Justia Montana Supreme Court Opinion Summaries

The plaintiffs, a law firm and its principal, challenged a Montana statute enacted in 2021 that prohibits discrimination based on an individual’s vaccination status or possession of an immunity passport. The law applies broadly to businesses, governmental entities, employers, and public accommodations, with certain exceptions for schools, daycare facilities, and healthcare providers. One provision of the law also prohibits requiring individuals to receive vaccines authorized only for emergency use or still undergoing safety trials. The plaintiffs alleged that the statute violated several provisions of the Montana Constitution, including rights to a clean and healthful environment, equal protection, inalienable rights, and the constitutional requirement that a bill’s subject be clearly expressed in its title.The case was first heard in the District Court of the Seventh Judicial District, Richland County. The District Court denied the plaintiffs’ request for a preliminary injunction and dismissed most of their constitutional claims, but allowed the claim regarding the bill’s title and single-subject requirement to proceed. On remand from the Montana Supreme Court’s earlier decision in Netzer Law Office, P.C. v. State, the District Court ultimately held that the main antidiscrimination provision of the law complied with the constitutional clear-title requirement, but that the provision prohibiting mandates for emergency use or trial vaccines did not, and voided that subsection.On appeal, the Supreme Court of the State of Montana affirmed the District Court’s dismissal of the plaintiffs’ other constitutional claims. The Supreme Court held that the law’s title was sufficiently clear and not misleading as to its main antidiscrimination provision, affirming its validity. However, the Supreme Court reversed the District Court’s invalidation of the provision regarding emergency use and trial vaccines, holding that this subsection was germane to the bill’s general purpose and did not violate the clear-title or single-subject requirements. Thus, both challenged provisions of the statute were upheld. View "Netzer v. State" on Justia Law

Richard Mabee died from a methamphetamine overdose while confined in the Wheatland County Jail. He had traveled from Washington to Montana, violating his probation, and was arrested after a traffic stop. During booking, officers did not observe signs of drug use or find contraband, but video footage later showed Mabee disposing of a small object in his cell. Early the next morning, Mabee exhibited signs of methamphetamine intoxication, which were observed by Deputy Sweet, who monitored him via video but did not physically check on him until he was found unresponsive. Despite attempts at CPR, Mabee was pronounced dead from an overdose. The source of the methamphetamine was unclear, but the County theorized Mabee had concealed it prior to his confinement.The Estate of Richard Mabee sued Wheatland County for negligence, alleging the jailers failed to provide adequate medical care. The County asserted that Mabee’s own negligence contributed to his death and should diminish or bar recovery. The Fourteenth Judicial District Court, Wheatland County, allowed the County to present a comparative negligence defense and approved a special verdict form for the jury to apportion fault. The jury found both parties negligent, attributing 95% of the fault to Mabee and 5% to the County. As a result, the District Court entered judgment for the County, denying damages to the Estate.The Supreme Court of the State of Montana reviewed whether the District Court erred in permitting the comparative negligence defense. The Court held that, absent “special circumstances” where a jailer knows or should know a detainee is at risk of harm, comparative negligence applies and the factfinder may apportion fault. The Court affirmed the District Court’s judgment, concluding the Estate did not preserve any error regarding jury instructions on “special circumstances” and failed to show reversible error. View "Est. of Mabee v. Wheatland County" on Justia Law

