Justia Montana Supreme Court Opinion Summaries

A property management company operating several apartment buildings in Missoula County contracted with a waste management provider for “three-yard” dumpster service. After the expiration of their initial service agreement, the provider continued to supply waste removal services on an invoice-by-invoice basis. The property management company later discovered that many of the dumpsters labeled as “three-yard” actually had a capacity of less than three cubic yards, with one model measuring approximately 2.52 cubic yards. The waste management provider rotated these containers among customers and did not maintain records of which customers received which models. The property management company alleged that it was charged overage fees for exceeding the stated capacity of these undersized containers.The property management company filed suit in the Fourth Judicial District Court, Missoula County, asserting claims for breach of contract and negligent misrepresentation, and sought to represent a class of similarly situated customers. The District Court bifurcated discovery and, after briefing and oral argument, certified two classes: one for breach of contract and one for negligent misrepresentation, both defined as customers who paid for “three-yard” service but received dumpsters of 2.6 cubic yards or less. The District Court found that common questions predominated over individual issues and that class litigation was superior to individual actions.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in finding predominance of common questions and whether it erred by not considering the ascertainability of class members. The Supreme Court held that the District Court did not abuse its discretion in certifying the classes, as common questions regarding the provider’s contractual and legal obligations predominated, and individualized damages did not preclude certification. The Court also held that ascertainability is not a mandatory requirement under Montana’s class action rule. The District Court’s order granting class certification was affirmed. View "Allied Waste v. LH Residential" on Justia Law

Cissy Deen Manyhides was placed on probation after pleading guilty to Endangering the Welfare of a Child. As a condition of her probation, she agreed to make her residence open and available to probation officers for home visits or searches upon reasonable suspicion, and to refrain from possessing illegal drugs. In February 2022, probation officers conducted a home visit at her apartment. During a walkthrough for safety and compliance, one officer observed drug paraphernalia in plain view in her bedroom. This led to a further search of her belongings, revealing additional contraband and suspected methamphetamine. Manyhides was subsequently charged with drug possession and possession of drug paraphernalia.The Eighth Judicial District Court of Montana reviewed Manyhides’s motion to suppress the evidence, arguing that the officers’ actions constituted an unlawful search. The District Court denied the motion, finding that the officers’ conduct during the home visit did not amount to a search under the law. Manyhides then pleaded guilty to felony drug possession while reserving her right to appeal the suppression ruling.The Supreme Court of the State of Montana reviewed the District Court’s decision. The Supreme Court held that a standard probation home visit, conducted pursuant to explicit probation conditions, does not constitute a search requiring reasonable cause. The Court found that Manyhides had no reasonable expectation of privacy precluding such visits, as she had agreed to the conditions of her probation. The officers’ actions remained within the permissible scope of a home visit until contraband was observed in plain view, at which point reasonable cause existed for a further search. The Supreme Court affirmed the District Court’s denial of the motion to suppress. View "State v. Manyhides" on Justia Law

In May 2022, Garry Douglas Seaman shot and killed James Preston Freeman and seriously wounded Heidi Gabert, following the end of his romantic relationship with Gabert, with whom he shares a minor child. Seaman was criminally charged, and Gabert and Dawn Freeman, James’s spouse, filed a civil suit for damages. To prevent Seaman from transferring or selling assets during the litigation, Gabert and Freeman successfully sought a receivership over all of Seaman’s property. After negotiations, the parties reached a settlement memorialized in a memorandum of understanding (MOU), which included $10 million judgments for Gabert and Freeman, liquidation of Seaman’s assets, and a homestead exemption for Seaman.The Nineteenth Judicial District Court, Lincoln County, approved the creation of a designated settlement fund (DSF) to facilitate asset liquidation. Initially, the court’s DSF Order required the Liquidation Receiver to reserve funds from asset sales to pay Seaman’s capital gains taxes, interpreting the MOU’s tax payment provision as unambiguous. Gabert and Freeman moved to amend this order under Montana Rule of Civil Procedure 59(e), arguing the court erred in its interpretation and that the parties did not intend to reserve funds for Seaman’s capital gains taxes. After an evidentiary hearing, the District Court agreed, finding the MOU ambiguous and, based on extrinsic evidence, concluded the parties did not intend to reserve such funds. The court amended its order, striking the provision requiring reservation for capital gains taxes.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in amending the DSF Order. The Supreme Court held that the District Court did not abuse its discretion, correctly found the MOU ambiguous, and its factual finding regarding the parties’ intent was not clearly erroneous. The Supreme Court affirmed the District Court’s amended order. View "Gabert v. Seaman" on Justia Law

