Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court sentencing Defendant to seventy years in Montana State Prison for deliberate homicide, a felony, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) Defendant's claim that his trial attorney provided ineffective assistance when he advised Defendant and the court that mitigated deliberate homicide was not a lesser-included offense of deliberate homicide was more appropriate for postconviction relief; and (2) the district court did not err when it concluded that the State's offer of proof provided sufficient evidence to accept Defendant's Alford plea. View "State v. Bristow" on Justia Law

The Supreme Court affirmed the decision of the Attorney General rejecting a constitutional initiative proposed for the 2024 ballot (B12), of which Petitioner was a proponent, holding that the Attorney General correctly determined that the new facial content proposed by B12 violated the separate-vote requirement in Mont. Const. art. XIV, 11.The Attorney General concluded that B12, which would amend Mont. Const. art. VIII, 3, was legally insufficient due to a violation of the separate-vote requirement and ambiguity in the text of the initiative. The Supreme Court affirmed the decision and enjoined the Secretary of State from approving petitions for circulation to the electorate for signatures or otherwise submitting the measure for approval by voters, holding that the separate-vote issue was dispositive and that the Attorney General properly concluded that B12 violated the constitutional separate-vote requirement. View "Monforton v. Knudsen" on Justia Law

The Supreme Court affirmed the judgment of the district court sentencing Defendant based on the counts of strangulation of a partner, assault of a partner, and child endangerment, holding that the district court did not err or abuse its discretion.Specifically, the Supreme Court held that the district court (1) did not abuse its discretion when it permitted Dr. Tiffany Kuehl to testify about the legal and medical definitions of strangulation; (2) did not abuse its discretion by admitting Defendant's statements made in a separate legal proceeding; (3) did not err in assuring that no prejudicial juror misconduct occurred; and (4) erred in allowing a brief statement of the make-up of the population of the high-risk, violent crimes pod of the jail, but the error was harmless. View "State v. Sneed" on Justia Law

The Supreme Court affirmed the order of the district court denying the motion filed by H.M., a youth held in detention, seeking to dismiss a formal petition brought by the State to adjudicate H.M. as a delinquent youth, alleging one count of misdemeanor resisting arrest and three counts of assault on a police officer, holding that the district court did not err in denying the motion.As grounds to dismiss the petition H.M. argued that the State filed it one day beyond the seven-day time limit for such petitions against detained youths in Mont. Code Ann. 41-5-1401(2). The youth court declined to dismiss the petition, concluding that the State had good cause to file the petition and to detain H.M., outside the seven-day deadline. The Supreme Court affirmed, holding (1) the good cause exception in section 41-5-1401(2) applies to the youth court's decision not to dismiss an untimely petition charging a youth held in detention; and (2) the youth court properly denied H.M.'s motion to dismiss. View "In re H.M." on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated kidnapping, sexual intercourse without consent, and partner or family member assault, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Supreme Court held (1) Mont. Code Ann. 45-5-303(2) is not facially unconstitutional because it permits a judge, rather than a jury, to apply factors that reduce the maximum penalty; (2) Defendant's level three offender designation was objectionable, not illegal, and Defendant did not properly reserve his objection to the designation during sentencing; and (3) Defendant's counsel was not ineffective for failing to argue that the maximum sentence for kidnapping was ten years based on mitigating factors and failing to object to Defendant's level-three sex offender designation. View "State v. Pine" on Justia Law

The Supreme Court affirmed the judgment of the district court finding that Frank Piocos was not eligible to be a candidate for Roosevelt County Attorney, holding that the district court had substantial, credible evidence to support a finding that Piocos was not a resident of Roosevelt County for voting purposes on November 8, 2022.In January 2022, Piocos filed as a candidate for County Attorney. Piocos elected on November 8, 2022. On January 20, 2023, Contestant brought this action challenging Piocos's eligibility based on residency grounds. The district court determined that the election was void because Piocos was not a resident of Roosevelt County for thirty days prior to the election. The Supreme Court affirmed, holding (1) for purposes of voting under Mont. Code Ann. 13-1-112, the Legislature's intent was for a person to have a place of abode in the county to which the person intends to return even when absent; and (2) the district court did not err when it found that Piocos did not reside in Roosevelt County without making a factual finding of where he did reside. View "Downs v. Piocos" on Justia Law

