Justia Montana Supreme Court Opinion Summaries

In this insurance dispute, the Supreme Court reversed in part and affirmed in part the judgment of the district court granting the cross-motion for partial summary judgment in favor of Plaintiffs and New West Health Services and denying Allied World Assurance Company's motion for partial summary judgment, holding that the district court erred in part.Dana Rolan, who serious injuries in an automobile accident, had health insurance through New West. New West denied coverage because the tortfeasor's liability insurance paid $100,000 of Rolan's medical expenses. Rolan filed a class action complaint alleging that New West violated its made-whole obligations. New West tendered the defense to its insurer, Allied. The district court certified the class and held New West liable for monetary losses. Plaintiffs and New West subsequently entered into a settlement. Allied opposed the district court's ensuing motion for final judgment, arguing that the proposed settlement amount was not covered by Allied. The district court approved the settlement between New West and Plaintiffs. The Supreme Court held that the district court (1) erred in holding that Allied was estopped from asserting a $1 million "each Claim" limit of liability under the policy; and (2) correctly concluded that Allied's "Loss" provision did not preclude Allied's indemnity obligation of the class's damages. View "Rolan v. New West Health Services" on Justia Law

The Supreme Court reversed the order of the district court affirming the denial of Defendant's motion to suppress evidence, holding that law enforcement officers lacked particularized suspicion to justify their investigatory stop of Defendant.Defendant was stopped by law enforcement officers based solely on his "flicking" his high beams on and off once. Defendant entered a conditional guilty plea to aggravated driving under the influence, third offense, reserving the right to appeal the justice court's denial of his motion to suppress. The district court affirmed. The Supreme Court reversed, holding that the totality of the circumstances did not give rise to particularized suspicion, and therefore, the seizure violated Defendant's constitutional right to be free from unreasonable searches and seizures. View "State v. Gardner" on Justia Law

The Supreme Court reversed the judgment and sentencing order of the district court that sentenced Defendant to ten years at the Montana State Prison (MSP) for assault on a peace officer and eighty years at MSP for attempted deliberate homicide after he was convicted of both charges, holding there was insufficient evidence to convict Defendant of attempted deliberate homicide.Specifically, the Supreme Court held (1) the State did not present sufficient evidence to convict Defendant of the crime of attempted deliberate homicide; and (2) the district court erred when it orally imposed conditions in its oral pronouncement of sentence in this case. The Supreme Court remanded the case for the district court to strike the conditions it orally stated as conditions of parole. View "State v. Boyd" on Justia Law

The Supreme Court reversed the order of the district court denying Defendant's motion to suppress evidence obtained when law enforcement officers entered Defendant's private property without a warrant, holding that that the State did not prove exigent circumstances permitting a warrantless search.At issue was whether Defendant had a reasonable expectation of privacy in his residence's driveway when he told a sheriff's deputy, who was attempting to effectuate a traffic stop, that he was trespassing and needed a warrant and whether exigent circumstances existed to allow the sheriff's deputy to conduct a warrantless investigation on the property. The Supreme Court held (1) the deputy sheriff properly entered the driveway when he already had initiated a traffic stop but exceeded his authority after Defendant asked him to leave; and (2) Defendant's failure to stop for a minor traffic violation did not create an exigency allowing the deputy sheriff to conduct a warrantless investigation after Defendant invoked his right to privacy. View "State v. Smith" on Justia Law

The Supreme Court reversed the judgment of the district court convicting and sentencing Defendant for felony driving under the influence (DUI), holding that Defendant sufficiently objected regarding his inability to pay a statutory surcharge imposed by the district court at sentencing.After a hearing, the district court ordered Defendant to pay a $5000 mandatory fine for a felony DUI and also ordered him to pay fees and costs, a $500 surcharge, a witness fee, a prosecution fee, and a technology fee. On appeal, Defendant argued that the district court should have waived the $500 surcharge due to his inability to pay. The State argued in retort that the colloquy between Defendant and the district court was too nonspecific to count as an objection to the surcharge. The Supreme Court reversed in part, holding that Defendant's objection was sufficient to notify the district court that the required ability-to-pay inquiry was at play. View "State v. Steger" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant for theft of property exceeding $1,500 in value, holding that the district court committed harmless error in allowing a State witness to appear by two-way video at trial.Before trial, the State moved the district court to allow the witness to testify by two-way video, arguing that transporting a witness, whose testimony was expected to last only several minutes, almost 500 miles would be overly burdensome and costly. The district court granted the motion. On appeal, Defendant argued that the district court violated his right to confront witnesses against him by allowing the witness to appear by two-way video at trial. The Supreme Court affirmed, holding (1) because the court made no finding establishing an important public policy reason for the video testimony apart from judicial economy, allowing the witness to testify by video violated Defendant's constitutional right to confrontation; but (2) the State met its burden to show that the error was harmless. View "State v. Martell" on Justia Law

