Justia Montana Supreme Court Opinion Summaries

A married couple established a family trust in 2003, which, after the husband’s death in 2013, split into three sub-trusts. The Potter Exemption Trust (PET) became the owner of approximately 4,000 acres of land and a minority interest in E Bar L Ranch, LLP, which operates a guest ranch on both its own land and land leased from the PET. The wife, Betty, is the income beneficiary of the PET, while the husband’s children from a prior marriage are remainder beneficiaries. The PET’s trustees were initially three friends of the deceased husband, who later appointed successors, including Caitlin Wall and James Stone. Wall is also an employee of E Bar L, and Stone has performed contract work for E Bar L. In 2022, the PET and E Bar L entered into a new five-year lease for the PET land, with Wall participating as both PET trustee and E Bar L employee.Betty filed a petition in the Montana Fourth Judicial District Court seeking Wall’s removal as trustee, alleging a conflict of interest due to Wall’s dual roles, and requesting access to E Bar L’s financial records to investigate potential breaches of trust. She also challenged the validity of the 2022 lease. The PET, E Bar L, and other interested parties countered, seeking declaratory judgment affirming the trustees’ authority and the lease’s validity. The District Court granted summary judgment against Betty on all but one issue, finding no conflict of interest, denying her access to E Bar L’s financials, upholding the lease, and ruling that the trust instrument did not require three trustees or allow Betty to appoint successors.The Supreme Court of the State of Montana reversed the District Court’s summary judgment on the issues of conflict of interest, the validity of the lease, access to financial information, and Wall’s removal as trustee, holding that genuine issues of material fact precluded summary judgment. The Court affirmed the District Court’s ruling that the trust instrument did not mandate three trustees or permit Betty to appoint successors. The case was remanded for further proceedings. View "In re Potter Exemption Trust" on Justia Law

Law enforcement in Montana began investigating drug trafficking activities involving shipments from California to Butte. Their investigation led them to a residence where a controlled delivery of a package containing fentanyl was made. After the package was delivered and seized, a cooperating witness, Trevor Handy, identified Eric Ramirez as being involved in drug distribution activities and described his association with the residence and other individuals under investigation. Law enforcement obtained and executed a search warrant at an Airbnb where Ramirez was staying, finding drugs, cash, and a loaded handgun in a bedroom linked to Ramirez by physical evidence, including his DNA. Ramirez was charged with criminal possession with intent to distribute fentanyl, methamphetamine, and heroin.The case proceeded to trial in the Montana Second Judicial District Court, Butte-Silver Bow County. During trial, Ramirez testified that he was merely visiting friends and denied involvement in drug distribution. He requested two jury instructions: one on “mere presence,” arguing that being present at the scene was not enough for conviction, and another on witness accountability, seeking to have the jury view the testimony of the cooperating witness with distrust. The District Court denied both requests, finding that the instructions given already adequately covered the law and Ramirez’s theory of defense. The jury convicted Ramirez on the fentanyl and methamphetamine charges but acquitted him on the heroin charge.On appeal, the Supreme Court of the State of Montana reviewed whether the District Court erred in denying the requested jury instructions. The Supreme Court held that the District Court did not abuse its discretion, as the instructions provided fully and fairly instructed the jury on the applicable law and allowed Ramirez to argue his defense. The Court affirmed the convictions, concluding that Ramirez’s substantial rights were not prejudiced by the denial of the proposed instructions. View "State v. Ramirez" on Justia Law