A woman was stopped by a sheriff’s deputy in Ravalli County, Montana, for driving a vehicle with expired registration. The stop followed a call from a citizen informant reporting unusual activity at a residence known for prior drug activity, and an off-duty trooper’s observation of the woman leaving that residence in the vehicle. During the stop, the deputy questioned the woman about her activities and associations with the residence, and she provided explanations consistent with her presence there for lawful reasons. The deputy, suspecting drug activity, ultimately seized the vehicle and the woman’s purse, later obtaining a search warrant that led to the discovery of methamphetamine and drug paraphernalia in the purse.The Twenty-First Judicial District Court, Ravalli County, denied the woman’s motion to suppress the evidence found in her purse. The court held that the deputy had particularized suspicion to extend the traffic stop beyond the registration issue to investigate possible drug activity, and that there was probable cause to seize the vehicle and its contents, including the purse. The court also found that the search warrant was supported by probable cause and that the woman had not shown any false statements in the warrant application.On appeal, the Supreme Court of the State of Montana reviewed whether the district court properly denied the motion to suppress. The Supreme Court held that while the deputy had particularized suspicion to extend the stop and inquire about drug activity, the suspicion was dispelled by the woman’s answers and did not ripen into probable cause to seize the vehicle or the purse. The Court found the district court’s findings regarding the woman’s demeanor and the basis for probable cause to be clearly erroneous. The Supreme Court reversed the district court’s denial of the motion to suppress. View "State v. Carter-Brueggeman" on Justia Law

After the death of the previous sheriff, the County Commissioners of Big Horn County appointed Jeramie Middlestead as interim sheriff in November 2023. Middlestead subsequently ran for election to retain the position. Lee A. Bartel filed a complaint in June 2024, alleging that Middlestead was ineligible to serve as sheriff because he was not a resident of, nor registered to vote in, Big Horn County, as required by Montana law. Bartel sought to prevent Middlestead from being sworn in, arguing that his appointment and potential election violated statutory requirements. Despite these allegations, Middlestead won the November 2024 election and was sworn in as sheriff in December 2024.The Twenty-Second Judicial District Court, Big Horn County, presided over by Judge Olivia Rieger after Judge Matthew J. Wald recused himself, considered Bartel’s motion for a preliminary injunction to prevent Middlestead from assuming office. The District Court denied the motion in February 2025, finding that while there were unresolved questions about Middlestead’s qualifications, Bartel had not demonstrated irreparable harm, the equities weighed against granting the injunction since Middlestead had already been sworn in, and that removing the sheriff would not serve the public interest. The court also determined that the statutory standards for granting a preliminary injunction had not been met.The Supreme Court of the State of Montana reviewed the case. It held that the matter was not moot because the District Court retained the authority to provide effective relief, including potentially ordering Middlestead’s removal if he was found ineligible. The Supreme Court further held that the District Court did not abuse its discretion in denying the preliminary injunction, affirming the lower court’s order and remanding the case for further proceedings. View "Bartel v. Middlestead" on Justia Law