A man was involved in a single-vehicle accident in Gallatin County, Montana, where his Jeep left the road, struck a sign, and then drove away. Witnesses reported the incident, and law enforcement traced the vehicle to the man’s residence using the license plate information. Upon arrival, officers observed damage to the Jeep and encountered the man, who exhibited signs of impairment such as bloodshot eyes and a dazed demeanor. The man admitted to purchasing and inhaling a can of Dust-Off, a product containing difluoroethane (DFE), and acknowledged that he had passed out while driving. Field sobriety tests indicated impairment, and a subsequent blood test confirmed the presence of DFE.The Gallatin County Justice Court denied the man’s motions to suppress evidence, which alleged a lack of particularized suspicion, unlawful search and seizure, and a Miranda violation. After a bench trial, the court found him guilty of misdemeanor DUI (third offense). The Eighteenth Judicial District Court, Gallatin County, affirmed the conviction and the denial of the suppression motions, concluding that law enforcement had particularized suspicion, that there was no reasonable expectation of privacy in the driveway or the exterior of the Jeep, and that no custodial interrogation requiring Miranda warnings had occurred.The Supreme Court of the State of Montana reviewed the case de novo. It held that law enforcement had particularized suspicion to investigate for DUI based on the totality of the circumstances, including the crash, the man’s behavior, and his admissions. The Court found no unlawful search or seizure, as there was no reasonable expectation of privacy in the areas searched, and the man voluntarily provided the Dust-Off can. The Court also determined that no custodial interrogation occurred before arrest, so Miranda warnings were not required. The Court declined to address an unpreserved evidentiary claim and found sufficient evidence supported the DUI conviction. The conviction was affirmed. View "State v. Ellis" on Justia Law

The State petitioned to involuntarily commit J.L.O., alleging she suffered from schizophrenia and posed a danger to herself or others. The petition relied on a report by a licensed clinical social worker (LCSW) who examined J.L.O. the day before the petition was filed. The District Court appointed a licensed professional counselor to examine J.L.O., and scheduled a hearing for January 2, 2024, within the statutory five-day window. J.L.O. was detained at the Montana State Hospital pending the hearing. The State provided J.L.O.’s counsel with the LCSW’s report only after the hearing, and it was discovered that the LCSW was not certified as a “professional person” under Montana law.J.L.O.’s counsel moved to dismiss the commitment petition, arguing that the State failed to have J.L.O. examined by a qualified professional person within the required timeframe. The State conceded the LCSW’s lack of certification but argued that J.L.O.’s request for a continuance waived the five-day hearing deadline. The Fourth Judicial District Court denied the motion to dismiss and proceeded with the commitment process, ultimately appointing a certified professional person who did not personally examine J.L.O. but relied on records and secondhand information. The District Court committed J.L.O. to the Montana State Hospital for up to ninety days and authorized involuntary medication.The Supreme Court of the State of Montana reviewed the case and held that the District Court erred by denying J.L.O.’s motion to dismiss. The Supreme Court found that the statutory requirements for involuntary commitment—including examination by a qualified professional person within the five-day hearing deadline—were not met, and that the error was not harmless. The Supreme Court reversed the District Court’s Order of Commitment. View "In re J.L.O." on Justia Law

The petitioner was charged with several felonies stemming from an incident in July 2024, including assault with a weapon, unlawful possession of a firearm by a convicted person, and tampering with evidence. He was arraigned on these charges in July 2024 and did not seek to substitute the presiding judge at that time. In June 2025, the State filed an Amended Information adding three new felony counts of criminal distribution of dangerous drugs, and the petitioner was arraigned again on these new charges. Within two days of this second arraignment, the petitioner moved to substitute the judge, arguing that the motion was timely because it was filed within ten days of the arraignment on the Amended Information.The Twentieth Judicial District Court, Lake County, denied the motion, holding it was untimely because the ten-day period for substitution under § 3-1-804(1)(b), MCA, began with the initial arraignment in July 2024, not the subsequent arraignment on the amended charges. The court reasoned that allowing substitution after any arraignment on amended charges could lead to manipulation of the process and disrupt judicial efficiency.The Supreme Court of the State of Montana reviewed the case on a petition for writ of supervisory control. The Court held that the right to substitute a judge in a criminal case under § 3-1-804(1)(b), MCA, is triggered by the initial arraignment, not by subsequent arraignments on amended informations, even if new charges are added. The Court concluded that the District Court did not err in denying the motion as untimely and denied the petition for writ of supervisory control, remanding the matter for further proceedings. View "Caye v. 20th Judicial District Court" on Justia Law

