Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction and judgment of guilty for the offense of escape, holding that Defendant was not entitled to relief on his claims of error.The State charged Defendant with felony escape after he failed to report to his probation offense. The jury returned a guilty verdict, and Defendant was sentenced to six years' imprisonment. The Supreme Court affirmed, holding that the district court (1) did not err in denying Defendant's motion to dismiss for insufficient evidence; and (2) did not err in declining to provide Defendant's requested jury instruction for criminal contempt as a lesser-included offense. View "State v. Ohl" on Justia Law

The Supreme Court affirmed the decision of the district court to affirm the Montana Department of Environmental Quality's (DEQ) issuance of a solid waste management system (SWMS) license to the City of Billings for future expansion of its Class II facility, the Billings Regional Landfill, holding that the DEQ did not violate the law.Specifically, the Supreme Court held (1) in approving the City's license application, the district court did not err when it concluded that DEQ made a "reasoned determination" that the City satisfied the requirements of Admin. R. M. 17.50.1005; (2) the district court did not err when it concluded that DEQ did not need to prepare an environmental impact statement pursuant to Admin. R. M. 17.4.608(1)(g); and (3) the district court did not err by not addressing whether the proposed expansion area violates Mont. Code Ann. 75-10-212(2)(c). View "Hillcrest Natural Area Foundation, Inc. v. Dep't of Environmental Quality" on Justia Law

The Supreme Court affirmed the order of the district court affirming the decision of the Board of Supervisors of the Gallatin Conservation District (GCD) that a waterway within property owned by Appellant constituted a "natural, perennial-flowing stream" under the Natural Steambed and Land Preservation Act of 1975 (the 310 Law), holding that the district court did not err.Specifically, the Supreme Court held that the district court (1) did not err in concluding that GCD properly exercised its discretion in evaluating the entirety of the record, including historical evidence, when deciding whether the waterway on Appellant's property fell within the conservation district's jurisdiction; and (2) did not erroneously uphold GCD's determination that substantial evidence supported its conclusion that the waterway constituted a natural perennial-flowing stream as set forth in the 310 Law. View "Pfeil Acquisitions LLC v. Gallatin County Conservation District" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the decision of the Montana Department of Revenue (MDOR) denying Appellant's petition to adopt a proposed administrative rule construing Mont. Code Ann. 15-30-2605(3), holding that the MDOR correctly construed sections 15-30-2605(1) and (3) and did not capriciously, arbitrarily, or unlawfully preliminarily deny Appellant's petition for adoption of a proposed rule interpreting the section 15-30-2605(3).At issue were internal MDOR reviews initiated by clients of Appellant, a certified public accountant, regarding 2021 MDOR adjustment notices regarding their 2017 income tax returns. Appellant argued that the noticed MDOR adjustments were untimely beyond the three-year deadline set forth in section 15-30-2605(3) and petitioned MDOR to adopt a rule to clarify section 15-30-2605 based on his contrary interpretation of section 15-30-2605(3). MDOR denied the petition, and the district court affirmed. The Supreme Court affirmed, holding that the district court did not err in determining that MDOR's construction of section 15-30-2605(3) was correct and that Appellant failed to demonstrate that the denial of his rulemaking petition was arbitrary, capricious, or based on an erroneous conclusion of law. View "Wangerin v. Dep't of Revenue" on Justia Law

In this foreclosure action arising under the Small Tract Financing Act (STFA), the Supreme Court affirmed the order of the district court granting Defendant's motion for summary judgment and denying Plaintiffs' cross motion for summary judgment, holding that the STFA does not contain an indication that a trustee is barred from delegating certain notice duties to agents.Thomas and Mindy Pennell entered into a deed of trust under the STFA to secure financing to purchase certain property. The deed of trust was later assigned to Nationstar Mortgage, which appointed First American Title Company of Montana as successor trustee. When the Pennells defaulted, First American began foreclosure proceedings. Daniel Inman purchased the property at a trustee's sale, and First American executed a trustee's deed conveying the property to him. The Pennells then filed a complaint for declaratory judgment seeking a declaration that the trustee's sale and resulting trustee's deed were void because First American failed to follow the requirements of the STFA. The district court granted summary judgment for Nationstar. The Supreme Court affirmed, holding (1) the Pennells' argument that an indenture trustee is prohibited under the STFA from delegating its notice duties to an agent was without merit; and (2) the district court correctly granted summary judgment in favor of Nationstar. View "Pennell v. Nationstar" on Justia Law