T.W. was the subject of two involuntary commitment petitions filed by the State of Montana in August 2022. The first petition was based on reports that T.W. was suffering from severe psychosis, including paranoid delusions, hallucinations, suicidal ideations, and self-starvation, which rendered her unable to meet her basic needs and posed a threat to herself and others. At the jury trial for the first petition, T.W. waived her right to be present due to emotional distress and was permitted to observe the proceedings remotely with her video and audio off. The jury found that T.W. suffered from a mental disorder but did not require commitment, and the District Court dismissed the petition.Shortly after her release, T.W. experienced further mental health crises, including a 911 call and subsequent hospitalization, which led the State to file a second, nearly identical commitment petition. T.W. moved to dismiss the second petition, arguing it was barred by res judicata and collateral estoppel, as it relied on evidence similar to that presented in the first trial. The Montana Nineteenth Judicial District Court denied the motion, finding that the second petition was based on new events and that preclusion doctrines did not apply. At the second trial, T.W. again sought to waive her presence and requested to observe the proceedings remotely with her video and audio off, but the court required her to appear via two-way audio-video with both on, over her objection.The Supreme Court of the State of Montana held that the State’s second commitment petition was not barred by res judicata or collateral estoppel, as the issues and evidence were sufficiently distinct and the statutory scheme allows for subsequent petitions when new facts arise. However, the Court found that the District Court erred by compelling T.W.’s remote appearance over her valid waiver and objection, violating her statutory and constitutional rights. The Supreme Court affirmed in part and reversed in part, vacating the commitment order. View "In re T.W." on Justia Law

Carol Hudson died in 2018, leaving most of her estate to her sons through her will and a revocable trust. Her long-term partner, Doug Nail, claimed entitlement to an elective spousal share of her estate, asserting that he and Carol were common-law spouses under Montana law. Carol’s son, Alan Johnson (AJ), disputed this claim, arguing that Carol did not consider Doug her husband and had consistently identified herself as single on official documents. The couple had lived together in Montana for nearly a decade, shared a home, and were viewed by many friends and family as married, though Carol kept her own name and filed taxes as single.The Eighteenth Judicial District Court of Gallatin County consolidated probate and declaratory relief actions and held a bench trial. After hearing conflicting testimony from friends, family, and the parties themselves, the District Court found that Doug and Carol were common-law spouses. The court credited testimony that Carol and Doug had mutually consented to a marital relationship and held themselves out as married to their community, despite evidence that Carol identified as single on financial and medical documents. The District Court concluded that Doug was entitled to seek an elective share of Carol’s estate.The Supreme Court of the State of Montana reviewed the District Court’s findings for clear error and its legal conclusions for correctness. The Supreme Court held that substantial credible evidence supported the District Court’s findings that Doug and Carol mutually consented to marriage and confirmed their marriage by public repute. The Supreme Court affirmed the District Court’s ruling, holding that Doug and Carol were common-law spouses at the time of Carol’s death, and Doug was entitled to pursue an elective share of the estate. View "In re Estate of Hudson" on Justia Law

Frank and Shirlynne Apecella purchased property in Hamilton, Montana, in 2020, which historically received irrigation water from the Decker Ditch, originating at Roaring Lion Creek and running through their neighbor Lillian Overman’s property. After moving in, the Apecellas discovered they were not receiving water through the ditch and, upon investigation, learned that Overman’s husband had filled in the ditch and posted a “no trespassing” sign. The Apecellas own a water right in Roaring Lion Creek, and the disputed ditch segment runs from a bifurcation point on Overman’s property to the boundary with the Apecella property. The Apecellas sought a declaratory judgment affirming their ditch easement and alleged Overman interfered with their easement rights.The Montana Twenty-First Judicial District Court held a bench trial and found that the Apecellas had established both an implied and a prescriptive easement for the ditch in question, and that Overman had interfered with their easement by filling in the ditch. The court rejected Overman’s defenses of abandonment and reverse adverse possession, finding insufficient evidence that the Apecellas or their predecessors had abandoned the easement or that Overman had extinguished it through adverse use. The court permanently enjoined Overman from further interference and awarded the Apecellas attorney fees as the prevailing party under Montana law.The Supreme Court of the State of Montana affirmed the District Court’s judgment. It held that Overman failed to prove by clear and convincing evidence either abandonment or reverse adverse possession of the Apecellas’ irrigation ditch easement. The Court also held that the Apecellas were the prevailing party under § 70-17-112(5), MCA, and were entitled to reasonable costs and attorney fees. The District Court’s orders were affirmed in all respects. View "Apecella v. Overman" on Justia Law

