Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the district court's sentence on Defendant's convictions for escape and assault on a peace officer, holding that the district court erred in calculating credit for time served and in imposing supervisory conditions on Defendant's future parole.On appeal, Defendant argued (1) the trial court failed properly to credit the time Defendant spent in jail prior to sentencing after he was committed on another offense to the Montana Department of Corrections (DOC), and (2) the court improperly imposed supervisory conditions on Defendant's unsuspended sentence to the DOC. The State conceded the second issue on appeal. The Supreme Court reversed, holding that the district court (1) erred by granting Defendant only 56 days of credit for time served and should have given for time served in the amount of 396 days; and (2) erred in imposing supervisory conditions on Defendant's sentence when it was ordered entirely unsuspended. View "State v. Spagnolo" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court convicting and sentencing Defendant for assault with a weapon, holding that the district court erred in its calculation of Defendant's credit for time served.On appeal, Defendant challenged several evidentiary rulings and the calculation of credit toward his sentence for time served. The Supreme Court remanded the case, holding that the district court (1) did not err by admitting the victim's hospital statement at trial as a prior inconsistent statement; (2) did not err by admitting evidence of a conversation between Defendant and his girlfriend as an admission by party-opponent; and (3) should have awarded Defendant an additional 269 days of credit for time served. View "State v. Pitkanen" on Justia Law

The Supreme Court reversed the order of the district court granting Defendant's motion to dismiss Plaintiff's complaint making a claim for statutory damages against the Board of County Commissioners pursuant to Mont. Code Ann. 76-3-625(1) and equal protection, takings, and due process claims under 42 U.S.C. 1983, holding that the district court erred.In granting the Board's motion to dismiss, the district court determined that Plaintiff's section 76-3-625(1) claims were barred by a thirty-day statute of limitations and its section 1983 claims failed to state a claim. The Supreme Court reversed, holding that the district court erred in (1) determining that the section 76-3-625(1) claim was subject to a thirty-day statute of limitations and was therefore time-barred; and (2) erred in concluding that Plaintiff's 42 U.S.C. 1983 claims lacked a sufficient protected property interest and were insufficiently pled to survive a motion to dismiss for failure to state a claim. View "Tai Tam, LLC v. Missoula County" on Justia Law

The Supreme Court affirmed the order entered by the district court granting summary judgment to the Public Service Commission (PSC) and dismissing Appellants' claim that Mont. Code Ann. 69-2-102 was unconstitutional, holding that this matter lacked a justiciable controversy.Appellants filed a petition seeking a judgment declaring that the PSC's contested case procedures were unconstitutional. Specifically, Appellants alleged that the PSC's application of section 69-2-102 was unconstitutional as applied. The district court granted summary judgment to the PSC, dismissing Appellants' challenges against the statute on justiciability grounds. The Supreme Court affirmed, holding that the district court did not err in concluding that Appellants lacked standing to challenge, on due process grounds, the constitutionality of section 69-2-102. View "Broad Reach Power, LLC v. Mont. Dep't of Service Regulation" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence confiscated by a adult foster care group home's manager who subsequently turned the evidence over to the police, holding that the district court did not err when it failed to suppress the evidence.The manager of the group home contacted the police on several occasions stating that she had confiscated child pornography from Defendant, a resident of the group home, pursuant to the group home's rules. The manager gave the police the confiscated evidence, which led to the grant and execution of a search warrant. Defendant was subsequently charged with possession of child pornography. Defendant moved to suppress the evidence, which the district court denied. Defendant subsequently entered into a plea agreement with the State. The Supreme Court affirmed the denial of Defendant's motion to suppress, holding (1) the group home manager was acting as a private party when she confiscated Defendant's electronic devices containing pornography; and (2) Defendant consented to the manager confiscating his electronic devices by agreeing to the group home's rules. View "State v. Larson" on Justia Law

