Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the district court concluding that Plaintiffs - a climate advocacy group and three NorthWestern Energy ratepayers - had standing to challenge Mont. Code Ann. 69-8-421 as unconstitutional and then invalidating the statute, holding that Plaintiffs' challenge to the preapproval statute was not justiciable.At issue was section 69-8-421, which effectively permitted NorthWestern, but no other public utility, to apply to the Montana Public Service Commission for preapproval of an electricity supply resource. Plaintiffs filed a complaint requesting declaratory judgment that the preapproval statute violated both Mont. Const. art. II, 31 and Mont. Const. art. V, 12. NorthWestern filed a motion to dismiss for both lack of standing and ripeness. The district court denied the motion. The Supreme Court reversed, holding (1) Plaintiffs lacked standing to raise the rights of non-party utilities; and (2) Plaintiffs' alleged consumer injuries were not yet ripe for consideration. View "350 Montana v. State" on Justia Law

The Supreme Court affirmed the decision of the district court to deny Petitioner's petition to reinstate his driver's license, holding that the district court did not err in denying the petition because Petitioner did not meet his burden to prove that the suspension of his driver's license was improper.On appeal, Petitioner argued that his request to speak to an attorney prior to taking a preliminary breath test and a post-arrest blood test should not have been taken as an implied refusal to submit to either test and, therefore, he did not refuse to take the tests. The Supreme Court affirmed, holding (1) the record reflected that Petitioner explicitly refused to take the tests; and (2) the district court correctly denied Petitioner's petition. View "Turner v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court ruling that Mont. Code Ann. 50-20-109(1)(a), which restricts providers of abortion care to physicians and physician assistants (PAs), violates a woman's fundamental right of privacy, guaranteed by the Montana Constitution, to seek abortion care from a qualified health care provider of her choosing, holding that there was no error.In reaching its decision, the district court concluded that the State failed to "clearly and convincingly demonstrate a medically acknowledged, bona fide health risk which justifies interfering with a patient's fundamental right[....]to choose the health care provider who performs the [abortion] procedure[.]" The Supreme Court affirmed, holding (1) there is no medically acknowledged, bona fide health risk for the State to restrict the availability of abortion care by preventing Advanced Practice Registered Nurses (APRNs) from performing abortions; and (2) therefore, Montanans have the right to seek abortion care from certified APRNs. View "Weems v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of criminal endangerment, driving under the influence of alcohol (DUI) and partner or family member assault, holding that the district court did not err in denying Defendant's motions to suppress.At issue was the denial of Defendant's motion to suppress for lack of particularized suspicion, motion to suppress breath test, and motion to suppress statements. Specifically, Defendant argued that there were insufficient articulable facts to conduct an investigatory stop, there were sufficient articulable facts to conduct a DUI investigation, and the district court did not err in concluding that Defendant's statements to law enforcement were voluntary. View "State v. Schlichenmayer" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgments of the district court convicting Defendant and denying his post-judgment motion for resentencing or rescission, holding that the district court unlawfully imposed sex offender registration on Defendant under Mont. Code Ann. 46-23-512.Defendant entered a guilty plea and a no contest plea on two counts of felony criminal endangerment. On appeal, Defendant argued, among other things, that the district court erred in concluding that the State did not breach the parties' plea agreement at sentencing. The Supreme Court reversed in part, holding (1) the State did not undermine or breach the plea agreement; but (2) the district court erred under section 46-23-512 in imposing sex offender registration. View "State v. Collins" on Justia Law

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