Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the oral disposition and accompanying order issued by the Youth Court, which committed V.K.B. to the custody of the Montana Department of Corrections (DOC) for placement at the Pine Hills Youth Correctional Facility following his adjudication as a delinquent youth, holding that the district court exceeded its statutory authority and abused its discretion.V.K.B. was fifteen year old when he accidentally shot and killed another boy. The State filed a delinquent youth petitions alleging that V.K.B. was a delinquent youth. The Youth Court adjudicated V.K.B. a delinquent youth and ordered him to be placed at Pine Hills. The Supreme Court reversed, holding that the district court exceeded it statutory authority and abused it discretion by committing V.K.B. to the DOC for placement at Pine Hills without making the required findings under Mont. Code Ann. 41-5-1513(1)(e) that V.K.B. was a serious juvenile offender and that such a commitment was necessary for the protection of the public. View "In re V.K.B." on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing for failure to state a claim Plaintiff's complaint against the Secretary of State and the Gallatin County Election Administrator alleging that they violated Montana election laws and the Uniform Electronic Transactions Act, holding that the district court did not err.Plaintiff, who sought to run as an Independent candidate for Montana Attorney General in the 2020 general election, brought the complaint alleging that Defendants violated Montana election laws and the Uniform Electronic Transactions Act when they rejected his petition for nomination forms because they contained only electronic signatures. The district court dismissed the complaint for failure to state a claim. The Supreme Court affirmed, holding that Plaintiff failed to state a claim that would entitle him to relief. View "Meyer v. Jacobsen" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of assault with a weapon, a felony, and misdemeanor possession of marijuana and drug paraphernalia and sentencing him to a nine-year prison term, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the State's peremptory strike of the only non-white member of the jury venire was not plain error under the three-prong equal protection analysis set forth by Batson v. Kentucky, 476 U.S. 79 (1986); (2) Defendant failed to establish plain error as to his arguments regarding various unpreserved assertions of error regarding the prosecutor’s closing argument and rebuttal comments; and (3) defense counsel's withdrawal of the Batson challenge and failure to object to certain statements by the prosecutor did not constitute ineffective assistance of counsel. View "State v. Miller" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court which partially affirmed and partially reversed two earlier orders on reconsideration issued by the Montana Public Service Commission, holding that the district court erred in affirming the Commission's orders as related to interconnection costs associated with a certain transmission line.Specifically, the Supreme Court held that the district court (1) erred in upholding the Commission's determination assigning $267 million in network upgrade costs to Appellants; (2) correctly upheld the Commission's decision to calculate avoided energy costs using a proxy model; (3) properly upheld the Commission's decision to calculate ancillary service deductions based on NorthWestern Energy Corporation's proposed rates; and (4) properly upheld the Commission's determination that fifteen-year contract lengths were appropriate for all three of Appellant's projects. View "CED Wheatland Wind, LLC v. Montana Department of Public Service Regulation" on Justia Law

The Supreme Court affirmed the judgment of the district court determining that Defendant's two North Dakota convictions were sufficiently similar to constitute prior convictions under Mont. Code Ann. 61-8-734(1)(a).The State charged Defendant with driving under the influence of alcohol (DUI), fourth or subsequent offense. On appeal, Defendant challenged the denial of his motion to dismiss, arguing that his prior convictions in North Dakota and Wyoming could not serve as predicate offenses for the enhancement of his DUI charge because the statutes of the two states were dissimilar to Montana's statute. The Supreme Court affirmed, holding that the district court did not err when it held that North Carolina's DUI statute was a similar statute under section 61-8-734(1)(a). View "State v. Pankhurst" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing the final count of Plaintiff's complaint after granting summary judgment in favor of Plaintiff's declaratory judgment and issuing a permanent injunction against Defendants, holding that there was no error or abuse of discretion.Plaintiff filed a complaint seeking a declaration that Defendants had materially breached an agreement regarding a shared water well and requesting injunctive relief barring Defendants from interfering with Plaintiff's use of the well. The district court granted a permanent injunction and declaratory relief and then dismissed Plaintiff's breach of contract claim. The Supreme Court affirmed, holding that the district court (1) properly granted summary judgment to Plaintiff based on the language the agreement limiting water usage; (2) did not abuse its discretion in granting injunctive relief; and (3) did not abuse its discretion in denying Defendants' motion for leave to amend. View "Estate of Mandich v. French" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment on a quiet title action and related counterclaims to Plaintiffs, holding that there was no error.In this case concerning an approximately thirty-acre property Plaintiffs brought a quiet title action against Defendants. Defendants asserted a counterclaim against Plaintiffs for constructive fraud. The district court granted summary judgment in favor of Plaintiffs. The Supreme Court affirmed, holding that the district court (1) did not err in finding that Plaintiffs gained ownership of the disputed property through adverse possession; and (2) did not err in granting summary judgment to Plaintiffs on Defendants' fraud claim. View "Hart v. Hale" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court, holding that the proceedings must be remanded for Defendant to receive credit for time served.Defendant was convicted and sentenced for criminal endangerment and was sentenced to a five-year suspended sentence. After Defendant committed several probation violations, the district court revoked his suspended sentence and imposed a new sentence. The order denied Defendant's request that he be credited for a sixty-day period that he served as a sanction at the Sanction, Treatment, Assessment, Revocation, and Transition (START) facility. The Supreme Court held (1) Defendant's first argument was not preserved for appeal; and (2) Defendant was entitled to credit for time served at the START facility. View "State v. Tippets" on Justia Law

In this real property dispute, the Supreme Court affirmed the judgment of the district court awarding a total of $360,000 to Corey Rubin and Don Hauth in the lower court proceedings against Brent and Grace Hughes, holding that the district court did not err or abuse its discretion.Rubin and Health filed a complaint against the Hugheses seeking a declaratory judgment as to their respective easements, a temporary restraining order, and injunction, and alleging that the Hugheses' behavior constituted a nuisance, interfered with the use of their easements, and caused them mental distress. The district court entered judgment against the Hugheses. The Supreme Court affirmed, holding that the district court (1) properly denied the Hugheses' motion for a directed verdict; (2) did not err in determining that the Hugheses did not have an easement that entitled them to specific performance; (3) did not err in waiving the statutory cap on punitive damages; and (4) did not abuse its discretion in excluding evidence of Rubin's unenforceable agreement to grant the Hugheses an easement. View "Rubin v. Hughes" on Justia Law

The Supreme Court affirmed the decree of guardianship by the district court granting guardianship of Mother's son to his maternal grandparents, holding that the district court did not err in finding that continued efforts to reunify Mother and child would likely be unproductive.After a hearing, the district court granted the Department of Public Health and Human Services' petition for guardianship of six-year-old S.S. On appeal, Mother argued that the district court erred in finding that continued efforts to reunify Mother and S.S. would likely be unproductive. The Supreme Court affirmed, holding that the record contained substantial evidence to support the district court's finding that additional reunification efforts would not be productive. View "In re S.S." on Justia Law