Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the judgment of the district court adjudging Defendant guilty of five offenses, holding that the district court lacked jurisdiction over counts one, four, and five, and therefore, Defendant's convictions on those counts were improper.Defendant was adjudged guilty of misdemeanor assault (count one), felony assault on a peace officer or judicial officer (count two) and three counts of misdemeanor assault with a bodily fluid (counts three, four, and five). Defendant pled guilty to the misdemeanor charges and was found guilty by a jury on the felony charge. The Supreme Court reversed in part, holding (1) the district court erred by retaining jurisdiction over counts one, four and five; and (2) remand was required for the district court to amend the charge imposed with the sentence for count two from $200 to $20 and for count three from $20 to $15. View "State v. Pehringer" on Justia Law

The Supreme Court reversed the judgment of the district court imposing sentencing conditions limiting Defendant's ability to access the internet or possess certain electronic devices, holding that three conditions were overly broad.Defendant pled guilty to one count of sexual intercourse without consent for communicating with the victim through text messaging and Snapchat. The district court sentenced Defendant to a twelve year term of incarceration and imposed the conditions at issue on appeal regarding technology use. The Supreme Court reversed the district court's imposition of the three challenged conditions, holding that, in their current incarceration, the conditions failed to consider the multiple legitimate purposes for internet usage, but that, as modified by the Court, the conditions provided Defendant the change to rehabilitate outside of the prison setting and the community protection from future criminal activity. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to dismiss for lack of a speedy trial, holding that, while the State did not show a valid reason for the over 1,300-day delay in bringing Defendant's case to trial, Defendant was not prejudiced.On May 23, 2017, the State charged Defendant with felony criminal distribution of dangerous drugs and felony criminal possession of dangerous drugs with intent to distribute. On February 10, 2021, Defendant pleaded guilty to criminal distribution of dangerous drugs, and the remaining charge was dismissed. On appeal, Defendant argued that the district court erred in denying his motion to dismiss for lack of a speedy trial. The Supreme Court affirmed, holding that the district court did not err in its balance of the speedy trial factors and in concluding that Defendant was not denied his right to a speedy trial. View "State v. Daly" on Justia Law

The Supreme Court affirmed the judgment of the district court enforcing a settlement agreement between Duane Bender and Rebecca Estates, LLC (collectively, Bender) and Stacey Rosman providing for Bender's purchase of Rosman's property near Shepherd, holding that the district court did not err.Bender filed suit against Rosman alleging trespass and tortious interference with contract and seeking to quiet title. Prior to trial, the parties reached a settlement agreement providing for the purchase of Rosman's property by Bender. The district court issued an order enforcing the settlement agreement for the price of $202,000. Bender appealed. The Supreme Court affirmed, holding that the district court did not err by concluding that Rosman was entitled to specific performance of the settlement agreement. View "Bender v. Rosman" on Justia Law

The Supreme Court affirmed the order of the district court granting a summary judgment motion filed by Petitioners and two insurers, Farmers Insurance Exchange and Truck Insurance Exchange (collectively, Insurers), and denying Respondent's cross-motion for summary judgment, holding that the district court did not err by finding that Insurers had no duty to defend Respondent under the terms of the relevant insurance policies.After a complaint in the underlying lawsuit alleging slander, malicious prosecution, and bodily injury was amended to add Respondent as a defendant Respondent tendered the complaint to Farmers seeking defense and indemnity under a series of homeowners insurance policies and commercial general liability policies. Later, the Insurers filed a declaratory judgment action seeking a judicial determination that they were not obligated to defend and indemnity Respondent. The district court found that Insurers had no duty to defend Respondent under any of the policies. The Supreme Court affirmed, holding that Respondent failed to meet his burden of demonstrating that the claims fell within the scope of coverage of any of the policies at issue. View "Farmers Insurance Exchange v. Minemyer" on Justia Law

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