The Supreme Court reversed the orders of the district court granting Zinvest, LLC's motion for summary judgment and dismissing Wells Fargo Bank, N.A.'s complaint alleging that Zinvest failed to give proper notice of pending tax deeds under Mont. Code Ann. 15-18-212 and requesting the tax deeds issued to Invest be declared void, holding that the district court erred.Wells Fargo held a deed of trust against two parcels of land. Because the taxes assessed against each parcel for the tax year 2014 were unpaid the Missoula County treasurer conducted a tax lien sale for both parcels. Missoula County purchased the tax liens, executed a county treasurer's certificate of tax sale for both parcels and assigned the certificates to Zinvest. When Zinvest mailed notices that tax deeds may issue to Wells Fargo, they were returned. The Missoula County treasurer then executed tax deeds conveying the parcels to Zinvest. Wells Fargo subsequently brought its complaint. The district court granted summary judgment for Zinvest. The Supreme Court reversed, holding that Zinvest's failure to mail notices that the tax deeds may issue to Wells Fargo violated Mont. Code Ann. 15-18-212. View "Wells Fargo Bank, N.A. v. Zinvest, LLC" on Justia Law

The Supreme Court denied Defendant's motion to allow withdrawal of his guilty plea and dismiss the underlying matter on double jeopardy grounds, holding that the district court did not err in denying Defendant's motion to withdraw his guilty plea and dismiss and the criminal endangerment and criminal mischief charges in Jefferson County.Jefferson County charged Defendant with criminal endangerment, fleeing from or eluding a peace officer, and criminal mischief. The next month, Gallatin County charged with him criminal endangerment and fleeing from or eluding a peace officer. Defendant pled guilty to both charges. Defendant subsequently moved to withdraw his guilty plea and to dismiss the Jefferson County charges, arguing that they violated constitutional double jeopardy protections. The district court allowed the motion as to the fleeing from or eluding a peace officer charge and otherwise denied the motion. The Supreme Court affirmed, holding that the district court did not err by denying Defendant's motion to withdraw his guilty plea as to the criminal endangerment and criminal mischief charges. View "State v. Dunne" on Justia Law

The Supreme Court affirmed the judgment of the district court revoking Defendant's suspended sentence and imposing a sentence with a termination date beyond the original sentence, holding that the district court did not err in sentencing Defendant to a term no greater than his original sentence and in denying credit for elapsed time.Defendant pleaded guilty to two counts of felony indecent exposure. The State later filed a petition to revoke Defendant's sentence. The district court imposed a suspended sentence with a termination date beyond the original sentence. The Supreme Court affirmed, holding that the district court did not violate either Mont. Code Ann. 46-18-203(7)(a)(iii) or Mont. Code Ann. 46-18-203(7)(b) in sentencing Defendant to a term no greater than his original sentence and in denying credit for elapsed time. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the district court issuing a decree quieting title to a claimed easement in favor of Rose Family Trust (Rose), holding that the district court did not err by determining that a "notice of purchaser's interest" (NPI) did not convey title to the easement in dispute.Rose filed this action to quiet title and to enjoin use of the claimant easement by Appellants. The district court ruled in favor of Rose, holding that the NPI at issue did not constitute a valid instrument of conveyance and therefore did not transfer any easement rights to Appellants. On appeal, Appellants argued that the NPI was itself an instrument of conveyance and, alternatively, that the NPI functioned as an abstract of an instrument of conveyance. The Supreme Court disagreed and affirmed, holding that neither the NPI nor the abstracted contract for deed effectuated title transfer, and therefore, there was no actual conveyance on which Appellants could base their claim. View "Towsley v. Stanzak" on Justia Law

The Supreme Court affirmed the order of the district court denying Defendant's motion to prevent silent security camera footage from being made available to the jury during deliberations and subsequent judgment of guilty to the charge of deliberate homicide, holding that the district court did not abuse its discretion.After a jury trial, Defendant was found guilty of deliberate homicide and sentenced to a 100-year term of imprisonment. On appeal, Defendant argued that the district court abused its discretion by allowing silent video footage from the neighbor's security camera to go into the jury room during deliberations. The Supreme Court affirmed, holding that where the camera footage at issue was neither testimonial in nature nor cared any substantial risk of undue emphasis, it was not an abuse of discretion for the district court to provide the jury with unrestricted access to this footage during deliberations. View "State v. Green" on Justia Law