Justia Montana Supreme Court Opinion Summaries

In a dispute arising from a failed subdivision in Missoula County, Montana, a group of property purchasers, led by Gilbert and Judith Johnston, claimed that Flying S Title and Escrow, Inc., breached a purported contract to provide title insurance for the properties they bought. The properties were originally platted as lots, but the purchasers believed that they would eventually be reconfigured into larger parcels. However, the necessary infrastructure was not installed and the amended plat was never recorded, so the parcels never came into existence. The purchasers claimed that pro forma documents provided by Flying S constituted a contract to insure the parcels. The Supreme Court of Montana disagreed, ruling that the pro forma documents did not constitute a contract, but were merely an offer to issue a title insurance policy for the parcels, subject to the terms stated in the documents. The court noted that a contract for title insurance could not exist under the pro forma documents because the parcels, and the title thereto, never existed. Furthermore, the court found that Flying S had not been unjustly enriched by the purchasers' premium payments because it had provided, as agreed, title insurance for the transaction completed by the purchasers to buy the lots. Therefore, the court affirmed the lower court's decision in favor of Flying S Title and Escrow, Inc. View "Johnston v. Flying S Title & Escrow, Inc." on Justia Law

This case involves an appeal by the Montana Department of Environmental Quality (DEQ) and Tintina Montana Incorporated (Tintina) of a district court's order revoking a permit granted to Tintina to construct and operate the Black Butte Copper Mine. The district court revoked the permit on the grounds that the DEQ failed to adhere to two statutory schemes governing the state permitting process: Montana’s Metal Mine Reclamation Act (MMRA) and the Montana Environmental Policy Act (MEPA). The Supreme Court of Montana found that DEQ demonstrated compliance with both laws and accordingly reversed the district court's order and reinstated Tintina's permit.The Supreme Court held that DEQ satisfied MMRA and MEPA in approving Tintina’s proposed cemented tailings facility. The court concluded that DEQ had evaluated the science and made a reasoned decision, supported by substantial evidence, that the surface tailings at the Black Butte Copper Mine would be stable and non-flowable.The court also held that DEQ satisfied MEPA by rationally evaluating the environmental impact of the mine’s total nitrogen discharges into Sheep Creek. After considering relevant data, DEQ articulated a reasoned explanation for its rationale, and its determination was supported by substantial evidence and was not arbitrary, random, or seemingly unmotivated based on the existing record.Furthermore, the court held that DEQ satisfied MEPA when it considered and dismissed alternatives to the proposed action. DEQ had appropriately had its independent consultant take a deeper look when Tintina’s working group emphasized cost considerations in dismissing the depyritization alternatives. ERM identified technical feasibility issues it suggested be considered more carefully, and DEQ’s final review shows that the agency considered those challenges and decided to accept the cemented paste tailings option (with modification) as the preferred action. MTU has not demonstrated that DEQ failed its responsibility under MEPA to consider reasonable alternatives to the proposed action.The case was remanded to the district court to reinstate DEQ’s decision to grant Tintina’s permit. View "Montana Trout Unlimited v. Tintina" on Justia Law

In this case, the defendant, June Wolverine, was charged with six misdemeanor traffic violations, including a third offense of Driving Under the Influence of Alcohol (DUI). Wolverine was unable to attend her trial due to being in federal custody. The State of Montana moved to continue the trial, but did not provide information on when Wolverine would be released from federal custody. Wolverine subsequently filed a motion to dismiss the charges due to a lack of a speedy trial, as required by Montana law. The Justice Court denied Wolverine's motion, and she pleaded guilty to the DUI charge while reserving her right to appeal the speedy trial issue. The District Court affirmed the Justice Court's denial of the motion to dismiss, ruling that Wolverine's federal incarceration had a clear causal impact on the trial delay.The Supreme Court of the State of Montana reversed the decision of the District Court. The Supreme Court held that the State had failed to demonstrate good cause for the delay in Wolverine's trial. The State knew Wolverine was in federal custody and had ample time to ask for Wolverine’s temporary release for trial or to notify the Justice Court about the looming deadline for a speedy trial. Yet, the State did nothing as the deadline passed. The Supreme Court concluded that the State did not fulfill its obligation to try the defendant in a timely manner, thus violating Wolverine's right to a speedy trial. The court reversed the District Court's decision and ruled in favor of Wolverine. View "State v. Wolverine" on Justia Law

