Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the order entered by the district court granting summary judgment to the Public Service Commission (PSC) and dismissing Appellants' claim that Mont. Code Ann. 69-2-102 was unconstitutional, holding that this matter lacked a justiciable controversy.Appellants filed a petition seeking a judgment declaring that the PSC's contested case procedures were unconstitutional. Specifically, Appellants alleged that the PSC's application of section 69-2-102 was unconstitutional as applied. The district court granted summary judgment to the PSC, dismissing Appellants' challenges against the statute on justiciability grounds. The Supreme Court affirmed, holding that the district court did not err in concluding that Appellants lacked standing to challenge, on due process grounds, the constitutionality of section 69-2-102. View "Broad Reach Power, LLC v. Mont. Dep't of Service Regulation" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress evidence confiscated by a adult foster care group home's manager who subsequently turned the evidence over to the police, holding that the district court did not err when it failed to suppress the evidence.The manager of the group home contacted the police on several occasions stating that she had confiscated child pornography from Defendant, a resident of the group home, pursuant to the group home's rules. The manager gave the police the confiscated evidence, which led to the grant and execution of a search warrant. Defendant was subsequently charged with possession of child pornography. Defendant moved to suppress the evidence, which the district court denied. Defendant subsequently entered into a plea agreement with the State. The Supreme Court affirmed the denial of Defendant's motion to suppress, holding (1) the group home manager was acting as a private party when she confiscated Defendant's electronic devices containing pornography; and (2) Defendant consented to the manager confiscating his electronic devices by agreeing to the group home's rules. View "State v. Larson" on Justia Law

The Supreme Court reversed the orders of the district court granting Zinvest, LLC's motion for summary judgment and dismissing Wells Fargo Bank, N.A.'s complaint alleging that Zinvest failed to give proper notice of pending tax deeds under Mont. Code Ann. 15-18-212 and requesting the tax deeds issued to Invest be declared void, holding that the district court erred.Wells Fargo held a deed of trust against two parcels of land. Because the taxes assessed against each parcel for the tax year 2014 were unpaid the Missoula County treasurer conducted a tax lien sale for both parcels. Missoula County purchased the tax liens, executed a county treasurer's certificate of tax sale for both parcels and assigned the certificates to Zinvest. When Zinvest mailed notices that tax deeds may issue to Wells Fargo, they were returned. The Missoula County treasurer then executed tax deeds conveying the parcels to Zinvest. Wells Fargo subsequently brought its complaint. The district court granted summary judgment for Zinvest. The Supreme Court reversed, holding that Zinvest's failure to mail notices that the tax deeds may issue to Wells Fargo violated Mont. Code Ann. 15-18-212. View "Wells Fargo Bank, N.A. v. Zinvest, LLC" on Justia Law

The Supreme Court denied Defendant's motion to allow withdrawal of his guilty plea and dismiss the underlying matter on double jeopardy grounds, holding that the district court did not err in denying Defendant's motion to withdraw his guilty plea and dismiss and the criminal endangerment and criminal mischief charges in Jefferson County.Jefferson County charged Defendant with criminal endangerment, fleeing from or eluding a peace officer, and criminal mischief. The next month, Gallatin County charged with him criminal endangerment and fleeing from or eluding a peace officer. Defendant pled guilty to both charges. Defendant subsequently moved to withdraw his guilty plea and to dismiss the Jefferson County charges, arguing that they violated constitutional double jeopardy protections. The district court allowed the motion as to the fleeing from or eluding a peace officer charge and otherwise denied the motion. The Supreme Court affirmed, holding that the district court did not err by denying Defendant's motion to withdraw his guilty plea as to the criminal endangerment and criminal mischief charges. View "State v. Dunne" on Justia Law

