Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the order of the district court granting summary judgment to J&L Lands, LP and awarding J&L a portion of the proceeds from the sale of Jerry Nezat's homestead property, holding that the homestead exemption statutes disposed of this matter.J&L filed this action against Nezat to foreclose a judgment lien on the property at issue but agreed to lift its lien to allow Nezat to sell the property. After Nezat sold the property the district court granted summary judgment to J&L and awarded J&L up to twenty-five percent of the proceeds from the sale of the home despite Nezat's homestead declaration on the property. The Supreme Court reversed, holding that the district court erred in satisfying J&L's judgment lien before Nezat received the full value of the homestead exemption from the proceeds of the sale. View "J&L Lands, LP v. Nezat" on Justia Law

In this marital dissolution proceeding, the Supreme Court affirmed the judgment of the district court awarding child support and failing to award retroactive child support, holding that there was no error or abuse of discretion.The district court awarded Wife permanent child support of $1,800 per month from Husband and declined Wife's request for retroactive child support. The Supreme Judicial Court affirmed, holding that the district court (1) did not err or abuse its discretion in categorizing Husband's income from his father as "gift income," resulting in the exclusion of that income from the court's child support calculation; and (2) did not abuse its discretion when it refused to award Wife retroactive child support. View "Miller v. Miller" on Justia Law

The Supreme Court affirmed Defendant's convictions for partner or family members assault (PFMA), unauthorized use of a motor vehicle, and two counts of tampering with witnesses or informants but reversed the district court's imposition of various fees and costs on Defendant, holding that remand was required for an analysis of Defendant's ability to pay before imposing costs and fees.Specifically, the Supreme Court held (1) the admission of certain hearsay statements was not harmless error; (2) Defendant's right to a fair trial by an impartial jury was not violated; (3) Defendant was not entitled to relief on his argument that his right to confrontation was violated by the repeated emphasis on recorded jail phone calls; (4) the record was insufficient to review Defendant's claim of ineffective assistance of trial counsel; and (5) the district court erred in imposing jury and other costs on Defendant without first undertaking an ability to pay inquiry. View "State v. Oliver" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing North Star Development, LLC's petition for judicial review of the Montana Public Service Commission's (PSC) August 2020 rate determination regarding North Star's 2019 application for water and sewer utility rate increase authorizations, holding there was no error.Specifically, the Supreme Court held (1) the district court correctly concluded that North Star failed to exhaust all available administrative remedies, as required by Mont. Code Ann. 2-4-702(1)(a); (2) the correct jurisdictional basis for dismissal of a petition for judicial review due to failure to exhaust administrative remedies is a lack of procedural justiciability rather than lack of subject matter jurisdiction; and (3) the district court did not commit reversible error by failing to consider North Star's asserted waiver and equitable estoppel defenses. View "North Star Development, LLC v. Montana Public Service Commission" on Justia Law

The Supreme Court reversed in part and affirmed in part the order of the district court granting summary judgment in favor of Lewis and Clark County (County) and Bridge Creek Estates Homeowners Association (HOA) on the County's claim for declaratory judgment and on Philip Wirth's counterclaim against the County, holding that the district court erred in part.Specifically, the Supreme Court held that the district court (1) erred in its interpretation of the covenants by concluding that Wirth was unambiguously prevented from further subdividing the lots retained by him within the subject subdivision, in failing to consider extrinsic evidence, and by resolving the issue at summary judgment; (2) erred by granting summary judgment to the County and dismissing Wirth's counterclaim for statutory damages; (3) did not err in granting summary judgment to the HOA; and (4) prematurely granted attorney fees to the HOA. View "Wirth v. Lewis & Clark County" on Justia Law

The Supreme Court affirmed the order entered by the district court dismissing as time-barred Appellant's negligence claims against Community Hospital of Anaconda and Pintler Surgical Specialists (collectively, CHA), holding that there was no error.Specifically, the Supreme Court held that the district court (1) did not err by concluding that Appellant's claim against CHA was a professional negligence claim subject to the two-year period of limitations pursuant to Mont. Code Ann. 27-2-205(1); and (2) did not err by ruling that Appellant's medical negligence claim was not tolled under section 27-2-205(1) and dismissing the claim as time-barred. View "Selensky-Foust v. Mercer" on Justia Law

The Supreme Court affirmed Defendant's conviction for felony driving a motor vehicle under the influence of alcohol or drugs (DUI), holding that there was no harmless error in the proceedings below.Specifically, the Supreme Court held (1) the district court did not violate Defendant's right to equal protection by denying his Batson objection to the State's peremptory strike of the only racial minority member of the venire; (2) while one of the prosecutor's remarks during closing argument was erroneous, the prosecutor's remarks, considered cumulatively, did not violate Defendant's right to a fair trial; and (3) the district court did not err when it relied on one of Defendant's prior convictions to support enhancement of his DUI conviction to a felony offense and in determining that the prior conviction was constitutionally valid. View "State v. Wellknown" on Justia Law

The Supreme Court reversed Defendant's convictions for felony criminal possession of dangerous drugs and misdemeanor criminal possession of drug paraphernalia, holding that the district court erred in denying Defendant's motion to suppress.On appeal, Defendant argued that the district court abused its discretion in denying his motion to suppress evidence seized after a vehicle search that resulted from an unlawfully prolonged investigative driving under the influence (DUI) stop. The district court denied the motion to suppress on the ground that the initial stop of Defendant was lawful based on a reasonable particularized suspicion of DUI. The Supreme Court reversed, holding (1) while Defendant was lawfully stopped on a reasonable particularized suspicion of DUI, the officers unlawfully prolonged the duration of the stop before subjecting Defendant to the confirmatory DUI field sobriety testing; and (2) therefore, the district court erroneously denied Defendant's motion to suppress. View "State v. Zeimer" on Justia Law

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