; and (3) did not err in denying the Estate's motion for partial summary judgment on liability. View "Stricker v. Blaine County" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgments of the district court enforcing the parties' mediated memorandum of understanding (MOU) regarding a subdivision dispute and then implementing it in the form of a more formal final settlement agreement proposed by Developers for approval by the Town of Fort Peck, Montana, holding that the district court erroneously granted Developers judgment as a matter of law.The district court ultimately concluded that the mediated MOU was an independently valid and enforceable contract in accordance with its written terms and as approved by the Town Council at its closed meeting, thus granting Developers' motion to enforce and implement the mediated MOU. The Supreme Court reversed in part, holding that the district court erred in granting Developers judgment as a matter of law that the Town Council took action to approve the parties' mediated MOU at its closed meeting and that a genuine issue of material fact remained as to whether a majority a quorum of the Town Council satisfied the agreed condition precedent to contract formation and enforceability of the MOU. View "Hanson v. Town of Fort Peck" on Justia Law

The Supreme Court reversed the judgment and order transferring jurisdiction of this matter involving H.R. from youth court to district court, imposing a Department of Corrections (DOC) commitment, auditing two years of supervision to the disposition, and requiring H.R. to register as a sex offender, holding that there was no error.The youth court revoked H.R.'s probation and committed him to the DOC for placement. Upon turning eighteen, H.R. was released, and the State sought to transfer jurisdiction from youth court to district court and to order the supervisory responsibility to transfer from juvenile probation services to adult probation services. The youth court transferred jurisdiction to the district court and supervisory responsibility to adult probation. The Supreme Court reversed, holding that the youth court exceeded the bounds of its authority under Mont. Code Ann. 41-5-208 because it imposed a new disposition on H.R. in addition to the transfer of jurisdiction and supervision agency because such a new disposition was not available under section 41-5-208. View "State v. H.R." on Justia Law

The Supreme Court reversed judgments issued by the district court in these consolidated appeals concerning the interpretation of the Montana Residential Mobile Home Lot Rental Act as it related to mobile home owners who had been evicted from their lots, holding that the Act does not allow for a no-cause termination of a periodic tenancy.David and Doreen Lockhart appealed the order issued by the district court upholding the order for possession issued by the justice court and ordering them to vacate and remove all personal property from a mobile home lot owned by Westview Mobile Home Park, LLC. Hydi Cunningham appealed the district court orders following the justice court's judgment and order for possession of property and writ of issuance ordering Cunningham to vacate the mobile home lot she had been renting from Greener Montana Property Management, LLC. The Supreme Court reversed in both causes, holding (1) the Act does not allow a lot-only landlord to terminate a homeowner tenant's month-to-month lease without cause; and (2) therefore, the no-cause terminations of both leases in this case were illegal and invalid. View "Greener Montana Property Management LLC v. Cunningham" on Justia Law

The Supreme Court affirmed the judgment of the district court terminating Mother's parental rights to Daughter, holding that the district court did not err or abuse its discretion.Following a hearing, the district court held that it was in Daughter's best interest to terminate Mother's parental rights. The Supreme Court affirmed, holding (1) Mother failed to show that the Department's failure to insist on a written response prejudiced Mother's substantial rights; (2) a district court's failure to comply with statutory requirements for adjudication as youth in need of care has no effect on the court's jurisdiction to hear and determine a petition of parental rights, and the district court in this case did not commit legal error by proceeding on the termination petition; (3) Mother's claims of ineffective assistance of counsel failed; and (4) the district court did not abuse its discretion when it determined that termination, as opposed to guardianship, was appropriate. View "In re Z.N-M." on Justia Law