The Supreme Court affirmed the judgment of the district court revoking Defendant's suspended sentence and imposing a sentence with a termination date beyond the original sentence, holding that the district court did not err in sentencing Defendant to a term no greater than his original sentence and in denying credit for elapsed time.Defendant pleaded guilty to two counts of felony indecent exposure. The State later filed a petition to revoke Defendant's sentence. The district court imposed a suspended sentence with a termination date beyond the original sentence. The Supreme Court affirmed, holding that the district court did not violate either Mont. Code Ann. 46-18-203(7)(a)(iii) or Mont. Code Ann. 46-18-203(7)(b) in sentencing Defendant to a term no greater than his original sentence and in denying credit for elapsed time. View "State v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the district court issuing a decree quieting title to a claimed easement in favor of Rose Family Trust (Rose), holding that the district court did not err by determining that a "notice of purchaser's interest" (NPI) did not convey title to the easement in dispute.Rose filed this action to quiet title and to enjoin use of the claimant easement by Appellants. The district court ruled in favor of Rose, holding that the NPI at issue did not constitute a valid instrument of conveyance and therefore did not transfer any easement rights to Appellants. On appeal, Appellants argued that the NPI was itself an instrument of conveyance and, alternatively, that the NPI functioned as an abstract of an instrument of conveyance. The Supreme Court disagreed and affirmed, holding that neither the NPI nor the abstracted contract for deed effectuated title transfer, and therefore, there was no actual conveyance on which Appellants could base their claim. View "Towsley v. Stanzak" on Justia Law

The Supreme Court affirmed the order of the district court denying Defendant's motion to prevent silent security camera footage from being made available to the jury during deliberations and subsequent judgment of guilty to the charge of deliberate homicide, holding that the district court did not abuse its discretion.After a jury trial, Defendant was found guilty of deliberate homicide and sentenced to a 100-year term of imprisonment. On appeal, Defendant argued that the district court abused its discretion by allowing silent video footage from the neighbor's security camera to go into the jury room during deliberations. The Supreme Court affirmed, holding that where the camera footage at issue was neither testimonial in nature nor cared any substantial risk of undue emphasis, it was not an abuse of discretion for the district court to provide the jury with unrestricted access to this footage during deliberations. View "State v. Green" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of deliberate homicide and tampering with or fabricating physical evidence, holding that Defendant's assignments of error were without merit.On appeal, Defendant argued, among other things, that the State's 391-day delay in bringing his case to trial violated his constitutional right to a speedy trial under both the state and federal constitutions. The Supreme Court affirmed, holding (1) where the delay was primarily institutional under the conditions presented at the time by the unprecedented COVID-19 pandemic and where Defendant failed to demonstrate prejudice, Defendant failed to establish that he was denied his right to a speedy trial; and (2) the district court did not err when it denied Defendant's motion to strike the jury panel. View "State v. Hesse" on Justia Law

The Supreme Court affirmed the order of the district court sentencing Defendant to ten years in Montana State Prison, with four years suspended, in connection with his conviction for aggravated sexual intercourse without consent, holding that there was no basis for reversal.Specifically, the Supreme Court held (1) the district court did not err in applying the rape shield statute to exclude a portion of the victim's texts regarding her sexual conduct; (2) the instructions provided by the district court fully and fairly instructed the jury regarding the mental state applicable to charges of sexual intercourse without consent; and (3) the district court properly instructed the jury by delivering a general unanimity instruction. View "State v. Ragner" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the summary judgment ruling of the district court and resulting final judgment granting Plaintiff judgment that Plaintiff was the sole owner of a formerly co-owned family cabin property and denying Defendant's constructive fraud counterclaim, holding that that the district court erred in part.At issue was cabin property located on land owned by the United States Forest Service in Granite County, Montana. Plaintiff brought this action seeking declaratory judgment that he was the sole owner of the property and asserting a claim for quiet title. Defendant asserted a counterclaim alleging constructive fraud. The district court ruled in favor of Plaintiff. The Supreme Court reversed in part, holding that the district court (1) did not err in granting summary judgment to Plaintiff on his asserted declaratory judgment and quiet title claims; but (2) erred in granting summary judgment to Plaintiff on Defendant's constructive fraud counterclaim. View "Drescher v. Malee" on Justia Law