Justia Montana Supreme Court Opinion Summaries

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

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