The case concerns an incident between Taylor Jean Carlson and her ex-boyfriend, Shane Dalke, following a wedding they both attended. After a series of arguments and confrontations at Dalke’s home, Carlson physically assaulted Dalke and attempted to take his phone, which he was using to record her behavior. During the struggle, the phone was dropped, and Carlson picked it up, unsuccessfully tried to access it, and then destroyed it by throwing it on the concrete multiple times, rendering it inoperable. Police were unable to recover any data from the phone due to the damage.The Eighth Judicial District Court, Cascade County, presided over Carlson’s trial. She was charged with misdemeanor Partner Family Member Assault and felony Tampering with or Fabricating Physical Evidence. At trial, Carlson’s attorney requested a jury instruction for the misdemeanor offense of Criminal Destruction of or Tampering with a Communication Device as a lesser included offense of the tampering charge. The State opposed, arguing the statutes required different elements. The District Court denied the request, reasoning that the communication device offense contained an element not present in the tampering statute, and thus was not a lesser included offense as a matter of law. Carlson was convicted of tampering with evidence.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court erred in denying the lesser included offense instruction. The Supreme Court held that Criminal Destruction of or Tampering with a Communication Device is not a lesser included offense of Tampering with or Fabricating Physical Evidence because the two statutes have distinct elements, particularly regarding intent and the nature of the conduct criminalized. The Supreme Court affirmed the District Court’s decision. View "State v. Carlson" on Justia Law

A 70-year-old woman was the subject of a state petition for involuntary civil commitment, alleging she suffered from a severe mental disorder with manic and psychotic features. Over several months, she had multiple encounters with law enforcement and was charged with various offenses, including assault and disorderly conduct. The petition included a psychiatric evaluation and described significant behavioral changes affecting her safety and relationships. At the initial hearing, the woman was represented by counsel, who stated she did not want a trial and wished to be stabilized, and the court read her rights aloud.The Eighth Judicial District Court, Cascade County, presided over the hearing. The court relied on the representations of counsel and the woman’s brief affirmations to find that she knowingly and intentionally waived her procedural rights, including the right to contest the commitment. The court then ordered her commitment to the Montana State Hospital for up to 90 days, issuing findings that largely repeated the petition’s allegations. The order stated that the woman and her counsel agreed to waive her rights, but the court did not directly question her about the waiver or develop a record of her understanding.The Supreme Court of the State of Montana reviewed the case. It held that the district court erred by failing to make an adequate inquiry or develop a sufficient record to support a finding that the woman knowingly and intentionally waived her rights, as required by Montana law. The Supreme Court emphasized that merely informing a respondent of their rights or relying on general statements from counsel is insufficient. The order of commitment was reversed, reaffirming the necessity for strict compliance with statutory and due process requirements in involuntary commitment proceedings. View "In re P.G.J." on Justia Law

The case concerns an altercation that occurred after Jeffrey Burrington, while driving with his wife, began tailgating another vehicle driven by Ryan Williams. After both vehicles stopped, a verbal confrontation ensued, during which Burrington punched Williams in the face. Williams subsequently sought medical attention and was diagnosed with a fractured mandible, which required him to maintain a liquid diet for six weeks and limited his ability to perform certain job duties as a smokejumper. Burrington was charged with Aggravated Assault, a felony, and the State also proposed a jury instruction for the lesser included offense of Assault.In the Fourth Judicial District Court for Missoula County, Burrington moved to dismiss the case, arguing that Williams did not suffer a serious bodily injury and that he acted in self-defense. The District Court denied the motion, finding these were issues for the jury. At trial, Burrington presented a dual defense: justifiable use of force and lack of serious bodily injury. The jury heard testimony from Williams, medical experts, and both Burrington and his wife regarding prior incidents that shaped their perception of threat. After the State rested, Burrington moved for a directed verdict, which the District Court denied, concluding that the evidence was sufficient for the jury to decide.The Supreme Court of the State of Montana reviewed whether the District Court erred in denying the motion for a directed verdict, whether plain error review was warranted for unobjected-to trial incidents, and whether cumulative error required a new trial. The Supreme Court held that a rational jury could find Williams’s six-week mandibular injury constituted a “protracted loss or impairment” and thus a serious bodily injury under Montana law. The Court also found no plain error or cumulative error warranting reversal. The conviction and sentence were affirmed. View "State v. Burrington" on Justia Law