This case was a negligence action brought by Dennis Vancos against the State of Montana, Department of Transportation, for injuries he sustained when struck by a car at an intersection. Vancos alleged that the traffic control device at the intersection was inadequately designed, installed, and maintained, leading to the accident. The Supreme Court of the State of Montana addressed three issues on appeal. The first was whether the District Court made an error in handling evidence of Vancos’s consumption of alcohol. The court found that the District Court did err by allowing evidence of Vancos's alcohol consumption but refusing to take judicial notice of his blood alcohol content (BAC), which was not deemed to be in evidence. The court held that a party need not introduce evidence of a fact judicially noticed, and therefore, the District Court's interpretation of the rule was incorrect, and it abused its discretion by refusing to take judicial notice of Vancos's BAC.The second issue was whether the District Court erred by not accepting Vancos’s proposed jury instruction on pedestrian rights-of-way. The court found that the District Court did not abuse its discretion when it rejected Vancos’s proposed instruction and instead chose to instruct the jury on the entirety of the law.The third issue, which was not addressed due to the requirement for a new trial determined by the first issue, was whether the District Court erred by not striking a prospective juror for cause. Due to the error in handling evidence of Vancos's alcohol consumption, the court reversed in part, affirmed in part, and remanded the case to the District Court for a new trial. View "Vancos v. Montana Department of Transportation" on Justia Law

In this case, defendant Bradley Alan Stokes appealed his convictions from the Fourteenth Judicial District Court, Musselshell County, for both burglary and assault with a weapon. Stokes was charged with these crimes following an altercation at the home of Michael Benson, in which he used a crowbar to break into the residence and assaulted Benson with the crowbar. He was convicted of burglary and assault with a weapon, both felonies. There was agreement that Stokes could not be convicted of both charges, as the assault with a weapon charge was the predicate offense for the burglary conviction. The dispute concerned which of the convictions should be vacated and whether the case should be remanded for resentencing.The Supreme Court of the State of Montana reversed Stokes's conviction for assault with a weapon, as it was determined to be the predicate offense that merged into the principal offense of burglary. The court held that the assault with a weapon conviction should be vacated, following the precedent that when a criminal defendant is improperly convicted of two offenses arising from the same transaction, the remedy is to reverse the conviction for the lesser-included offense only and remand for resentencing. Therefore, the court remanded the case to the District Court to vacate the assault with a weapon conviction and for resentencing on the remaining burglary conviction. View "State v. Stokes" on Justia Law

Shawn Fowler, a former Montana state trooper, sued the Department of Justice, Montana Highway Patrol (MHP) alleging constructive discharge in violation of the Wrongful Discharge from Employment Act (WDEA). He also alleged breach of contract by the Montana Public Employees Association (MPEA) for declining his request to arbitrate. Fowler claimed that he was forced to retire due to a hostile work environment, which was mainly due to disciplinary action taken against him for mishandling two suspected DUI traffic stops in 2017. The MHP argued that Fowler, who was covered by a collective bargaining agreement (CBA), failed to exhaust the grievance procedures of the CBA before filing a lawsuit.The Supreme Court of the State of Montana reversed the judgment of the Sixth Judicial District Court, Park County. The Supreme Court held that an employee covered by a CBA can't bring a claim under the WDEA. The Court determined that Fowler’s alleged constructive discharge was covered by the CBA and he was required to exhaust the grievance procedures for a constructive discharge through the CBA. The Court found that Fowler did not grieve any of the events preceding his suspension, which he claimed contributed to his constructive discharge, and he resigned from employment prior to exhausting the grievance procedure of the CBA. The Court concluded that the District Court erred in denying the State’s two motions for summary judgment and reversed the judgment. View "Fowler v. Department of Justice" on Justia Law

The defendant, Jacob Palmer, was found guilty of felony Partner or Family Member Assault (PFMA) by the Eleventh Judicial District Court, Flathead County, following an incident where he attacked his girlfriend, K.Y., with whom he had been in a relationship for over a decade. During his trial, evidence was presented regarding prior altercations between Palmer and K.Y. Palmer appealed to the Supreme Court of the State of Montana, challenging the District Court's decision to admit this evidence.The issue before the Supreme Court of Montana was whether the District Court had abused its discretion by admitting evidence of Palmer's prior altercations with K.Y. in his PFMA trial. The Supreme Court held that the District Court had not abused its discretion. The court reasoned that the evidence of Palmer's previous altercations with K.Y. was relevant and admissible under Montana Rule of Evidence 404(b). The court explained that such evidence can provide context about the complex dynamics of domestic violence, including the cycle of abuse and the reasons why victims such as K.Y. might not immediately report the abuse or might be reluctant to discuss the abuse with law enforcement. The court further determined that the probative value of this evidence was not significantly outweighed by its potential prejudicial effect against Palmer. As such, the court affirmed the District Court's decision to admit the evidence and upheld Palmer's conviction. View "State v. Palmer" on Justia Law

