Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court convicting Defendant of sexual intercourse without consent, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) the district court did not abuse its discretion by excluding evidence related to Defendant's accuser's pending DUI charge in another county; (2) the district court did not violate Defendant's constitutional right to confront the witnesses against him or present his defense by limiting cross-examination of Defendant's accuser regarding alleged leniency she may have received related to her pending DUI case in return for her testimony against Defendant; and (3) the chief prosecutor’s prior representation of Defendant did not deprive the entire Lake County Attorney’s Office of authority to prosecute Defendant. View "State v. James" on Justia Law

The Supreme Court reversed the judgment of the district court granting summary judgment to Defendant, Plaintiff's former employer, on her wrongful discharge claims brought under the Montana Wrongful Discharge From Employment Act (WDEA), Mont. Code Ann. 39-2-905(1), holding that genuine issues of material fact remained.After Plaintiff was discharged from her employment she brought this action alleging that Defendant discharged her without good cause, as defined by Mont. Code Ann. 39-2-903(5), and in violation of Defendant's own personnel policy. The district court granted summary judgment to Defendant on the wrongful discharge claims on the ground that the damages elements of those claims failed as a matter of law because Plaintiff failed reasonably to mitigate her claimed damages by seeking comparable full-time employment after her discharge. The Supreme Court reversed, holding that the district court erred in granting summary judgment on the causation of damages element of Plaintiff's asserted wrongful discharge claims. View "Timpano v. Central Mont. District Six Human Resources Development Council, Inc." on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the judgment of the standing master amending the parties' parenting plan regarding their minor child, L.D.C., and the related standing master judgment denying Mother's subsequent motion to transfer jurisdiction to the Tribal Court of the Blackfeet Indian Tribe, holding that there was no error in the proceedings below.Mother and Father, members of the Blackfeet Indian Tribe, entered into a final parenting plan providing for them to co-equally parent L.D.C. The standing master later entered a written judgment amending the parties' parenting plan to place L.D.C. exclusively in Father's custody and care. Mother subsequently filed a state court motion for "transfer" of jurisdiction over the matter to the tribal court and a parallel child custody petition in the tribal court. The standing master denied both motions, and the district court affirmed. The Supreme Court affirmed, holding that the district court (1) had jurisdiction to amend the prior parenting plan; and (2) properly amended the prior parenting plan. View "In re Parenting of L.D.C." on Justia Law

The Supreme Court affirmed the sentencing order and judgment following Defendant's conviction of incest, holding that the district court did not err in excluding evidence of the complaining witness's prior statements regarding an alleged "false accusation" of sexual assault.After a jury trial, Defendant was convicted of incest and sentenced to imprisonment for a 100-year sentence. On appeal, Defendant argued that the district court erred when it excluded evidence of prior statements regarding an alleged "false accusation" of sexual assault made by K.O., the complaining witness. The Supreme Court affirmed, holding that the district court did not abuse its discretion by excluding evidence of K.O.'s statements regarding the prior statements at issue. View "State v. Hansen" on Justia Law

The Supreme Court affirmed the preliminary injunction entered by the district court enjoining Defendant from inhibiting Plaintiff's use of a disputed road over Defendant's property during the pendency of the proceedings to determine Plaintiff's rights, holding that there was no error or abuse of discretion.Plaintiff filed a complaint alleging that it had legal access to the disputed road and requested injunctive relief. After a hearing, the district court granted preliminary injunctive relief to Plaintiff enjoining Defendants from inhibiting Plaintiff's access to the road. Defendants appealed. The Supreme Court affirmed, holding that the district court did not obviously, evidently, or unmistakably abuse its discretion by granting preliminary injunctive relief in this case. View "Flying T Ranch, LLC v. Catlin Ranch, LP" on Justia Law

The Supreme Court answered a certified question that law enforcement officers do not, as a matter of Montana law, act outside the scope of their employment when they use their authority as on-duty officers to sexually assault a person they are investigating for a crime.L.B. brought this action under the Federal Tort Claims Act alleging that she was sexually assaulted by Bureau of Indian Affairs (BIA) Officer Dana Bullcoming after she called the police and reported that her mother was driving while intoxicated. The district court granted summary judgment for the Government, concluding that Officer Bullcoming was not acting outside the scope of his employment when he sexually assaulted L.B. because he was not acting in furtherance of his employer's interest. The The Ninth Circuit certified a question of law to the Supreme Court, which answered that, under Montana law, Officer Bullcoming's sexual assault of L.B. was within the scope of his employment as a law enforcement officer. View "L.B. v. United States" on Justia Law

The Supreme Court affirmed the order of the district court ruling in favor of Plaintiffs on cross-motions for summary judgment and enjoining the Montana Secretary of State from placing House Bill (HB) 325 on Montana's 2022 general election ballot, holding that the referendum proposal violates the Montana Constitution.In approved, HB 325 will establish seven Supreme Court districts in Montana and requires that Supreme Court justices be elected district by district, rather than statewide. Plaintiffs brought this challenge to the constitutionality of the measure. The district court granted summary judgment for Plaintiffs. The Supreme Court affirmed, holding (1) the district court did not err in determining that the question of the constitutionality of the referendum proposed by HB 325 is ripe for judicial resolution; and (2) the district court did not err in enjoining the Secretary from placing HB 325 on the ballot in the 2022 general election. View "McDonald v. Jacobsen" on Justia Law

The Supreme Court affirmed the order of the district court ruling in favor of Plaintiffs on cross-motions for summary judgment and enjoining the Montana Secretary of State from placing House Bill (HB) 325 on Montana's 2022 general election ballot, holding that the referendum proposal violates the Montana Constitution.If approved, HB 325 will establish seven Supreme Court districts in Montana and requires that Supreme Court justices be elected district by district, rather than statewide. Plaintiffs brought this challenge to the constitutionality of the measure. The district court granted summary judgment for Plaintiffs. The Supreme Court affirmed, holding (1) the district court did not err in determining that the question of the constitutionality of the referendum proposed by HB 325 is ripe for judicial resolution; and (2) the district court did not err in enjoining the Secretary from placing HB 325 on the ballot in the 2022 general election. View "McDonald v. Jacobsen" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Appellant of incest for the sexual abuse of T.N. and sentencing her to 100 years in prison, holding that there was no error or abuse of proceedings in the proceedings below.Specifically, the Supreme Court held (1) the district court did not violate Defendant's "right to access witnesses" in denying her motion to to conduct pretrial interviews with T.N. and J.M.; (2) the State's failure to lodge with the district court forensic interviews from a different case did not violate Defendant's right to a fair trial, and Defendant was not entitled to a new trial on this ground; and (3) based on the totality of the evidence, this Court declines to employ the doctrine of plain error to review Defendant's claim that the district court should have given a specific unanimity instruction. View "State v. Mathis" on Justia Law

The Supreme Court affirmed the district court's grant of a preliminary injunction temporarily enjoining the implementation of three laws the Legislature enacted in 2021 that regulate or restrict abortion services, holding that there was no error of law or manifest abuse of discretion.In 2021, the Montana Legislature passed into law and the governor signed into law bills regulating or restricting abortions services and providing for various criminal penalties and civil remedies. The district court granted a preliminary injunction, finding that Plaintiffs made a prima facie showing that the challenged laws violated their rights under the Montana Constitution and determining that Plaintiffs would suffer irreparable injury if the challenged laws took effect. The Supreme Court affirmed, holding that either ground on which the district court granted a preliminary injunction would have been sufficient to justify relief. View "Planned Parenthood of Montana v. State" on Justia Law