This dispute arose from the use of easements on subdivided property in Yellowstone County, Montana. After a series of conveyances, Patti and Steve Schubert owned Tract 7B-2, which benefited from a 30-foot-wide access easement across neighboring Tract 7B-1, owned by Jeremy and Tynagh Toepp. The Schuberts installed a large electric gate, keypad, and package box within the easement, and engaged in activities such as removing vegetation and using heavy equipment, which the Toepps claimed damaged their property and overburdened the easement. The Schuberts also challenged the Toepps’ rights to use a shared well. The parties attempted to resolve their disputes through mediation, resulting in a signed Memorandum of Understanding (MOU), but disagreements persisted over the interpretation and scope of the settlement, particularly regarding the gate and the use of the easement.The Thirteenth Judicial District Court, Yellowstone County, heard cross-motions to enforce the MOU. Sitting without a jury, the District Court found the MOU to be a binding agreement that implied the Schuberts’ encroaching gate could remain in place. The court limited the Schuberts’ use of the access easement to ingress and egress only, prohibited unnecessary removal of vegetation, and awarded attorney fees to the Toepps, finding the Schuberts had unreasonably multiplied the proceedings by insisting on additional terms not included in the MOU.On appeal, the Supreme Court of the State of Montana reversed the District Court’s conclusion that the MOU allowed the encroaching gate to remain, holding that the MOU did not contemplate a gate easement and that the gate constituted an unlawful encroachment requiring removal. The Supreme Court affirmed the District Court’s limitation of the easement to ingress and egress and its award of attorney fees to the Toepps, finding no abuse of discretion. The case was remanded for entry of judgment consistent with these holdings. View "Schubert v. Toepp" on Justia Law

A Pennsylvania resident requested an investigation into alleged contamination of his property, which was linked to fracking operations involving EQT. An employee of Environmental Health Sciences (EHS), based in Pennsylvania, conducted research and sampling on the property, which informed a news series published by EHS. EHS is headquartered in Montana, but its journalists work remotely from various states. During litigation in Pennsylvania, EQT sought documents from EHS related to the research and reporting. The subpoena was domesticated and served on EHS in Montana.The Eighteenth Judicial District Court, Gallatin County, Montana, granted EHS’s motion to quash the subpoena, holding that Montana’s Media Confidentiality Act applied and provided absolute privilege over the requested records. The court found that the relevant communications and research occurred in Pennsylvania but concluded that Montana law should govern under the Restatement (Second) of Conflict of Laws § 139. EQT sought relief after a related Montana Supreme Court decision, but the District Court denied the motion, maintaining its original analysis.The Supreme Court of the State of Montana reviewed the case de novo, focusing on the choice-of-law issue. The court determined that an actual conflict existed between Montana’s absolute privilege and Pennsylvania’s narrower, qualified reporter’s privilege. Applying the Restatement (Second) of Conflict of Laws § 6 factors, the Montana Supreme Court held that Pennsylvania’s privilege law should apply because Pennsylvania had the most significant relationship to the communications and newsgathering at issue. The court reversed the District Court’s order and remanded for further proceedings, instructing the lower court to apply Pennsylvania’s privilege law to determine whether the subpoenaed records are protected. View "EQT CHAP v Environmental Health Sciences" on Justia Law