Molly and Mark Johnson were involved in a motor vehicle accident for which they were insured by State Farm. State Farm paid for most of their property losses, except for certain items. After making these payments, State Farm asserted its subrogation rights and was reimbursed by the at-fault driver’s insurer, GEICO. The Johnsons later settled with the at-fault driver and GEICO for the remaining property damage not covered by State Farm, but had to pay attorney fees from this recovery. The Johnsons then sued State Farm, alleging that State Farm’s subrogation violated the made whole doctrine by collecting from GEICO before the Johnsons were fully compensated, including attorney fees, and also brought a claim for conversion.The United States District Court for the District of Montana initially remanded the case to state court for lack of standing, finding the Johnsons had not shown a substantial risk of injury. In the Montana Eleventh Judicial District Court, the Johnsons’ amended complaints were dismissed for lack of standing, as the court found they had not sufficiently alleged that State Farm’s subrogation prevented them from being made whole. The court also dismissed the conversion claim, finding it preempted by statute and lacking standing. The Johnsons’ attempt to further amend their complaint was denied, and their petition for supervisory control to the Montana Supreme Court was also denied.The Supreme Court of the State of Montana reviewed the case and affirmed the district court’s dismissal. The Court clarified that the made whole doctrine requires an insured to be fully compensated, including attorney fees, before an insurer may subrogate. However, it held that because the Johnsons’ remaining losses were not covered by their State Farm policy, State Farm’s subrogation did not violate the made whole doctrine. The Court also affirmed dismissal of the conversion claim, as the Johnsons lacked standing. View "Johnson v. State Farm Insurance" on Justia Law

The defendant was charged with multiple felony and misdemeanor violations for repeatedly contacting his estranged wife in violation of a temporary order of protection issued in May 2022. After the order was dismissed due to the protected party’s absence at a hearing, the defendant continued his prohibited communications, including sending over 100 text messages in a short period. He was arrested and later entered into a plea agreement, acknowledging the State’s intent to seek Persistent Felony Offender (PFO) status but securing a promise that the State would not pursue the PFO designation if he complied with certain conditions, including not committing further offenses or violating bail.The Eighth Judicial District Court, Cascade County, presided over the case. After the defendant pled guilty, he was released on his own recognizance. However, prior to sentencing, the State alleged that the defendant violated release conditions by continuing to contact the protected party. The State then sought to pursue the PFO designation, arguing that the defendant’s breach of the plea agreement allowed it to deviate from its original sentencing recommendation. The District Court continued the sentencing hearing to allow briefing and argument on whether the State’s PFO notice was timely and whether the defendant had breached the agreement. The District Court found that the State’s notice, although sent two minutes after the deadline, was sufficient and that the defendant suffered no prejudice from the timing.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in accepting the State’s PFO notice and imposing a PFO sentence, and whether plain error review should be conducted regarding the court’s omnibus hearing procedure. The Supreme Court held that the State’s PFO notice was compliant and timely for statutory purposes, and that the defendant was not prejudiced by the minor delay. The Court also declined to exercise plain error review over the omnibus hearing procedure. The judgment of the District Court was affirmed. View "State v. Anderson" on Justia Law

Erin Holcomb was convicted of deliberate homicide following an incident at a friend’s house near Fairfield, Montana. On the night in question, Holcomb and two friends arrived at the home after drinking and shooting guns earlier in the day. Holcomb brought a handgun into the house and was seen handling it repeatedly. After a dispute over driving due to intoxication, Holcomb refused to leave the driver’s seat of a truck, leading to a heated argument with the host, Trysten Fellers. Later, Fellers called his father for help, and after further attempts to get the guests home, Fellers drove his farm truck out to where Holcomb was in a field. Fellers stopped the truck, illuminating Holcomb, and a gunshot was heard. Fellers was found with a fatal gunshot wound, and Holcomb was arrested the next morning.The State of Montana charged Holcomb with deliberate homicide in the Ninth Judicial District Court. At trial, Holcomb’s defense requested a jury instruction on justifiable use of force, arguing that evidence showed Holcomb feared imminent harm from Fellers, who allegedly assaulted and pursued him. The District Court denied this request, finding insufficient evidence that Holcomb was in imminent danger of death or serious bodily injury. After a five-day trial, the jury found Holcomb guilty.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court abused its discretion in refusing the justifiable use of force instruction. The Supreme Court held that the trial record did not support the instruction, as there was no evidence that Fellers physically assaulted Holcomb, drove threateningly, or fired a weapon at him. The Court concluded that Holcomb’s fear was not reasonable or supported by the evidence, and affirmed the conviction. View "State v. Holcomb" on Justia Law

