Justia Montana Supreme Court Opinion Summaries

In a case before the Supreme Court of the State of Montana, the Montana Environmental Information Center sued the Montana Department of Public Service Regulation, Public Service Commission, and Northwestern Corporation, also known as Northwestern Energy. The plaintiff contested Northwestern's failure to purchase energy from Community Renewable Energy Project (CREP) resources in 2015 and 2016. Northwestern, which is a public utility, had obtained waivers from the Commission for these obligations. The plaintiff claimed that Northwestern’s waivers were granted erroneously and sought penalties for Northwestern’s non-compliance.The District Court reversed the Commission's decision, concluding that Northwestern hadn't taken all reasonable steps to procure CREP resources for the years in question. The court also assessed a $2,519,800 penalty against Northwestern. On appeal, the Supreme Court of the State of Montana held that the District Court correctly reversed the Commission's waiver for 2015, but made an error in assessing the penalty. The Supreme Court affirmed the decision in part, vacated it in part, and remanded the case to the District Court for further proceedings. The court directed the District Court to remand the case to the Commission to assess the penalty against Northwestern for its non-compliance in 2015 and, if applicable, 2016. View "Montana Environmental Information Center v. Northwestern Energy" on Justia Law

In this case, the defendant, Malinda Crazymule, was found to have violated her probation. The Sixteenth Judicial District Court, Rosebud County revoked her suspended sentence and ordered a four-year commitment to the Department of Corrections (DOC). The court gave Crazymule 130 days of street time and 21 days of jail time credit but denied credit for jail time served while Crazymule was in Northern Cheyenne Tribal custody. Crazymule appealed this denial.The Supreme Court of the State of Montana reversed the lower court's decision. The key issue was whether Crazymule was entitled to credit for the time served during her arrest warrant's issuance while she was in custody for tribal offenses. The Supreme Court found that the District Court erred in its interpretation of the relevant statutes.According to Section 46-18-203(7)(b), MCA, if a suspended or deferred sentence is revoked, the judge must allow credit for time served in a detention center. The Supreme Court emphasized that the language of this statute is not discretionary regarding awarding credit for time served. The court held that the District Court had jurisdiction over Crazymule once the arrest warrant was issued following the filing of the State’s revocation petition with the court, regardless of Crazymule's incarceration for a different offense.The Supreme Court concluded that Crazymule was entitled to credit from the date the revocation warrant was issued and she remained incarcerated in a detention center. The case was reversed and remanded for further proceedings. View "State v. Crazymule" on Justia Law

This case involves a minor plaintiff, identified as S.W., who suffered severe injuries inflicted by her father's girlfriend. The State of Montana's Department of Public Health and Human Services was sued based on claims that it negligently failed to remove S.W. from her father's home prior to the injuries. The District Court ruled that the state's child abuse investigation was negligent and had led to S.W.'s injuries. A jury awarded S.W. over $16 million in damages.Several issues were raised on appeal, including whether the District Court was correct in deciding that the state's immunity provision did not cover the State, but only individual persons, whether the state was negligent as a matter of law, and whether the assault on S.W. was foreseeable.The Supreme Court of the State of Montana held that the District Court was correct in its interpretation that the state's immunity provision did not extend to the State. However, the Supreme Court found that the District Court erred in its summary judgment that the State was negligent as a matter of law and that the assault on S.W. was foreseeable as a matter of law. The Court ruled that these issues contained material factual disputes that should be left to a jury. The Supreme Court also held that the District Court abused its discretion by imposing a disproportionate sanction on the State for spoliation of evidence. The judgment was reversed, the jury’s verdict was vacated, and the case was remanded for a new trial. View "S. W. v. State" on Justia Law