The Supreme Court affirmed the judgment of the district court sentencing Defendant, holding that the district court did not err in determining that there was probable cause Defendant committed a crime that allowed the State to withdraw from the plea agreement and relieved the State's obligation to make a particular sentencing recommendation.Defendant pled guilty to assault with a weapon, criminal endangerment, and theft pursuant to a plea agreement. The State recommended a twenty-year sentence with no time suspended and treatment of Defendant as a persistent felony offender (PFO). Prior to sentencing, the State informed Defendant that it would withdraw from its plea agreement recommendation based on alleged crimes Defendant committed while in custody. The district court ultimately permitted the State to diverge from its sentencing recommendation in the plea agreement. The Supreme Court affirmed, holding that the district court (1) correctly determined that Defendant waived his right to challenge the timeliness of the PFO notice; and (2) did not err in determining that Defendant had breached the plea agreement and that the State was entitled to withdraw from the guilty plea and recommend a harsher sentence. View "State v. Claus" on Justia Law

The Supreme Court affirmed the judgment of the district court issuing an order awarding the Estate of Thomas Ronan the insurance proceeds of a house that was destroyed by fire, holding that the district court did not err.When Janet Le Ora Ronan died, she left a holographic will specifically devising her interest in a farm to Thomas "with him having preference to keeping the house [and] farmstead...." After the district court adopted a stipulated settlement agreement (SSA) setting forth the terms as to how to distribute the estate the house was destroyed in a fire. Thomas later died. Appellants had previously insured the house with Janet's estate as the insurance beneficiary, and the insurance company issued $169,089 for the house and $15,250 for personal property destroyed in the fire. The district court relied on the doctrine of equitable conversion to award Thomas's estate the insurance money. The Supreme Court affirmed, holding that the district court (1) did not err in distributing the insurance proceeds according to Montana residuary law or the SSA; and (2) did not err by relying on the doctrine of equitable conversion to distribute the insurance proceeds in furtherance of Janet's intent in specifically devising the house to Thomas. View "In re Estate of Ronan" on Justia Law

The Supreme Court reversed Defendant's felony sentence imposed in connection with his conviction for felony driving under the influence (DUI) per se, holding that the presentence investigation report (PSI) in this case did not constitute competent proof if its accuracy is challenged.The district court found Defendant guilty of DUI per se and filed a PSI. The district court relied on the PSI and ordered a felony sentence of five years' incarceration with three years suspended. The Supreme Court reversed and remanded the case for resentencing, holding that Defendant's sentence was unlawful because the district court erred by taking the disputed PSI, without further of Defendant's prior convictions, as competent proof of Defendant's prior convictions. View "State v. Letherman" on Justia Law

The Supreme Court affirmed the order of the district court denying Defendant's motion to suppress evidence obtained during a probation home visit, holding that the district court did not err in denying the suppression motion.Defendant was convicted of bail jumping and received a deferred sentence of four years. After a probation home visit resulted in the discovery of a "significant amount of methamphetamine" by a probation officer the State petitioned to revoke Defendant's deferred sentence. Defendant filed a motion to suppress, arguing that the discovery of the drugs found in her home was the result of an unlawful search. The district court denied the motion, concluding that the officer did not violate the reasonable protocols for a probation home visit. The Supreme Court affirmed, holding that what began as a home visit turned into a search pursuant to the officer's plain view observation of drug paraphernalia, which provided probable cause for the search. View "State v. Thompson" on Justia Law

The Supreme Court accepted supervisory control in the underlying action, holding that Montana had specific personal jurisdiction over Melissa Groo regarding Triple D Game Farm, Inc.'s intentional tort claims when the tortious activity allegedly accrued in Montana despite Groo interacting only with the forum via social media.At issue was Groo's purposeful and substantial use of social media to affect Triple D's business operations. Triple D brought this lawsuit alleging tortious interference with contractual relations and tortious interference with prospective economic advantage claims. Groo moved to dismiss the claims for lack of personal jurisdiction, arguing that her statements did not create the necessary minimum contacts with Montana as a forum. The district court denied the motion to dismiss, condoling that Groo had the requisite minimum contacts with the state and that the court's exercise of personal jurisdiction over her did not violate due process principles. The Supreme Court affirmed, holding that the district court was not proceeding under a mistake of law, and the court had personal jurisdiction to resolve this dispute. View "Groo v. Eleventh Judicial District Court" on Justia Law