The Supreme Court affirmed Defendant's conviction for assault on a peace officer, holding that the district court did not err by denying Defendant's motion for mistrial based upon a prosecutor's comment made during opening statement and a prosecution witness's remark about Defendant's prior prison incarceration.On appeal, Defendant argued that the district court erred in denying his motion for mistrial based on two alleged incidents of prosecutorial misconduct. The Supreme Court affirmed the conviction, holding (1) the prosecutor's improper actions in this case did not prejudicially affect Defendant's right to a fair and impartial trial; and (2) therefore, the district court did not abuse its discretion in denying Defendant's motion for mistrial. View "State v. Erickson" on Justia Law

The Supreme Court affirmed the final order and summary judgment order of the Montana Water Court adjudicating eleven United States Bureau of Reclamation (BOR) water rights claims in Basin 41B, holding that there was no error in the proceedings below.The BOR's claims to direct flow from the Beaverhead River and reservoir storage in the Clark Canyon Reservoir were associated with the East Bench Unit Reclamation Project. The East Bench Irrigation District (EBID) and the Clark Canyon Water Supply Company (CCWSC) had contracts with the BOR to deliver water from the project. The Supreme Court affirmed, holding (1) the Water Court's findings of fact regarding the maximum irrigated acreage for the EBID were supported by substantial evidence; (2) the Water Court did not err by not providing specific boundaries or maximum irrigated acreage for the CCWSC place of use on the BOR's Clark Canyon Reservoir storage claim; and (3) the Water Court did not err in removing a curtailment remark from all CCWSC shareholders' private water rights in this action. View "East Bench Irrigation District v. Open A Ranch, Inc." on Justia Law

The Supreme Court affirmed in part and reversed in part Defendant's sentence of five years' imprisonment with two years suspended and fees and fines totaling $5560, as well as an order to pay imprisonment, probation, and alcohol treatment costs "if financially able," holding that the district court improperly failed to inquire into Defendant's ability to pay the fines, fees, and surcharges ordered.Defendant pled guilty to felony operation of a noncommercial vehicle by a person with a blood alcohol concentration of .08 or more, in violation of Mont. Code Ann. 61-8-406 and -731. Defendant challenged his sentence on appeal, arguing that the imposition of the financial costs violates statutes and the Court's precedents requiring district court findings about ability to pay. The Supreme Court reversed in part, holding that the district court (1) acted within its discretion to condition payment of imprisonment, probation, and treatment costs on a later determination of Defendant's ability to pay; (2) acted legally in imposing the mandatory $5000 fine; but (3) did not make the requisite inquiry into Defendant's ability to pay the $560 in fees and surcharges. View "State v. Yeaton" on Justia Law

The Supreme Court accepted certification of two questions by the United States Court of Appeals for the Ninth Circuit regarding whether a charitable write-off of medical expenses may be recovered as damages or is subject to the collateral source rule.Specifically, the Supreme Court concluded (1) for a claim that accrued prior to the effective date of Mont. Code Ann. 27-1-308 a plaintiff in a survival action may not recover the reasonable value of medical care and related services when the costs of such services or care are wholly written off under the provider's charitable care program and the patient receives a zero-balance bill; and (2) for a claim that accrued prior to the effective date of Mont. Code Ann. 27-1-308, such a charitable care write-off is not a collateral source within the meaning of section 27-1-307. View "Gibson v. United States" on Justia Law