In this case, Kaitlyn Holmes, a nurse, was convicted of theft and ordered to pay restitution for stealing credit cards from the personal belongings of several employees at a medical clinic in Bozeman, Montana. The Eighteenth Judicial District Court, Gallatin County, also held Holmes responsible for the disappearance of social security cards from the belongings of one of the victims, Brooke Templeton, and included in the restitution order the cost of LifeLock memberships for Templeton and her children.Holmes appealed the decision, arguing that she should not be held liable for the missing social security cards as she only admitted to stealing the credit cards. She also contested the inclusion of the cost of long-term LifeLock memberships in the restitution order.The Supreme Court of the State of Montana affirmed the lower court's decision holding Holmes responsible for the missing social security cards, noting that there was sufficient evidence to establish a causal connection between Holmes' crimes and the missing cards. However, the court partially reversed the lower court's decision regarding the restitution order. It held that the cost of the LifeLock memberships, intended to provide broad identity theft protection for the victims, was too attenuated to qualify for restitution under the statute as it was not incurred in the pursuit of the lost property.The case was remanded for entry of an amended judgment. The court's decision underscores the importance of establishing a clear causal relationship between a defendant's criminal conduct and the pecuniary loss suffered by the victim when determining restitution. This case also highlights the limitations of restitution orders, indicating that secondary expenses, not directly related to the pursuit of lost property, may not qualify for restitution under the statute. View "State. v. Holmes" on Justia Law

In this case, petitioners Montanans Securing Reproductive Rights and Samuel Dickman, M.D., sought a declaratory judgment on original jurisdiction against the Montana Attorney General and the Montana Secretary of State. The petitioners argued that the Attorney General wrongly determined that their proposed ballot issue was legally insufficient, had no authority to attach a fiscal statement to the ballot issue, and that their ballot statements complied with Montana Code Annotated sections 13-27-212 and -213.The Supreme Court of Montana held that the Attorney General did err in concluding that the proposed ballot issue was legally insufficient, as it did not violate the separate-vote requirement of Article XIV, Section 11, of the Montana Constitution. The proposal effects a single change to the Montana Constitution on a single subject: the right to make decisions about one's own pregnancy, including the right to abortion.The court also found that the Attorney General exceeded his authority by appending a fiscal statement to the proposed ballot issue because the budget director's fiscal note did not indicate that the issue would have a fiscal impact.Finally, the court declined to rule on the compliance of the petitioners’ ballot statements with Montana Code Annotated sections 13-27-212 and -213, directing the Attorney General to prepare a ballot statement in line with statutory requirements and forward it to the Montana Secretary of State.The court essentially concluded that the proposed ballot issue was legally sufficient and did not require separate votes for its multiple components, as they were all closely related to the central issue of reproductive rights. The court also confirmed that the Attorney General had overstepped his authority by attaching a fiscal statement to the ballot issue. View "Montanans Securing Reproductive Rights v. Knudsen" on Justia Law

This case involves an appeal against a judgment from the Montana Eighteenth Judicial District Court, Gallatin County, which committed the appellant, G.M., into the custody and care of the Montana State Hospital (MSH) for involuntary mental health treatment. The key issue at hand is whether the District Court erroneously found that G.M. was unable to adequately care for her own basic needs and safety based on hearsay statements made by her husband through the testimony of a court-appointed professional.G.M., aged 66 at the time of the petition for involuntary mental health commitment in 2021, was alleged to be suffering from a diagnosed psychotic mental disorder. G.M.'s husband's statements, along with her own behavior and assessments from mental health professionals, were the basis for the court's decision. G.M.'s counsel repeatedly objected to the court-appointed professional's testimony regarding her husband's out-of-court statements, but these objections were overruled.G.M. testified on her own behalf, denying having a mental disorder or requiring treatment. Despite this, the District Court found that due to her diagnosed schizophrenic and delusional mental disorder, G.M. was “substantially unable to provide for her own basic needs of food, clothing, shelter, health, or safety."On appeal, the Supreme Court of the State of Montana affirmed the judgment of the lower court. The court found that the lower court's decision was not clearly erroneous and was supported by substantial admissible evidence. The court stated that the hearsay statements of G.M.'s husband were admissible under the rules of evidence to explain the underlying rationale for the court-appointed professional person's expert opinion. The court also noted that the judgment was independently supported by the professional person's personal observations and opinions on G.M.'s condition and ability to care for her own needs and safety. View "In re Matter of G.M." on Justia Law

