Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the district court denying Plaintiffs' motions for default judgment and for summary judgment and granting the summary judgment of Defendants, holding that there was no error.In the midst of a dispute over real property, Plaintiffs filed an action to quiet title. The district court denied Plaintiffs' motion for summary judgment and granted Defendants' motion for summary judgment on Plaintiffs' quiet title claim. The Supreme Court affirmed, holding that the district court (1) did not manifestly abuse its discretion by declining to enter a default judgment in favor of Plaintiffs after Defendants did not complete service of their answer until one day after the deadline of Mont. R. Civ. P. 12; and (2) did not err when it determined that Plaintiffs' claims were barred by the doctrine of laches. View "Carter v. Badrock Rural Fire District" on Justia Law

The Supreme Court affirmed in part the judgment of the district court dismissing Plaintiffs' request for class certification, holding that the district court did not abuse its discretion by holding that Plaintiffs' certification request did not meet the requirements of Mont. R. Civ. P. 23.Plaintiff lived in apartment complexes owned and operated by Defendants. Plaintiffs alleged that their leases contained multiple provisions violating Montana law. Plaintiffs sought certification as a class under Rule 23 to include other tenants who entered into similar lease agreements with Defendants. The district court dismissed most claims but denied the dismissal of two claims as to one plaintiff. The district court also denied Plaintiffs' request for class certification. The Supreme Court affirmed in part and remanded for further proceedings, holding that the district court did not err in dismissing Plaintiffs' request for class certification. View "Vulles v. Thies & Talle Management, Inc." on Justia Law

The Supreme Court affirmed the sentencing order of the district court requiring Defendant to pay $3,025 in restitution for his extradition from Georgia and to surrender his medical marijuana card, holding that Defendant failed to show that the district court's sentence was illegal or that it abused its discretion.On appeal, Defendant argued that the district court erred in ordering him to pay restitution when his only income consisted of Army disability benefits and erred in requiring him to surrender his medical marijuana card pursuant to Mont. Code Ann. 46-18-202(1)(f). The Supreme Court affirmed, holding (1) Defendant's sentence was lawful; and (2) the condition of Defendant's sentence that he surrender his medical marijuana card was constitutional and lawful. View "State v. Corriher" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion for a new trial on the offense of partner or family members assault (PFMA), third or subsequent offense, holding that the district court committed reversible error.The State charged Defendant with third or subsequent offense PFMA based on incriminating audio-video camera footage capturing Defendant's belligerent verbal and physical interaction with his teenage son and subsequent incriminating statements made in a post-arrest interrogation interview conducted by a sheriff's deputy. After he was convicted, Defendant filed a motion for a new trial on the ground that the court erroneously allowed the video playbacks to the jury without notice to the parties. The district court denied the motion. The Supreme Court reversed, holding that the district court erred in denying Defendant's motion for a new trial based on a violation of Mont. Code Ann. 46-16-503(2) and the related common law rule limiting the rehearing or replay of testimonial evidence during jury deliberations. View "State v. Hoover" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of sexual assault, holding that the district court did not err or abuse its discretion.After a jury trial, Defendant was convicted of sexually assaulting his minor stepdaughters. On appeal, Defendant argued that the district court deprived him of his right to present a complete defense and requested either dismissal of his case or a new trial. The Supreme Court affirmed, holding that the district court (1) did not err when it ruled that the State did not deliberately destroy potentially exculpatory evidence; (2) did not err when it prevented Defendant from presenting evidence to the jury relating to the State's alleged destruction of evidence; and (3) did not abuse its discretion when it limited the scope of testimony by Defendant's expert witness. View "State v. Villanueva" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Defendant's motion to suppress illegal drug evidence seized as a result of a protective pat-down search for weapons and in a subsequent search of his vehicle, holding that the district court erred in concluding that the protective pat-down search of Defendant was justified.Specifically, the Supreme Court held (1) the district court erroneously held that the pat-down search of Defendant was justified under Terry v. Ohio, 392 U.S. 1 (1968) and Mont. Code Ann. 46-5-401(2)(b), whether incident to a valid Terry investigative stop or analogous community caretaker doctrine stop, but did not err in concluding that the exclusionary rule did not apply to the illegal drug evidence seized in the warrantless pat-down and vehicle searches at issue; and (2) therefore, the district court erred in denying Defendant's motion to suppress evidence found in his coat pocket as a result of the initial pat-down search but correctly denied Defendant's motion to suppress evidence found in the subsequent consent search of his vehicle. View "State v. Laster" on Justia Law

The Supreme Court affirmed the order of the district court convicting Defendant of sexual intercourse without consent, holding that the district court did not abuse its discretion by permitting admission of evidence regarding other acts and statements made by Defendant.Defendant filed a motion in liming to preclude the admission of evidence involving the occurrence of any other sexual acts or statements regarding the victim. The district court denied the motion, concluding that evidence of Defendant's sexual conduct with the victim, apart from the conduct alleged in the information, was relevant and admissible. The Supreme Court affirmed, holding that the district court did not abuse its discretion in admitting the evidence. View "State v. Murphy" on Justia Law

The Supreme Court reversed the order of the district court denying Defendant's motion to suppress based on its determination that Defendant had not been seized, holding that the district court clearly erred when it concluded that Defendant was not seized.Defendant was found guilty of felony possession with intent to distribute. The district court order denying Defendant's motion to suppress concluded that Defendant voluntarily engaged with the law enforcement officer and was not seized because a reasonable person would have felt free to disengage and leave. Further, the order concluded that Defendant validly consented to the officer searching his vehicle. The Supreme Court reversed, holding (1) Defendant was seized in this case; and (2) the officer did not have particularized suspicion to justify the seizure. View "State v. Pham" on Justia Law

The Supreme Court affirmed the order of the district court denying the Ekalaka Volunteer Fire Department, Inc.'s (Department) motion for summary judgment, holding that the district court did not err in finding that the Town of Ekalaka's fire department was municipally owned as a matter of law.The Department claimed it had always been a private fire company that existed as an unincorporated association until 2016, when it filed its incorporation paperwork following the town attorney's advice. The Town, in response, filed for a declaratory judgment that the Department was municipally owned. The district court granted summary judgment for the Town. The Supreme Court affirmed, holding that the evidence overwhelmingly weighed toward declaratory judgment affirming the duly established municipal department. View "Ekalaka v. Ekalaka Volunteer Fire Department, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of felony criminal endangerment, misdemeanor stalking, and felony stalking, holding that the district court did not err.The first trial in this case resulted in a hung jury. A year later, a second trial was held, and Defendant was convicted. At issue on appeal was whether the admission of a railroad tie at the second trial was proper because it was not in the same condition as the first trial. The Supreme Court affirmed, holding that the district court (1) did not err by not dismissing the stalking charges for insufficient evidence; and (2) did not err by admitting the railroad tie into evidence at the second trial after it had been exposed to the elements following the first trial and its condition deteriorated. View "State v. Hren" on Justia Law