Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the district court granting summary judgment to the Montana Department of Transportation (MDT) and ruling that Kageco Orchards, LLC's requests for declaratory judgment relief and mandamus were correctly denied, holding that the district court did not err.Kageco filed suit against MDT alleging that the placement of certain mailboxes within MDT's right of way created a potential hazard and interfered with Kageco's lawful use of an approach from a highway to its property. Kageco sought a declaratory judgment and, alternatively, a writ of mandamus seeking to have the mailboxes removed and relocated. The district court granted judgment to MDT. The Supreme Court affirmed, holding that the district court (1) did not err in determining that Kageco did not have standing to pursue its claim for declaratory relief because there was no justiciable case or controversy; and (2) did not err in denying Kageco's request for a writ of mandamus because MDT's acts were discretionary as opposed to ministerial. View "Kageco v. Mont. Dep't of Transportation" on Justia Law

The Supreme Court affirmed the order of the district court granting petitions made by Lorri Williams to formally probate the estate of Gerry Williams, her ex-husband, and to remove Vicki Hofedlt as personal representative of Gerry's estate, holding that the district court did not err or abuse its discretion.Gerry and Lorri had two daughters, Brittany Williams and Vicki, during their marriage and later divorced. After Gerry died, Lorri paid for his funeral expenses. Vicki then filed an application for informal probate. Lorri filed a creditor's claim claiming funeral expenses and then filed a petition for formal probate asserting that the divorce decree was a testamentary instrument that needed to be probated along with Gerry's will. Lorri also filed a petition to remove Vicki as personal representative of Gerry's estate. The district court granted both petitions. The Supreme Court affirmed, holding that Vicki was not entitled to relief on her claims of error. View "In re Estate of Williams" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of sexual intercourse without consent, holding that there was no error in the district court's evidentiary rulings.Specifically at issue was whether the district court erred in excluding defense evidence on relevancy grounds or committed reversible error by admitting certain hearsay statements into evidence. The Supreme Court affirmed, holding that the district court (1) erred in admitting hearsay evidence, but the error was harmless and not subject to reversal on appeal; and (2) did not err in excluding irrelevant defense testimony. View "State v. Ripple" on Justia Law

The Supreme Court reversed the oral pronouncement issued by the district court waiving Appellant's right to be physically present at his commitment hearing and the findings of fact, conclusions of law, and order of commitment issued by the district court, holding that the court committed reversible error by waiving Appellant's right to physically appear.The State filed a petition for involuntary commitment of Appellant supported by a mental health evaluation. Appellant advised the court that he desired to be present in-person at the commitment hearing. At the time of the hearing, however, counsel represented that he wished to waive Appellant's appearance and instead have him appear via two-way video conferencing due to improper behavior. The district court granted counsel's request and permitted him to appear via two-way video communication. The district court subsequently committed Appellant to the Montana State Hospital and authorized the use of involuntary medication. The Supreme Court reversed, holding that the statutory requirements for waiver of physical presence at the commitment hearing were not met. View "In re J.D.L." on Justia Law

The Supreme Court affirmed the judgment entered by the district court after a jury trial adjudging Defendant guilty of incest in violation of Mont. Code Ann. 45-5-507(1), holding that the district court did not err in admitting evidence of other acts.On appeal, Defendant argued that the district court erred by denying his pre-trial motion in limine to exclude evidence of other acts committed between Defendant and the victim in Wyoming on the grounds that the evidence showed motive, opportunity and Defendant's pattern of behavior and the absence of mistake or accident. The Supreme Court affirmed, holding (1) the district court did not err by denying Defendant's motion in limine to exclude the evidence on the grounds that it relevant and admissible to prove motive, plan, and preparation under Mont. R. Evid. 404(b); and (2) the danger of unfair prejudice was cured by the district court's numerous and repeated limiting instructions. View "State v. Stryker" on Justia Law