The Supreme Court affirmed in part and remanded in part the order of the district court denying Plaintiffs' application to preliminarily enjoin the State from enforcing House Bill 702, a "vaccination discrimination law," as enacted by the Legislature and signed by the Governor, holding that the district court did not abuse its discretion in declining to issue the preliminary injunction.HB 702, codified as Mont. Code Ann. 49-2-312, was an act "prohibition discrimination based on a person's vaccination status." Plaintiffs sought to preserve their ability to enforce a vaccine mandate on current and prospective employees by bringing this action. The lower court dismissed the complaint, ruling that Plaintiffs failed to satisfy their burden of establishing a prima facie case that they would suffer irreparable harm caused by implantation of the law prior to the final resolution of the case. The Supreme Court remanded in part, holding (1) the court's decision to deny preliminary injunctive relief did not constitute a manifest abuse of discretion; and (2) the court did not manifestly abuse its discretion in denying preliminary injunctive relief prior to final resolution on the merits. View "Netzer v. State" on Justia Law

The Supreme Court affirmed the order of the district court denying Foster Parents' motion to intervene in an abuse of neglect proceeding, holding that abandonment must be alleged before a foster parent is allowed to intervene pursuant to Mont. Code Ann. 41-3-422(9)(b).The Department of Public Health and Human Services removed two Indian children for physical neglect and placed them with Foster Parents for three years. The Department later submitted an Interstate Compact for the Placement of Children for the younger child to be placed with her grandmother in Virginia. Foster Parents opposed the placement and filed a motion to intervene. The district court denied intervention, concluding that Foster Parents as a matter of law did not have a right to intervene. The Supreme Court affirmed, holding (1) because section 41-3-422(9)(b) precludes intervention in cases where the Department has not alleged abandonment, the district court did not err in denying Foster Parents' motion to intervene; and (2) Foster Parents were statutorily precluded from asserting a nonparent interest in the parent-child relationship while the proceedings remained pending. View "In re U.A.C." on Justia Law

The Supreme Court reversed the district court's sentence on Defendant's convictions for escape and assault on a peace officer, holding that the district court erred in calculating credit for time served and in imposing supervisory conditions on Defendant's future parole.On appeal, Defendant argued (1) the trial court failed properly to credit the time Defendant spent in jail prior to sentencing after he was committed on another offense to the Montana Department of Corrections (DOC), and (2) the court improperly imposed supervisory conditions on Defendant's unsuspended sentence to the DOC. The State conceded the second issue on appeal. The Supreme Court reversed, holding that the district court (1) erred by granting Defendant only 56 days of credit for time served and should have given for time served in the amount of 396 days; and (2) erred in imposing supervisory conditions on Defendant's sentence when it was ordered entirely unsuspended. View "State v. Spagnolo" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court convicting and sentencing Defendant for assault with a weapon, holding that the district court erred in its calculation of Defendant's credit for time served.On appeal, Defendant challenged several evidentiary rulings and the calculation of credit toward his sentence for time served. The Supreme Court remanded the case, holding that the district court (1) did not err by admitting the victim's hospital statement at trial as a prior inconsistent statement; (2) did not err by admitting evidence of a conversation between Defendant and his girlfriend as an admission by party-opponent; and (3) should have awarded Defendant an additional 269 days of credit for time served. View "State v. Pitkanen" on Justia Law

The Supreme Court reversed the order of the district court granting Defendant's motion to dismiss Plaintiff's complaint making a claim for statutory damages against the Board of County Commissioners pursuant to Mont. Code Ann. 76-3-625(1) and equal protection, takings, and due process claims under 42 U.S.C. 1983, holding that the district court erred.In granting the Board's motion to dismiss, the district court determined that Plaintiff's section 76-3-625(1) claims were barred by a thirty-day statute of limitations and its section 1983 claims failed to state a claim. The Supreme Court reversed, holding that the district court erred in (1) determining that the section 76-3-625(1) claim was subject to a thirty-day statute of limitations and was therefore time-barred; and (2) erred in concluding that Plaintiff's 42 U.S.C. 1983 claims lacked a sufficient protected property interest and were insufficiently pled to survive a motion to dismiss for failure to state a claim. View "Tai Tam, LLC v. Missoula County" on Justia Law