The defendant pleaded guilty to burglary, theft, and criminal mischief in 2017 and was sentenced to concurrent terms with a portion suspended, as well as ordered to pay restitution and various fees. After serving time in corrections and being released, he began the suspended portion of his sentence in 2020. In 2023, the State petitioned to revoke his probation, citing a new drug charge and several compliance violations, including failure to pay restitution and fees. The defendant admitted to the new criminal charge, and the other alleged violations were dismissed. At issue was whether he should receive credit for the time he spent on probation (“street time”) before revocation, given his failure to make restitution payments during a specific period.The Montana Eighth Judicial District Court found that, despite the lack of documented violations between August 2020 and January 2023, the defendant’s ongoing failure to pay restitution and fees constituted continuous noncompliance. The court denied him any credit for street time, reasoning that his nonpayment reflected a pattern of disregard for court-ordered conditions.The Supreme Court of the State of Montana reviewed the case de novo, focusing on whether the defendant’s nonpayment of restitution, absent evidence of a clear payment schedule or corrective interventions by his probation officer, constituted a violation sufficient to deny street time credit under § 46-18-203(7)(b), MCA. The Court held that, without a specific directive or record of interventions regarding payment, the State failed to establish a violation during the relevant period. Therefore, the District Court erred in denying street time credit. The Supreme Court reversed the lower court’s decision and remanded the case, directing that the defendant be credited with 883 days of street time. View "State v. Powell" on Justia Law

Tristin Fahrnow was injured when a hot-oil truck operated by an employee of E-5 Oilfield Services struck him on an icy Montana highway. Fahrnow had been inspecting his own vehicle after a prior collision at the intersection, and was standing in the roadway when the E-5 truck lost control and hit him. Fahrnow sued E-5 for negligence under a theory of vicarious liability, alleging that the E-5 driver failed to operate the truck safely given the hazardous conditions. E-5 asserted that Fahrnow’s own actions, including parking in the traffic lane and failing to display warning devices, constituted comparative negligence.The Seventh Judicial District Court of Montana granted summary judgment in favor of E-5, finding that Fahrnow was solely responsible for his injuries as a matter of law. The District Court also denied Fahrnow’s motions for sanctions against E-5 for alleged spoliation of evidence (loss of truck data and employment records) and denied his motion to compel E-5 to answer an interrogatory comparing the parties’ medical experts’ qualifications, granting E-5’s cross-motion for a protective order.The Supreme Court of the State of Montana reviewed the case de novo. It held that the record presented a genuine issue of material fact regarding the comparative negligence of both drivers, making summary judgment inappropriate. The Court reversed the District Court’s grant of summary judgment to E-5 and remanded for trial. However, the Supreme Court affirmed the District Court’s denial of Fahrnow’s motions for default judgment as a sanction for spoliation and its denial of the motion to compel further expert discovery, finding no abuse of discretion in those rulings. View "Fahrnow v. E-5 Oil Services" on Justia Law

