Justia Montana Supreme Court Opinion Summaries

The Supreme Court answered in the affirmative a certified question issued by the United States Court of Appeals for the Ninth Circuit in this insurance dispute.At issue was Mont. Code Ann. 33-15-334(2), which provides that Mont. Code Ann. 33-15-337(2) is "not intended to increase the risk assumed under policies subject to" its requirements. Specifically in question was whether, when an insurance policy does not adhere to the technical requirements of Mont. Code Ann. 33-15-337(2), the insurer may nonetheless rely on unambiguous exclusions or limitations to the policy's coverage. The Supreme Court answered the question in the affirmative, concluding that, notwithstanding a failure to follow the provisions of section 33-15-337(2), an insurer may rely on unambiguous exclusions or limitations to the policy's coverage when invalidating such a provision would result in an increase of the risk assumed. View "High Country Paving, Inc. v. United Fire & Casualty Co." on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence obtained from a blood draw conducted pursuant to a search warrant, holding that there was no error.Defendant moved to suppress evidence obtained from a blood draw, arguing that Wheatland County Justice of the Peace Richard Egabakken lacked jurisdiction to issue the warrant because the crimes occurred in Golden Valley County. The district court denied the motion to suppress. The Supreme Court affirmed, holding that the district court did not err when it concluded that Justice of the Peace Egebakken had jurisdiction to issue a search warrant for Defendant's blood draw in Wheatland County. View "State v. Grussing" on Justia Law

The Supreme Court reversed the order of the district court affirming the municipal court's denial of Defendant's motion to dismiss the charge of obstructing a peace officer for insufficient evidence, holding that the district court erred.Defendant was charged with obstructing a peace officer by attempting to walk away from officers while being questioned. Defendant moved to dismiss the charge for insufficient evidence, arguing that she could not knowingly obstruct the officer's enforcement of the law where the officer failed to inform her that she was being detained or otherwise required to remain on scene to answer questions. The municipal court denied the motion, and the district court affirmed. The Supreme Court reversed, holding that there was insufficient evidence to sustain the obstruction charge. View "State v. Bennett" on Justia Law

The Supreme Court affirmed the judgment of the district court committing Appellant to the Montana State Hospital (MSH) to regain fitness after a psychologist determined Appellant was not fit to stand trial on pending criminal charges, holding that the district court correctly denied Appellant's motion to dismiss.Appellant pleaded guilty to drug-related charges. Before sentencing, the district court ordered that Appellant be committed to MSH to regain fitness. Appellant's counsel later filed a motion to dismiss, arguing that both charges should be dismissed pursuant to Mont. Code Ann. 46-14-221(3)(a). The district court denied the motion to dismiss and later found Appellant fit to proceed. Appellant subsequently pleaded guilty through an Alford plea. The Supreme Court affirmed Appellant's conviction but remanded the case for the district court to conform its written judgment to the oral pronouncement of Appellant's sentence, holding that Appellant did not demonstrate that she was entitled to have the charges against her dismissed. View "State v. Rich" on Justia Law

The Supreme Court affirmed the order of the district court denying Appellant's motion for summary judgment and granting summary judgment in favor of United Services Automobile Association (USAA) in this insurance dispute, holding that the district court did not err.Appellants filed a complaint alleging that USAA violated its duty to defend Shawn Conrad, one of USAA's insured policy-holders against whom Appellants had obtained a judgment. The district court granted summary judgment for USAA, concluding that USAA had no duty to defend Conrad because his conduct against Appellants did not fall within the scope of the policy's coverage. The Supreme Court affirmed, holding (1) Appellants' claims against Conrad were beyond the scope of coverage in USAA's policy; and (2) therefore, USAA did not have a duty to defend Conrad. View "R.S. v. United Services Automobile Ass'n" on Justia Law

The Supreme Court affirmed the order entered by the district court granting Big Foot Dumpsters & Containers, LLC's motion to dismiss this action as moot following Big Foot's withdrawal of its application for a garbage hauling certificate from the Montana Public Service Commission (PSC), holding that there was no error.Big Foot filed an application for a Class D carrier certificate of public convenience or necessity to haul garbage in Flathead County. Ultimately, Big Foot requested an order allowing the withdrawal of its application and sought dismissal of the action. The district court granted dismissal. The Supreme Court affirmed, holding (1) the district court did not err by concluding that the case was mooted; and (2) the district court did not err by failing to apply any exception to the mootness doctrine. View "In re Class D Application of Big Foot" on Justia Law

The Supreme Court reversed the order of the district court affirming the justice court's denial of Defendant's motion to suppress, holding that particularized suspicion did not exist to support extending Defendant's traffic stop into a drug investigation.Defendant pleaded guilty to criminal possession of drug paraphernalia and criminal possession of marijuana. On appeal, Defendant challenged the denial of his motion to suppress the State's evidence as the product of an illegal extension of the stop, arguing that the police officer lacked particularized suspicion to justify extending the traffic stop and ordering a canine sniff search. The Supreme Court agreed and reversed, holding that the justice court erred in denying Defendant's motion to suppress. View "State v. Harning" on Justia Law

The Supreme Court affirmed the order of the district court dismissing Appellant's complaint against eighteen defendants relating to the installation of heating, ventilation, and air conditioning (HVAC) units at a property owned by Yellowstone Lodging, LLC, holding that Appellant did not meet the constitutional or prudential requirements of standing.Yellowstone, which owned and operated a hotel in West Yellowstone, hired and entered into contracts with several HVAC contractors to upgrade the HVAC system at the motel. Appellant, the sole member of Yellowstone, brought this complaint alleging thirty-nine claims related to the HVAC system, as well as claims of legal malpractice against the law firm and attorney Appellant originally engaged to pursue these claims on behalf of Yellowstone. The district court concluded that Appellant lacked standing to sue. The Supreme Court affirmed, holding that Appellant may not, through an assignment, bring Yellowstone's claims on his own behalf and without counsel. View "Sagorin v. Sunrise Heating & Cooling, LLC" on Justia Law

The Supreme Court affirmed the judgment of the district court in this litigation related to the expansion of an agricultural zoning district through citizen initiative to include the area where Montana Artesian Water Company had been developing a large-scale water bottling plant, holding that there was no error or abuse of discretion.At issue on appeal was whether Montana Artesian's water bottling facility was a valid nonconforming use under the Egan Slough Zoning District Regulations. Montana Artesian raised numerous issues on cross appeal. The Supreme Court affirmed, holding that the district court (1) properly denied Montana Artesian's motion for summary judgment on the validity of the ballot initiative process; (2) did not err in affirming the conclusion that Montana Artesian's facility was a legal nonconforming use; and (3) did not err in concluding that the initiative was not unconstitutional or illegal reverse spot zoning. View "Egan Slough Community, Yes! v. Flathead County Board of County Commissioners" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the district court in this case, holding that the district court applied an overly narrow legal standard in denying a motion to vacate or modify an arbitration award but did not err in refusing to grant attorney fees.Sutey Oil Company brought a complaint against Monroe's High County Travel Plaza and Marvin Monroe (collectively, Monroe), and the parties stipulated to arbitration. After a hearing, the arbitrator entered judgment for Sutey and awarded $220,750. Monroe moved to either modify or vacate the arbitration award. The district court denied the motion and refused to grant Sutey's request for attorney fees and costs. The Supreme Court reversed in part, holding (1) remand was required for clarification of the amount of the award pursuant to Mont. Code Ann. 25-5-217; and (2) the district court did not err in denying Sutey's motion for an award of attorney fees. View "Sutey Oil Co. v. Monroe's High Country Travel Plaza, LLC" on Justia Law