The Supreme Court reversed the judgment of the district court dismissing the complaint brought by Lustre Oil Company LLC and Erehwon Oil & Gas, LLC (collectively, Lustre Oil) for lack of subject matter jurisdiction, holding that the district court did not properly weigh the relevant jurisdictional factors.Lustre Oil filed an action against A&S Mineral Development Company, LLC seeking to quiet title and to invalidate A&S's interests in forty-one of the fifty-seven oil and gases leases operated by A&S within the Fort Beck Indian Reservation, home to the Assiniboine and Sioux Tribes. The district court dismissed the action for lack of jurisdiction, concluding that A&S was an arm of the Tribes entitling it to immunity. The Supreme Court reversed, holding (1) the district court did not err in concluding that A&S's incorporation under Delaware law did not favor immunity and in thus refusing to deny A&S tribal sovereign immunity based on state incorporation alone; and (2) consideration of the White factors weighed against the extension of sovereign immunity to A&S as an arm of the Tribes for the purpose of Lustre Oil's claims in this case. View "Lustre Oil Co. v. Anadarko Minerals, Inc." on Justia Law

The Supreme Court affirmed the decision of the district court upholding the ruling of the Montana Human Rights Commission dismissing Appellant's discrimination claim against the National Board of Medical Examiners (NBME), holding that the Commission correctly found that Appellant's complaint was not timely filed.Appellant, a medical student, filed a complaint against the NBME alleging that NMBE discriminated against her for having a mental disability when it denied her request for test-taking accommodations. The Human Rights Bureau dismissed the complaint on the basis that Appellant filed it outside of the 180-day statutory time limit. The Commission affirmed, and the district court dismissed Appellant's petition for review. The Supreme Court affirmed, holding that Appellant's complaint was not timely filed within 180 days of the date when the alleged discriminatory act occurred and Appellant discovered it. View "Zolnikov v. Nat'l Bd. of Medical Examiners" on Justia Law

The Supreme Court reversed the decision of the district court granting summary judgment to Defendants on Plaintiffs' asserted medical malpractice claim against Dr. Julie Kuykendall and Great Falls Obstetrical and Gynecological Associations (collectively, Defendants), holding that the district court erred in granting summary judgment on Plaintiffs' medical malpractice claim due to a failure to present sufficient supporting expert medical testimony.Stephanie Kipfinger gave birth to a son, E.C., who was ultimately diagnosed with hypoxic ischemic encephalopathy, cerebral palsy, developmental delay, and microcephaly. Kipfinger and Ben Cunningham (together, Plaintiffs) brought this action against Defendants, asserting a medical malpractice claim regarding Dr. Kuykendall's care of Stephanie and E.C. The district court concluded that Defendants were entitled to summary judgment. The Supreme Court reversed, holding that genuine issues of material fact precluded summary judgment on the causation element of Plaintiffs' medical malpractice claim against Defendants. View "Kipfinger v. Great Falls Obstetrical & Gynecological Associates" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's untimely post-conviction relief (PCR) petition and his motion for a new trial, holding that the district court did not abuse its discretion in finding that Appellant failed to present any evidence that would justify an exception to the time bar and denying his claims of ineffective assistance of counsel.In June 2016, Appellant was convicted of the felony aggravated assault of his son and was sentenced to twenty-two years in prison. In June 2020, Appellant filed a petition for a new trial and his PCR petition. The district court denied relief, holding (1) Appellant fell short of providing an equitable reason to depart from the determination that the PCR petition was time barred; and (2) Appellant did not offer newly-discovered evidence justifying granting his motion for new trial. The Supreme Court affirmed, holding that the district court (1) properly concluded that Appellant's PCR petition did not allege the existence of any newly-discovered evidence that would allow an exception to the one-year limitation; and (2) correctly denied Appellant's petition for a new trial based upon the alleged ineffective assistance of his trial counsel. View "Oliphant v. State" on Justia Law

The Supreme Court reversed the judgment of the district court granting a preliminary injunction preventing Robert Oberlander from accessing his leased State school trust land via private roadways in a subdivision, holding that Oberlander had standing to bring a prescriptive easement claim.In 2001, Oberlander acquired his leases and accessed the leased land by traveling over portions of two private roads maintained by the homeowners association (HOA) in this case. In 2021, the HOA applied for a preliminary injunction, claiming that Oberlander's use constituted a trespass, violation of applicable covenants, and unjust enrichment. Oberlander filed a third-party complaint against individual property owners within the HOA, claiming a prescriptive easement. The district court dismissed Oberlander's prescriptive easement claim on the grounds that he lacked standing and then granted the preliminary injunction. The Supreme Court reversed, holding that the preliminary was grounded in the improper conclusion that Oberlander lacked standing because, as an occupant of the dominant tenement, Oberlander had standing to bring a prescriptive easement claim pursuant to Mont. Code Ann. 70-17-109. View "Oberlander v. Hennequin" on Justia Law