Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court granting summary judgment for Leonard Schleder and declaring him the owner of the mineral rights at issue in this case, holding that the district court did not err or abuse its discretion.Specifically, the Supreme Court held that the district court (1) correctly interpreted the warranty deed language to reserve to Schleder all his mineral interests in the property; (2) properly considered the chain of title in interpreting the language of the unambiguous warranty deed; and (3) did not err in determining that estoppel by deed did not apply to prevent Schleder from asserting title to the mineral interests. View "Dellit v. Schleder" on Justia Law

The Supreme Court affirmed the judgment of the district court regarding several orders unfavorable to Plaintiff in this dispute over the development of a subdivision on property containing a floodplain within Lewis and Clark County, holding that there was no error or abuse of discretion.In its challenged orders, the district court dismissed Plaintiff's negligence and negligent misrepresentation claims, denied Plaintiff's motion for a declaratory judgment that Mont. Code Ann. 76-5-109(4) is unconstitutional, dismissed Plaintiff's claims for inverse condemnation and nuisance, and dismissed Plaintiff's suit against the Montana Department of Transportation. The Supreme Court affirmed, holding that the district court (1) did not err in dismissing Plaintiff's inverse condemnation claim; (2) did not err in dismissing Plaintiff's unjust enrichment claim; (3) did not err in finding Mont. Code Ann. 76-5-109(4) was constitutional; and (4) did not err in dismissing Plaintiff's remaining nuisance claims. View "Hamlin Construction & Development Co. v. Mont. Dep't of Transportation" on Justia Law

The Supreme Court reversed the order entered by the district court denying Skyline Consulting Group's motion to vacate and set aside bond substitution and reinstate construction lien, holding that the district court erred in concluding that Skyline had waived its right to challenge the substitute bond.In this dispute between two subcontractors, Mortensen Woodwork petitioned the district court to substitute Skyline's construction lien against certain property with the intent to pursue foreclosure. Skyline named SP Hotel Owner in the lien. Mortensen then secured a bond from a surety company for 150 percent of the amount Skyline claimed and filed a petition to substitute the bond for the lien. The district court did so. Skyline requested that the district court reinstate its lien because Mortensen was not authorized to substitute a bond. The district court denied the request. The Supreme Court reversed, holding (1) Skyline did not waive its right to challenge the substitute bond in a separate arbitration proceeding; and (2) the district court erred in concluding that Montana law authorized Mortensen, a subcontractor, to substitute a bond for Skyline's construction lien. View "Skyline Consulting Group v. Mortensen Woodwork, Inc." on Justia Law

The Supreme Court affirmed the judgment, decree of foreclosure, and order of sale by the district court, and the orders and actions contained within these documents, holding that there was no error or abuse of discretion.Thermal Design, Inc. filed a complaint to foreclose its construction lien against Mark and Pam Duffy and Central Copters, Inc. The complaint also asserted claims against TNT Building Systems. A jury found that TNT, acting as an agent of Central Copters, entered into a contract with Thermal Design for the insulation system, and both TNT and Central Copters were jointly and severally liable for breaching the contract with Thermal Design. As to a crossclaim between TNT and Central Copters, the jury found that both parties breached their agreement but that only TNT incurred damages. The district court entered a final order restating that, as a matter of law, Thermal Design had a valid construction lien attaching to both the Duffys’ real property and Central Copters’ building that should be foreclosed. The Supreme Court affirmed, holding that the district court did not err or abuse its discretion in the proceedings below. View "Thermal Design, Inc. v. Thorson" on Justia Law

The Supreme Court affirmed the judgment of the district court rejecting Plaintiff's appeal of the Montana Human Rights Commission's rejection of his claims grounded in political discrimination, holding that while the district court erred in ruling that Appellant had to pursue his 42 U.S.C. 1983 claim under the exclusive remedy of the Montana Human Rights Act (MHRA), claim preclusion now barred him from relitigating that claim.Plaintiff, the undersheriff of Missoula County, was reassigned to the position of senior deputy when his opponent in an election race won the office of Missoula County Sheriff. Plaintiff brought a human rights complaint alleging, inter alia, retaliation, discrimination, and constructive discharge based on his demotion. The Commission denied the complaint. Thereafter, Plaintiff brought this complaint alleging wrongful discharge, intentional infliction of emotion distress, unlawful political discrimination, and unlawful retaliation. The district court dismissed the complaint, holding that the MHRA was Plaintiff's exclusive remedy. The Supreme Court affirmed, holding (1) the district court improperly dismissed Plaintiff's section 1983 claim; and (2) because the underlying facts in Plaintiff's amended complaint were the same as his human rights complaint, the claims were precluded by the final judgment of the administrative proceedings. View "Clark v. McDermott" on Justia Law

