Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed Defendant's sentence for driving under the influence (DUI), holding that the district court erred by sentencing Defendant to the Montana State Prison (MSP) and by requiring him to pay a $100 statutory surcharge.Defendant was charged with felony DUI for a sixth offense. After a trial, the jury found Defendant guilty of DUI. The district court sentenced Defendant to serve a five-year term at the MSP and ordered him to pay a $100 surcharge pursuant to Mont. Code Ann. 46-18-236(1). The Supreme Court reversed in part, holding (1) the district court did not err by determining that permitting a certain witness to appear by video was supported by appropriate public policy considerations; and (2) as conceded by the statute, Defendant should have been sentenced to the Department of Corrections up to a maximum of five years and not to MSP, and the district court should have assessed Defendant a surcharge of $50. View "State v. Walsh" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for two counts of felony tampering with witnesses, holding that Defendant was not entitled to relief on any of his allegations of error.Specifically, the Supreme Court held (1) the State presented sufficient evidence to support Defendant's convictions for witness tampering pursuant to Mont. Code Ann. 45-7-206; (2) this Court declines to exercise plain error review of Defendant's claims of prosecutorial misconduct; and (3) trial counsel's failure to object to a alleged misconduct by the prosecutor did not constitute ineffective assistance of counsel. View "State v. Palafox" on Justia Law

The Supreme Court reversed the conclusion of the district court that the more than three-year delay between Defendant's arrest and his subsequent criminal trial did not violate his constitutional right to a speedy trial, holding that Defendant did not receive his guaranteed right to a speedy trial.Defendant was charged with assault with a weapon. After facing a lengthy wait to be evaluated for his mental fitness to stand trial Defendant received a bed at the Montana State Hospital (MSH), where his fitness for trial improved. Defendant's fitness, however, decompensated after he was sent back to jail, leading to a second admission to MSH before the case finally went to trial. A jury found Defendant guilty, and the district court denied Defendant's motion to dismiss for lack of speedy trial. The Supreme Court reversed, holding that the 1,179-day delay between Defendant's arrest and trial, due to systemic institutional problems, violated Defendant's constitutional right to a speedy trial. View "State v. Allery" on Justia Law

The Supreme Court reversed the judgment of the district court revoking Defendant's deferred sentence and sentencing him to a five-year term with the Montana Department of Corrections (DOC) and giving him credit for 138 days of time served, holding that's the district court imposed an illegal sentence.After an adjudicatory hearing, the district court found that Defendant committed several violations of his probation, as alleged by the State. The district court imposed the sentence after holding a dispositional hearing. The Supreme Court reversed, holding that the district court lacked authority to revoke Defendant's previous deferred sentence and to resentence him to a five-year DOC commitment because the deferred sentence expired before the State filed a petition to revoke. View "State v. Ellsworth" on Justia Law

The Supreme Court affirmed in part and reversed I'm part the order of the district court granting summary judgment to the State and Department of Natural Resources and Conservation (State) regarding interpretation of a settlement agreement between the parties, holding that the district court erred by reaching the merits of a nonjusticiable issue.In this case stemming from settled litigation between the parties involving the State's rent claims against utility companies for use of riverbed acreage occupied by their hydroelectric projects. On appeal, defendant Avista Corporation argued that the district court erred in concluding that the agreement's provision governing a conditional reduction of rent would not provide a retroactive credit for past rent paid by Avista. The Supreme Court affirmed in part and reversed in part, holding (1) a portion of the district court's order must be reversed as being unripe and constituting an advisory opinion about speculative issues that may never arise; and (2) the district court properly declared that "Avista [was] required to continue to pay the annual full market rental rate as set forth in the Settlement, Consent Judgment, and Lease." View "State Dep't of Natural Resources & Conservation v. Avista Corp." on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of bail-jumping and sentencing him to ten years in prison with no time suspended, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not violate Defendant's constitutional right to confrontation by admitting minute entries by the clerk of court stating that Defendant was present at his arraignment but absent from his omnibus hearing; and (2) the trial court did not commit reversible error when it denied Defendant's motion to continue the trial date because Defendant's substantial right were not prejudiced. View "State v. Staudenmayer" on Justia Law

The Supreme Court reversed the determination of the district court that the Indian Child Welfare Act (ICWA) did not apply to this proceeding but declined Mother's request to order her three minor children's immediate return to her, holding that remand was required due to noncompliance issues.Grandparents filed a petition to establish parenting and custody of three minor children, alleging that a child-parent relationship as defined by Mont. Code Ann. 40-4-211(6), existed between the children and Grandparents and that Parents had engaged in conduct contrary to the parent-child relationship. Parents and Grandparents subsequently signed a stipulated parenting plan designating Grandparents as the sole guardians of the children. Mother later filed a notice that she was withdrawing her consent to the stipulated parenting plan pursuant to 25 U.S.C. 1913(b), part of ICWA, and a motion for immediate return of the children to her custody. The district court denied relief, ruling that ICWA does not apply to internal family disputes. The Supreme Court reversed, holding that the district court failed to follow ICWA's procedural requirements and that remand was required for further proceedings. View "In re L.R.J." on Justia Law

The Supreme Court affirmed the judgment and commitment of the district court sentencing Appellant to fifty-five years in the Montana State Prison, including a consecutive ten-year commitment to the Department of Corrections, for his two criminal endangerment convictions, holding that there was no error.On appeal, Defendant argued that his two criminal endangerment convictions violated Mont. Code Ann. 46-11-410(2)(a), the multiple charges statute, because his convictions arose from the same transaction. The Supreme Court affirmed, holding that Defendant's convictions of criminal endangerment were based on two distinct criminal offenses and therefore did not violate the multiple charges statute. View "State v. McNamara" on Justia Law

The Supreme Court reversed the order of the Workers' Compensation Court (WCC) granting in part and denying in part Petitioner's motion for summary judgment, holding that the WCC erred in part.At issue on appeal was whether the WCC erred when it ruled that the aggregate wages of Petitioner, a disabled worker, calculated at the time of injury, are used to determine Petitioner's permanent partial disability (PPD) benefit rate regardless of Petitioner's actual wage loss at maximum healing. The Supreme Court reversed, holding that the WCC erred by ruling that Petitioner's PPD indemnity benefit rate was aggregated from both of her time-of-injury employments when she was only precluded from one employment upon reaching maximum medical improvement. View "Barnhart v. Mont. State Fund" on Justia Law

The Supreme Court affirmed the judgment of the district court in favor of a group of eastern Montana farmers (Farmers) and against four affiliates of USA Biofuels, LLC (Affiliates) on Farmers' claims on a variety of contract and tort theories, holding that there was no error.In 2018, Farmers entered individual written contracts with USA Biofuels to grow 10,000 acres of hemp. Farmers brought this action alleging that they never received full payment from Defendants, including USA Biofuels and various affiliates. The district court concluded on summary judgment that USA Biofuels breached its contract and awarded damages. Farmers subsequently abandoned their contract claims and secured a tort judgment against Affiliates. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion when it entered judgment on the punitive damages award; (2) did not err in instructing the jury; and (3) did not err in ruling on summary judgment that three shareholders were alter egos of USA Biofuels. View "Romo v. USA Biofuels, LLC" on Justia Law