The Supreme Court reversed the judgment of the district court following a jury verdict in favor of Glacier Eye Center, P.C. (GEC) and Kalispell Regional Medical Center, Inc. (KRMC) in this medical malpractice action, holding that the district court abused its discretion by refusing to give certain jury instructions, requiring that this matter be remanded for a new trial.Specifically, the Supreme Court held (1) the district court abused its discretion by refusing to give the jury a proportionate duty instruction and a loss of chance instruction under the facts of this case, and the court's failure to give these instructions resulted in the jury not being fully and fairly instructed in the applicable law, prejudicing Defendant and requiring a new trial; and (2) the district court erred by failing to poll the jury in the manner required by statute. View "Camen v. Glacier Eye Clinic, P.C." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgments of the district court adjudicating a parental interest and accompanying parenting plan regarding Father's minor child in favor of his non-parent ex-wife (Surrogate), holding that the district court erroneously made a child custody parenting plan determination involving a non-parent without the predicate parental interest implied as a condition precedent to imposition of a best interests-based parenting plan.Specifically, the Supreme Court held that the district court (1) correctly concluded that the preclusive terms of a gestational carrier agreement did not preclude Surrogate from later acquiring or establishing a parental interest and right to the extent independently authorized under Montana law; (2) did not err in finding and concluding that Father voluntarily signed the premarital agreement and that it ws thus a validly formed and enforceable contract; (3) did not erroneously reject Father’s assertion that the parent-child relationship provision was unenforceable as equitably unconscionable; and (4) erroneously adjudicated a non parent "parental interest" in favor of Surrogate without the required predicated finding of fact specified by Mont. Code Ann. 40-4-228(2)(a). View "Sayler v. Yan Sun" on Justia Law

The Supreme Court affirmed the judgment of the district court granting a Partnership's motion for summary judgment and concluding that Tract 3, one of three individual tracts that were carved out from Owners' land for separate ownership by each of the Partnership's owners, was burdened by a thirty-foot easement and could not benefit from it, holding that there was no error.In 1990, Owners conveyed the property at issue to the Partnership and conveyed Tract 3 to R.A. Roehder. The warranty deed conveying the property provided that the property was given together with thirty-foot-wide easements for ingress and egress. Roehder later sold his interest in the Partnership. After Roehder's death, Tract 3 was acquired by Zinvest, LLC by tax deed, and Zinvest conveyed the property to Lee Lou. The Partnership later filed a complaint to quiet title with a declaratory judgment that Lee Lou owned no interest in the easement and only the partnership had an interest in the easement. The court granted summary judgment in favor of the Partnership. The Supreme Court affirmed, holding that the district court did not err in determining that Tract 3 did not benefit from the thirty-foot easement and that tracts 1 and 2 did benefit from the easement. View "Duke Trust v. Lee Lou, LLC" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of the City of Whitefish and affirming the Whitefish City Council's decisions to deny a conditional use permit (CUP) and grant Resolution 21-43, which denied the permit, holding that there was no error in the proceedings below.Whitefish 57 Commercial, LLC and Rimrock Companies, LLC (collectively, Appellants) applied for a CUP to develop a hotel on a lot of their subdivision. After a public hearing on the development project the Council adopted Resolution 21-43 that denied the permit. Appellants appealed, claiming that the Council abused its discretion in denying their CUP. The district court granted summary judgment against Appellants. View "Whitefish 57 Commercial, LLC v. City of Whitefish" on Justia Law