Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Petitioner's petition for postconviction relief, holding that the district court correctly denied the postconviction relief petition.After a jury trial, Petitioner was found guilty of theft by common scheme for embezzling a sizable amount of money from a youth softball organization. The Supreme Court affirmed. Petitioner later brought this postconviction petition alleging, among other claims, ineffective assistance of his trial counsel. The district court denied the petition. The Supreme Court affirmed, holding that the district court did not err in concluding that Petitioner failed to demonstrate deficiency in his appellate counsel's representation and that his remaining complaints were unsuitable grounds for postconviction relief. View "Crabtree v. State" on Justia Law

The Supreme Court affirmed the order of the district court denying Appellants' motion for partial summary judgment and dismissing their inverse condemnation claim against the City of Billings, holding that the district court did not err.Appellants, who owned and resided in a home within the City limits, brought this action seeking to recover damages when 1,000 gallons of raw sewage backed up into their basement. The district court dismissed Appellants' sole claim of inverse condemnation because they did not establish that their damage was caused by the deliberate actions of the City. The Supreme Court affirmed, holding that Appellants failed to establish that the sewer backup was a constitutional damages of their basement for public use, and thus, a condemnation. View "Wittman v. City of Billings" on Justia Law

The Supreme Court affirmed Defendant's conviction of five felony sexual offenses against his former stepdaughter and one count of sexual intercourse without consent against his former wife, B.J., holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) the district court's denial of Defendant's motion to remove a prospective juror for cause was not a structural error requiring reversal of Defendant's convictions or a new trial; (2) the district court did not err by giving a conduct-based jury instruction defining mental state for the offense against B.J. rather than a results-based definition; and (3) this Court declines to exercise plain error review of an incorrect jury instruction on the definition of consent offered by Defendant. View "State v. Deveraux" on Justia Law

The Supreme Court reversed the order of the district court denying Defendant's motion to suppress and remanded this case to the district court to vacate Defendant's conviction of criminal possession of dangerous drugs and use or possession of property subject to criminal forfeiture, holding the district court erred in denying Defendant's motion to suppress.In his motion to suppress, Defendant claimed that law enforcement exceeded the scope of a lawful traffic stop by asking Defendant for his license and then questioning him behind the vehicle after learning that the license was valid. The district court denied the motion, concluding that the officer lawfully escalated his investigation from a traffic stop to an investigation of other criminal activity. The Supreme Court reversed, holding that the officer did not possess the requisite particularized suspicion to expand the scope of the traffic stop into a criminal investigation. View "State v. Carrywater" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment to the Department of Environmental Quality (DEQ) and dismissing a complaint alleging that DEQ violated the Montana Environmental Policy Act (MEPA), holding that DEQ was entitled to summary judgment as a matter of law.Montana Rivers, the Gallatin Wildlife Association, and Cottonwood Environmental Law Center (collectively, Plaintiffs) brought this lawsuit alleging that DEQ violated MEPA by failing to supplement a 2007 environmental impact statement (EIS) that DEQ had prepared for a proposed rulemaking by the Board of Environmental Review (Board). In 2013, the Board declined to proceed with that rulemaking by ending its notice and comment period and letting the process expire. The district court ruled that Plaintiffs had no viable MEPA cause of action because there was no longer any contemplated state action for which to supplement the EIS. The Supreme Court affirmed, holding that the district court did not err in concluding that there was no proposed state action pending that would obligate DEQ to prepare or supplement a MEPA analysis. View "Montana Rivers v. Montana Dep't of Environmental Quality" on Justia Law

In this case arising from House Bill 102 (HB 102), the Supreme Court held that the Montana Board of Regents of Higher Education (Board) has the sole authority under the Montana Constitution to set policy regarding the possession of firearms on the Montana University System property.In 2021, the legislature enacted HB 102, which generally revised gun laws with respect to open and concealed carry of firearms. HB 102 also nullified a Board policy that limited the use of and access to firearms on campuses of the Montana University System (MUS). The district court concluded that HB 102 was unconstitutional as applied to the Board because it violated the Board's constitutional authority to regulate MUS campuses. The Supreme Court affirmed, holding (1) campus safety and security is an integral responsibility of the Board's constitutional authority; (2) the regulation of firearms on MUS campuses falls squarely within this authority; and (3) as applied to the Board, certain sections of HB 102 unconstitutionally infringe upon the Board's constitutionally-derived authority. View "Board of Regents of Higher Education v. State" on Justia Law

The Supreme Court affirmed the judgment and sentence of the district court in this criminal case, holding that the district court adequately considered evidence of Defendant's post-offense rehabilitation under Miller v. Alabama, 567 U.S. 460 (2012), and imposed a constitutional sentence by striking a parole restriction.When he was seventeen years old, Defendant was charged with burglary and three counts of deliberate homicide. Defendant was convicted of all counts and sentenced to three consecutive life sentences without parole. Defendant later filed a successful postconviction petition seeking resentencing under Miller. After a resentencing hearing, the district court sentenced Defendant to three consecutive life terms at MSP without the possibility of parole. The Supreme Court remanded the case. On remand, the district court resentenced him to three life sentences and did not restrict Defendant's eligibility for parole. The Supreme Court affirmed, holding that the district court complied with the Court's instructions on remand in Keefe II and imposed a legal sentence. View "Keefe v. State" on Justia Law

The Supreme Court affirmed the order of the water court denying Robert and Carol Hurds' motion to amend the water right for a groundwater well on the grounds that the untimeliness of the motion meant the water court lacked jurisdiction to adjudicate the requested modification, holding that there was no error.In 2017, the Montana legislature established a June 30, 2019 deadline for exempt water rights holders to file a statement of claim. The deadline passed without the Hurds filing a statement of claim for their exempt water right. In 2021, the Hurds filed a motion to amend a statement of claim under Mont. Code Ann. 85-2-233(6). The water court concluded that it had no jurisdiction to modify a statement of claim for the Hurds because they hadn't properly filed a claim to amend. The Supreme Court affirmed, holding that the water court correctly denied the Hurds' motion for lack of jurisdiction. View "In re Hurd" on Justia Law

The Supreme Court affirmed the order of the district court granting a motion to approve a settlement agreement reached in mediation involving siblings Lily Smith and Sam, Dan, and Vernon Lindemulder, holding that Petitioners were not entitled to relief on their claims of error.The agreement at issue resolved claims involving the Alice M. Lindemulder Trust, established by the parties' mother, which held more than 2,000 acres of land in Stillwater County. Sam appealed the district court's decision to approve the settlement agreement, arguing that the agreement was unenforceable because he lacked the capacity to enter it and had been subjected to undue influence. The Supreme Court affirmed, holding that the district court (1) did not err in concluding that Sam validly consented to the agreement; and (2) did not err in holding that the agreement was valid and enforceable. View "Smith v. Lindemulder" on Justia Law

The Supreme Court affirmed the judgment and commitment issued by the district court following Defendant's convictions for two counts of deliberate homicide and one count of tampering with or fabricating physical evidence, holding that there was no error.On appeal, Defendant argued that the district court erred in admitting any and all text messages at trial and by not giving Defendant's proposed instruction regarding reasonable doubt. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by admitting testimony regarding certain text messages at trial; and (2) did not abuse its discretion by declining to give Defendant's proposed jury instruction regarding reasonable doubt. View "State v. Wienke" on Justia Law