The case involves an appellant, M.T.H., who was arrested for criminal endangerment after he pulled the steering wheel in his mother's vehicle while she was driving. M.T.H. was diagnosed with major depressive disorder and paranoid schizophrenia. Following his arrest, the State filed a petition for M.T.H.'s involuntary commitment to the Montana State Hospital (MSH) for up to three months. The District Court of the Twenty-First Judicial District, Ravalli County, ordered his commitment and authorized MSH to involuntarily administer medications to M.T.H. This led to an appeal to the Supreme Court of the State of Montana.The Supreme Court of Montana had two main issues to consider. The first issue was whether the District Court erroneously determined that a signed waiver constituted a sufficient record to commit M.T.H. The Supreme Court found that M.T.H.'s waiver and the District Court’s order committing him were sufficient to constitute an intentional and knowing waiver under the relevant statute. The court emphasized that the record reflected that M.T.H. understood his procedural rights and had a clear presence of mind to consider his position logically.The second issue was whether the District Court erroneously authorized MSH to administer involuntary medications to M.T.H. The Supreme Court held that the District Court erred in this aspect. It emphasized the importance of due process protections and noted that the State must demonstrate a need for involuntary medication before a court may authorize it. In this case, the State did not make this necessary showing. Therefore, the Supreme Court affirmed the District Court’s decision in part but reversed its decision to authorize involuntary medication for M.T.H. View "In re M.T.H." on Justia Law

The Supreme Court of the State of Montana was tasked with determining whether the Municipal Court had sufficient evidence to enter a permanent order of protection against the appellant, Alda Bighorn. Bighorn was prohibited from having contact with her grandchild, L.D.F.S, unless supervised, due to allegations made by L.D.F.S's mother, Camille Fritzler. Fritzler alleged that Bighorn had taken L.D.F.S to a family gathering while intoxicated and seeking narcotics, and was planning to enroll L.D.F.S with a Native tribe to gain custody over her. These allegations were not corroborated by any witness testimony or other evidence, but the Municipal Court granted a permanent order of protection against Bighorn. Bighorn appealed this decision, and the District Court affirmed the Municipal Court's ruling.The Supreme Court of the State of Montana reversed the lower courts' decisions, ruling that the Municipal Court had abused its discretion by granting the permanent order of protection without any substantial, credible evidence supporting Fritzler's allegations. The Supreme Court noted that hearsay allegations may be sufficient to support issuing a temporary order of protection, but not a permanent one. Furthermore, the court deemed it improper for the lower court to issue a visitation order for a grandparent in a protection order proceeding, stating that grandparent visitation should be established by filing a petition under the relevant statute. The case was remanded to the Municipal Court to vacate and rescind the permanent order of protection against Bighorn. View "Fritzler v. Bighorn" on Justia Law

Duane Burchill was convicted of two counts of robbery, one count of conspiracy to commit deceptive practices, and one count of possession of dangerous drugs in 2017. Following his conviction, Burchill filed a petition for postconviction relief, asserting that his counsel provided ineffective assistance by failing to object to the prosecutor’s misconduct during his trial. The Supreme Court of the State of Montana affirmed the denial of Burchill's petition for postconviction relief.Burchill's claim of ineffective assistance centered on two main arguments. First, he argued that the prosecutor repeatedly asked him to comment on the credibility of other witnesses by asking "were they lying" questions. Second, he alleged that the prosecutor posed questions suggesting his personal opinion that Burchill's testimony was not truthful.The court, however, found that the "were they lying" questions were not improper because they had probative value in evaluating the credibility of a defendant who is claiming that everyone else is lying. The court also disagreed that the prosecutor had expressed personal opinions on Burchill's credibility. The court concluded that the prosecutor's questions were within the scope of permissible questions allowed on cross-examination. Therefore, the court found that Burchill's counsel's failure to object did not constitute ineffective assistance.The court did not find it necessary to address Burchill's claim of prejudice due to the failure of his counsel to object, as it had already determined that his counsel's performance was not deficient. Thus, Burchill's petition for postconviction relief was denied. View "Burchill v. State" on Justia Law