A Connecticut resident was injured while participating in a guided horseback ride at a luxury guest ranch in Montana. Prior to the ride, he and his wife signed an agreement acknowledging the inherent risks of equine activities, including the possibility of serious injury or death. During the ride, the plaintiff’s horse stumbled, causing him to fall forward and sustain significant injuries that required surgery. The plaintiff alleged that the ranch’s employee failed to properly address concerns about his saddle and the horse’s behavior, and that the guide’s choices regarding the trail and riding formation contributed to the accident.The plaintiff filed suit in the Montana Fourth Judicial District Court, asserting claims of negligence, premises liability, negligence per se, and negligent infliction of emotional distress. The defendant moved for summary judgment, arguing that the Montana Equine Activities Act shielded it from liability because the plaintiff’s injuries arose from risks inherent in horseback riding. The District Court agreed, finding that the plaintiff’s evidence did not raise a genuine issue of material fact and that the incident fell within the scope of inherent risks as defined by the statute. The court granted summary judgment in favor of the defendant.On appeal, the Supreme Court of the State of Montana reviewed the District Court’s decision de novo. The Supreme Court held that the plaintiff’s injuries resulted from inherent risks of horseback riding as contemplated by the Montana Equine Activities Act. The Court found no evidence that the ranch’s conduct introduced atypical or uncharacteristic risks or that the guide acted with willful or wanton disregard for the plaintiff’s safety. Accordingly, the Supreme Court affirmed the District Court’s grant of summary judgment to the defendant. View "Girasole v. Paws Up" on Justia Law

The case concerns a defendant who was charged with felony distribution of dangerous drugs in Montana, based on alleged conduct between July 2017 and February 2018. During pretrial proceedings, the State redacted portions of discovery materials, including a police report and a witness interview transcript, to exclude information not related to the defendant or not considered impeachment evidence. The witness in question, Ferguson, was facing federal charges and ultimately testified at trial that she had supplied the defendant with methamphetamine but denied receiving any promises or benefits for her testimony, aside from immunity from state charges.At trial in the Eighth Judicial District Court, several witnesses testified to the defendant’s involvement in drug transactions. Ferguson’s testimony was corroborative but not the sole evidence against the defendant. After the defendant’s conviction, a federal prosecutor filed a motion to reduce Ferguson’s sentence, citing her assistance in the defendant’s case. The defendant’s counsel was unaware of this at the time of trial and sentencing. The defendant later filed a petition for postconviction relief, arguing that the State violated its obligations under Brady v. Maryland by failing to disclose potential benefits to Ferguson and under Napue v. Illinois by not correcting her allegedly false testimony regarding those benefits. The District Court denied the petition, finding no evidence of a pretrial agreement or expectation of benefit that could be imputed to the State, and concluded that any non-disclosure was not material to the outcome.The Supreme Court of the State of Montana affirmed the District Court’s denial of postconviction relief. The Court held that, while evidence of a witness’s expectation of a benefit may be subject to disclosure, the record did not establish that such an expectation existed or that it could be imputed to the State prosecutor. Furthermore, the Court found that any non-disclosure was not material, as other substantial evidence supported the conviction. The Court also rejected the Napue claim, finding no basis to conclude the State knowingly allowed false testimony. View "Temple v. State" on Justia Law