The Supreme Court reversed Defendant's conviction of sexual abuse of children, holding that the trial court erred by denying Defendant's motion to suppress, and the error was not harmless.On appeal, Defendant challenged the denial of his motion to suppress the evidence discovered by his parole officer when the officer conducted a warrantless search of Defendant's phone. Defendant argued that the search was unreasonable because it exceeded the scope of his consent and because his parole officer lacked a valid exception to the warrant requirement. The Supreme Court agreed and reversed Defendant's conviction, holding that the probation officer's warrantless search of Defendant's digital photo gallery was not a valid probation search under the Montana Constitution, and the contraband discovered as a consequence of the unlawful search should have been suppressed under the exclusionary rule. View "State v. Mefford" on Justia Law

The Supreme Court affirmed the preliminary injunction entered by the district court prohibiting Montana Secretary of State Christi Jacboson from enforcing two election laws enacted during the 2021 Montana Legislative Session pending final resolution of constitutional challenges brought by Plaintiffs, holding that there was no abuse of discretion.At issue were Senate Bill 169, which prevented voters from using student identifications to establish identity at the polls without also furnishing specified additional documentation showing the voter’s name and current address, and House Bill 176, which removed the option for election day registration allowing Montanans to both register to vote and cast a ballot on election day. The district court entered an order temporarily enjoining the election laws. The Supreme Court upheld the order, holding that the evidence was sufficient to issue a preliminary injunction preserving the status quo pending a final resolution of the matter at trial. View "Democratic Party v. Jacobsen" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the district court distributing the marital estate and calculating child support upon the dissolution of Wife's marriage from Husband, holding that while the district court committed some errors, Wife failed to demonstrate that a new trial was required.Specifically, the Supreme Court held (1) the marital estate included Wife's interests in her family business and Husband's retirement earnings up to the date of the parties' dissolution; (2) the district court did not abuse its discretion calculating child support; and (3) Wife did not demonstrate that the errors committed by the district court in this case were due to the district court's adoption of Husband's proposed findings of fact and conclusions of law such that they require a new trial. View "In re Marriage of Frank" on Justia Law

The Supreme Court affirmed in part the order of the district court revoking Defendant's deferred sentence and imposing a ten-year suspended sentence without any reduction for elapsed time and remanded for the limited purpose of Manding the sentence to reflect 335 days of credit for elapsed time served prior to the revocation, holding that Defendant was entitled to credit for elapsed time.Specifically, the Supreme Court held (1) the district court had full authority to reimpose Defendant's original sentence of ten years for her felony theft conviction pursuant to Mont. Coder Ann. 46-18-203(7)(a)(iv); and (2) because section 46-18-203(7)(b) imposes a legal mandate on the district court properly to credit Defendant for elapsed time and to specifically explain any denial of credit for elapsed time the district court's sentence was improper to the extent it did not factor in credit Defendant was entitled to for elapsed time. View "State v. Pennington" on Justia Law

The Supreme Court reversed the judgment of the district court accepting an imposing a proposed youth court consent decree disposition, placing D.A.T. on supervised conditional probation for two years or until sooner released, and suspending the underlying youth court delinquency proceeding, holding that the youth court erred.At issue before the Supreme Court was whether the youth court erred in concluding that the consent decree guilt admission required by Mont. Code Ann. 41-5-1501(2) constitutes or requires a change of answer under Mont. Code Ann. 41-5-1502(8), thereby effecting a delinquency adjudication. The Supreme Court answered the question in the affirmative and remanded for entry of an amended dispositional order clarifying the effect of D.A.T.'s consent decree admission in according with Mon. Code Ann. 41-5-1501(1). View "In re D.A.T." on Justia Law