On May 29, 2003, two Blaine County Sheriff’s deputies responded to a domestic disturbance involving Laurence Dean Jackson Jr. in Harlem, Montana. During a pursuit through a field, both deputies were shot; Deputy Rutherford died from a gunshot wound to the chest, and Deputy Janis was severely injured. Jackson, claiming an alcohol-induced blackout, could not recall the events, leaving Janis as the sole eyewitness. At trial, the State relied on Janis’s testimony and physical evidence to argue that Jackson shot both deputies after a struggle. Jackson’s defense presented expert testimony challenging the State’s account, including a theory that the fatal bullet may have been fired by Janis, not Jackson.Following a 17-day trial in October 2004, Jackson was convicted of deliberate homicide and attempted deliberate homicide, receiving life sentences without parole. The Montana Supreme Court affirmed his conviction in 2009, and the U.S. Supreme Court denied certiorari in 2010. In 2011, Jackson filed a petition for postconviction relief in the Seventeenth Judicial District Court, Blaine County, alleging ineffective assistance of counsel. The District Court allowed for additional evidence and expert review but ultimately denied the petition without an evidentiary hearing, finding Jackson’s claims lacked specific factual support as required by Montana law.The Supreme Court of the State of Montana reviewed whether the District Court abused its discretion by denying Jackson’s petition without a hearing. Applying the Strickland v. Washington standard, the Court held that Jackson failed to present established facts showing deficient performance or prejudice by counsel. The Court found Jackson’s claims speculative and unsupported by the record, concluding the District Court acted within its discretion. The Supreme Court affirmed the denial of postconviction relief. View "Jackson v. State" on Justia Law

The defendant was cited for a third offense of driving under the influence (DUI) and for driving with a suspended license, both misdemeanors, in November 2021. He was initially convicted in Justice Court and then sought a trial de novo in the District Court. At trial, a jury found him guilty of both offenses. During sentencing, the defendant’s counsel informed the court that the defendant was on a limited income, receiving disability and social security, and requested that the court consider his financial situation when imposing fines and fees, including a request to waive the public defender fee.After the jury verdict in the Twenty-First Judicial District Court, the court sentenced the defendant to jail time, most of which was suspended, and imposed a $3,000 fine with statutory surcharges and a $250 public defender fee. The written judgment also included a $10 technology fee and $50 in prosecution costs, which were not mentioned in the oral pronouncement. The defendant appealed, arguing that the written judgment conflicted with the oral sentence and that the court failed to consider his ability to pay the fines and fees.The Supreme Court of the State of Montana reviewed the case. It held that when there is a conflict between the oral sentence and the written judgment, the oral sentence controls, and thus the $10 technology fee and $50 prosecution costs should not have been included. The court further held that the District Court erred by failing to inquire into the defendant’s ability to pay the public defender fee, the $3,000 fine, and the statutory surcharges, as required by Montana statutes. The Supreme Court reversed the sentence and remanded the case for a new sentencing hearing consistent with its opinion. View "State v. Post" on Justia Law

A married couple with four children sought dissolution of their marriage after several years together. The wife, who had primarily cared for the children earlier in the marriage, was employed as a surgical nurse earning about $2,990 per month, while the husband worked as a carpenter earning approximately $7,250 per month. In the dissolution proceedings, the marital estate was divided, with the wife receiving a share of the husband’s retirement and half the equity in the marital home, while the husband retained the home and its associated debt. The court also ordered the husband to pay child support, spousal maintenance, and the wife’s attorney’s fees.The Fourth Judicial District Court of Montana conducted a bench trial and issued a decree that included the award of attorney’s fees to the wife. The only evidence regarding attorney’s fees was the wife’s testimony that she owed her attorney about $2,000 and could be responsible for her own fees, and the husband’s testimony that he had paid his attorney by borrowing from his parents. The District Court found that the husband had been able to pay his attorney’s fees and the wife had not, and ordered the husband to pay the wife’s attorney’s fees without further explanation or reference to legal standards. The husband appealed, and after partial resolution in appellate mediation, the sole issue on appeal was the propriety of the attorney’s fees award.The Supreme Court of the State of Montana reviewed the case and held that the District Court abused its discretion by awarding attorney’s fees without grounding its decision in substantial evidence or applying the governing legal standards. The Supreme Court found that the District Court failed to make necessary findings regarding the necessity and reasonableness of the award and did not provide a sufficient factual or legal basis for its decision. The Supreme Court reversed the award of attorney’s fees. View "In re Marriage of Salois" on Justia Law