Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying a writ of prohibition of administrative proceedings initiated by the Montana Commissioner of Securities and Insurance, holding that the district court did not err in denying the writ of prohibition.The Commissioner issued a notice of proposed agency action and opportunity for hearing, alleging that Victory Insurance Company violated various provisions of the Insurance Code, including the requirements to provide the Commissioner access to certain managing general act (MGA) records "in a form usable to the commissioner." Victory responded by filing for a writ of prohibition seeking to halt the proceedings. The district court denied the writ. The Supreme Court affirmed, holding (1) the Commissioner's proceedings were within the agency's jurisdiction; (2) Victory had a legal remedy by way of appeal of the Commissioner's decision; and (3) Victory's federal litigation addressing a different legal issue did not have preclusive effect. View "Victory Insurance Co. v. Downing" on Justia Law

The Supreme Court reversed the order of the district court granting a new trial and vacating the underlying judgment on a $168,500 jury verdict in favor of Plaintiff in an admitted-liability automobile accident case, holding that the district court abused its discretion when it concluded that Plaintiff did not receive a fair trial under Mont. Code Ann. 25-11-102(1).Plaintiff sued Defendant seeking damages for the injuries she received when Defendant rear-ended her. The jury rendered a verdict that Plaintiff was not contributorily negligent, she was injured in the collision, and the general damages sustained totaled $168,500. Thereafter, the district court granted Plaintiff's motion for a mistrial, ordered a new trial, and vacated the judgment, concluding that two statements by Plaintiff's counsel constituted an irregularity preventing a fair trial under Mont. Code Ann. 25-11-102(1). The Supreme Court reversed, holding that the district court misapplied Mont. R. Evid. 411 and abused its discretion when it ordered a new trial because the disputed statements were not sufficiently prejudicial to warrant a new trial. View "Voegel v. Salsbery" on Justia Law

The Supreme Court reversed Defendant's convictions and sentence for negligent vehicular assault, resisting arrest, and disorderly conduct, holding that the district court committed reversible error by responding to the jury's questions about the definition and timing of "arrest" without first consulting Defendant and counsel on record.On appeal, Defendant argued that his right to be present was violated during a point at trial "where the jury made a substantive inquiry about the law pertaining to the charge of resisting arrest" under the facts of this case. The Supreme Court agreed and reversed as to Defendant's conviction for resisting arrest, holding that when the district court responded to questions from the deliberating jury outside of Defendant's presence, it constituted reversible error because it was during a critical stage of the proceedings. View "State v. Zitnik" on Justia Law

The Supreme Court affirmed Defendant's conviction for threats and other improper influence in official and political matters but remanded for the district court to strike its imposition of pretrial supervision costs, holding that the court erred in imposing pretrial supervision costs without considering Defendant's ability to pay. Specifically, the Supreme Court held (1) considering the probative value of the evidence and the limited risk of unfair prejudice, the district court did not abuse its discretion Under Iowa R. Evid. 403 by admitting evidence of Defendant's prior sex offense; and (2) the district court erred by imposing pretrial supervision costs without considering whether Defendant had the ability to pay the costs. View "State v. Hardin" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Defendant's request to provide a jury instruction on th lesser-included offense of mitigated deliberate homicide and the ensuing sentencing order and judgment for felony deceptive practices, holding that there was insufficient evidence to support Defendant's conviction of deceptive practices.On appeal, Defendant argued that the district court erroneously refused his request to provide a jury instruction on the lesser-included offense of mitigated deliberate homicide and that insufficient evidence supported the jury's guilty verdict as to his felony deceptive practices conviction. The Supreme Court affirmed, holding (1) Defendant's first claim of error was unavailing; and (2) the evidence was legally insufficient to convict Defendant of felony deceptive practices, and therefore, acquittal on this count was proper. View "State v. Craft" on Justia Law