The case involves Michael Goguen, an engineer and businessman, who was the subject of two civil suits alleging sexual and criminal misconduct. The New York Post published an article detailing these lawsuits, which Goguen claimed was defamatory. Goguen filed a defamation lawsuit against New York Post's parent company, NYP Holdings, and others. In response, NYP Holdings argued that their article was protected by New York’s fair report privilege, a law that protects media from defamation suits if they are reporting on official proceedings.However, the District Court in Montana, where Goguen resides, applied Montana law and denied NYP Holdings' motion to dismiss, finding that whether the article was privileged was a question of fact for the jury. On appeal, the Supreme Court of Montana determined that under Montana's choice of law rules, New York law should be applied to determine the fair report privilege. The Court found that all the contested statements in the article fairly and accurately reported the lawsuits against Goguen and were thus protected by New York's fair report privilege. Therefore, the Court held that NYP Holdings was entitled to dismissal of Goguen’s complaint.The Court also upheld the District Court's decision to dismiss Goguen's defamation claim against former police chief Bill Dial, ruling that Dial's statements in the article were protected opinions and not actionable. View "Goguen v. NYP Holdings" on Justia Law

The Supreme Court of the State of Montana was presiding over a dispute regarding the reimbursement claim of Angela Mastrovito from the Estate of Rebekah Barsotti. Mastrovito, the mother of the deceased Rebekah Barsotti, had served as her court-appointed guardian after Rebekah went missing and was presumed dead following a reported drowning accident. Mastrovito filed a claim for $140,688.45 in expenses she allegedly incurred during her guardianship, including costs for rent, legal fees, meals, travel, and others. The claim was opposed by Rebekah's husband, David Barsotti, who was appointed as the personal representative of Rebekah's estate.The District Court denied Mastrovito's claim for three reasons: her appointment as a guardian was retroactively improper due to Rebekah's death, the claimed expenditures were unreasonable, and the claim lacked sufficient substantiation. Mastrovito appealed this decision, arguing that her appointment was not improper and that she was denied a fair hearing to present evidence in support of her claim.Upon review, the Supreme Court affirmed the District Court's denial of the claim. The court reasoned that even if Mastrovito's appointment was proper, she still failed to provide sufficient support for her claim. The court concluded that a hearing could not change the fact that Mastrovito's claim was facially insufficient. The court underscored the need for providing supporting evidence to determine the validity and reasonableness of claimed costs. View "In re Estate of Barsotti" on Justia Law

The Supreme Court of the State of Montana affirmed a lower court decision that granted Dr. Gregory S. Tierney's motion to dismiss a medical malpractice lawsuit filed by Janice M. Dodds for insufficient service of process. Dodds initially filed the suit against Dr. Tierney and Benefis Health System in 2013, alleging medical malpractice related to a knee replacement surgery. She failed to serve the defendants in time. Dr. Tierney later filed for bankruptcy, which invoked an automatic stay, halting the lawsuit. After his bankruptcy discharge, Dodds attempted to serve Dr. Tierney but failed to do so within the required 30-day timeframe following the discharge.Dodds further sought to join Dr. Tierney's malpractice insurance company as the real party in interest, but the court denied the motion. Upon review, the Supreme Court found that Dodds had not proven Dr. Tierney's liability, thus the insurer had no duty to indemnify him. The court also rejected Dodds' argument that Dr. Tierney lacked standing after his Chapter 7 discharge. The court held that Dr. Tierney maintained a personal stake in demonstrating he was not liable for medical malpractice and that his insurer would only have a duty to indemnify him once Dodds proved her malpractice claims. View "Dodds v. Tierney" on Justia Law

The case involves an appeal from a defendant, Christopher Michael Welch, who was convicted of attempted incest, incest, sexual abuse of children, and unlawful restraint. Welch began dating the mother of three daughters in 2018, and they eventually got married. The oldest daughter, J.P., testified about the inappropriate behavior and sexual advances made by Welch towards her. During the trial, Welch's defense suggested J.P. fabricated her claims.Welch's appeal raised two issues. First, he claimed prosecutorial misconduct, arguing that the prosecutor improperly vouched for J.P.'s credibility and made inappropriate emotional appeals to the jury. The Supreme Court of the State of Montana found no evidence of prosecutorial misconduct that would warrant plain error review, arguing that the prosecutor's comments were within the boundaries of discussing witness credibility and the lack of forensic evidence. The court also rejected Welch's argument that the cumulative effect of the state's comments prejudiced his right to a fair trial.Second, Welch objected to certain probation restrictions imposed by the District Court, arguing they had no reasonable nexus to the offense charged. These included prohibitions on using or possessing alcohol and illegal drugs, gambling, entering bars, and entering casinos. The court found these to be standard conditions authorized by statute and ruled that Welch failed to demonstrate that the lower court abused its discretion in imposing them. Therefore, the court affirmed the conviction and sentencing. View "State v. Welch" on Justia Law