The Supreme Court affirmed the decision of the district court denying Hamilton Southside Historic Preservation Association's (HSHPA) petition for a writ of certiorari challenging four decisions of the Hamilton Zoning Board of Adjustment (ZBA), holding that the district court did not err.Specifically, the Supreme Court held that the district court did not err in determining that the ZBA did not abuse its discretion when it (1) issued a conditional use permit to the Roman Catholic Bishop of Helena to construct and use a new church structure after demolition of the St. Francis Catholic Church; (2) approved a rear-yard setback variance; (3) approved a steeple height variance; and (4) upheld the zoning administrator's approval of a joint use parking agreement for the new structure. View "Hamilton Historic Preservation Ass'n v. Zoning Bd. of Adjustment" on Justia Law

The Supreme Court reversed the judgment of the municipal court sentencing Appellant for operating a motor vehicle with a blood alcohol content of .08 percent or greater (DUI per se), first offense, holding that the municipal court lawfully ordered Appellant to satisfy a $600 fine using his COVID-19 stimulus payment but erred in concluding that it did not have discretion to suspend the fine or to enforce the fine through an alternative method of payment.Appellant pleaded guilty to an amended misdemeanor charge of first-offense DUI per se and agreed to the minimum $600 fine with the understanding that he would ask the court to consider his ability to pay the fine. The municipal court sentenced Appellant to ten days of incarceration and a $600 fine. Appellant appealed, arguing that the municipal court erred in imposing the fine despite his inability to pay. The district court affirmed. The Supreme Court reversed, holding that the municipal court abused its discretion by not recognizing that it possessed the discretion to order Appellant to satisfy the mandatory fine via alternative methods to a dollar-for-dollar repayment plan ordered by the municipal court. View "City of Whitefish v. Curran" on Justia Law

The Supreme Court affirmed the decision and orders entered by the district court in this property dispute, holding that substantial credible evidence supported the district court's finding that Cremer Rodeo Land and Livestock Company obtained a prescriptive easement over two roads across Linda McMullen's property.In 2016, Cremer Rodeo filed this lawsuit seeking a prescriptive easement over the Lien Road and the Medley Roads. After denying McMullen's motion for summary judgment the district court held a bench trial and concluded that Cremer Rodeo had a prescriptive easement over the Lien and Medley Roads. The Supreme Court affirmed, holding that the district court (1) did not err by denying McMullen's motion for summary judgment; (2) did not abuse its discretion by granting Cremer Rodeo leave to amend its complaint; (3) did not err when it concluded that Cremer Rodeo's amended complaint related back to its original complaint; and (4) properly found that Cremer Rodeo obtained a prescriptive easement over the Lien and Medley Roads. View "Cremer Rodeo Land v. McMullen" on Justia Law

The Supreme Court affirmed the judgment and orders approving a settlement between Robert Allum and Montana State Fund and dismissing Allum's claims for benefits, holding that Allum resolved all of his dispute benefits, and therefore, the Workers' Compensation Court (WCC) did not have jurisdiction over Allum's remaining stand-alone constitutional challenges.The State Fund accepted liability for the knee injury Allum received at work. Later, Allum notified State Fund that he also asserted a back condition resultant from his knee injury. Allum filed a petition seeking a hearing on his injury claims and also sought a hearing on his claims challenging the constitutionality of the Montana Workers' Compensation Act and the WCC. Allum and State Fund settled the injury claims prior to trial. The WCC approved the settlement agreement and then concluded that it lacked jurisdiction to address Allum's constitutional challenges because Allum had resolved all of his benefit disputes. The Supreme Court affirmed, holding that the WCC's conclusions of law were correct. View "Allum v. Mont. State Fund" on Justia Law

The Supreme Court affirmed the order of the district court denying Appellant's motion to dismiss a complaint citing him with violating 49 C.F.R. 393.11, incorporated by Mont. Code Ann. 61-10-154, which required a red light to be affixed to protruding loads, holding that the district court did not err by denying Appellant's motion to dismiss for unlawful delegation of legislative authority.After Appellant was convicted in justice court he appealed de novo to the district court, arguing that section 61-10-154, which authorizes the Montana Department of Transportation to adopt rules and regulations, and Mont. Code Ann. 61-9-512, which criminalizes violations of regulations adopted pursuant to section 61-10-154, constituted an unconstitutional delegation of legislative power to an administrative body. The district court denied the motion. The Supreme Court affirmed, holding that the legislature did not delegate the lawmaking function, as argued by Appellant. View "State v. Akhmedli" on Justia Law