Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court dismissing Plaintiffs' legal malpractice action with prejudice, holding that the district court did not err.Plaintiffs filed this legal malpractice suit against Defendant, the law firm of their former attorney who represented them in a tort case involving a boating accident, for its failure to discover and make a claim against a homeowners insurance policy with a $500,000 policy limit. The court granted summary judgment to Defendant and dismissed Plaintiffs' complaint. The Supreme Court affirmed, holding that the district court (1) did not err in denying Plaintiffs' motion for partial summary judgment on the issue of whether an endorsement deleted the watercraft exclusion from the insurance policy; (2) did not err in granting summary judgment to Defendant on the issue of whether there was insurance coverage under the insurance policy for the boating accident and dismissing the legal malpractice claims; and (3) did not abuse its discretion in denying Plaintiffs' Rule 60(b) motion for relief from judgment. View "Young v. Hammer" on Justia Law

The Supreme Court affirmed in part and reversed in part the order and judgment issued by the district court following Defendant's convictions for sexual assault, three counts of sexual intercourse without consent, and sexual abuse of children, holding that the district court erred by misapplying Montana's rape shield statute, Mont. Code Ann. 45-5-511(2), and violated Defendant's constitutional confrontation rights.After the State charged Defendant with sexually assaulting I.A., a female minor, law enforcement received a tip that Cody Hill and I.A. were involved in an inappropriate sexual relationship. The State subsequently charged Hill was sexually abusing I.A. Defendant sought a motion to compel seeking confidential criminal justice information from the criminal file regarding Hill. The district court denied Defendant's motion to compel and convicted Defendant. The Supreme Court reversed in part, holding that the district court (1) did not abuse its discretion by not requiring the State to provide additional confidential criminal justice information from the Hill investigation; but (2) erred by misapplying the rape shield statute and violated Defendant's constitutional right to confront his accuser and present evidence in his defense by disallowing evidence that Hill abused I.A. in an identical manner less than two weeks before the incident at issue in this case. View "State v. Twardoski" on Justia Law

In this original proceeding, the Supreme Court held that a subpoena issued by the Chair of the Senate Judiciary Committee to Director Misty Ann Giles and the subpoena issued by the Senate president and Speaker of the House to Court Administrator Beth McLaughlin did not serve a valid legislative purpose, were permissibly overbroad and were therefore invalid.McLaughlin brought this proceeding seeking to quash and permanently enjoin the enforcement of successive subpoenas the Legislature issued first to the Director of the State Department of Administration and later to McLaughlin for the production of McLaughlin's emails between certain dates. The second subpoena also ordered production of McLaughlin's stated-owned telephones and computers used to facilitate polling of state judges. The Supreme Court granted the request, holding (1) the subpoenas in question were impermissibly overboard and exceeded the scope of legislative authority; and (2) if the Legislature subpoenas records from a state officer like the Court Administrator auxiliary to its legislative function, whether those records be in electronic or other form, a Montana court and not the Legislature must conduct any needed in camera review and balance competing security and privacy interests to determine whether records should be redacted prior to disclosure. View "McLaughlin v. Montana State Legislature" on Justia Law

The Supreme Court reversed the order of the district court granting relief to Melissa Lynn Fuller from the 2016 final decree of dissolution of the marriage of Melissa and Bradley Dean Fuller, holding that the district court erred in setting aside the final decree of dissolution on the ground of perjury under Mont. Code Ann. 40-4-253(5).The district court concluded that the failure to the parties to disclose their jointly owned business to the court, which they determined that they would settled after the divorce, violated the law requiring full disclosure of assets, debts, income, and expenses. The court granted Melissa's requested relief by raising sua sponte the issue of mutual perjury under section 40-4-253(5), concluding that significant nondisclosures in final declarations of marital assets are conditions that justified the court to reopen the final decree. The Supreme Court reversed, holding that because the parties chose not to include their jointly owned businesses in their disclosures, the district court erred by reopening the judgment on that basis. View "In re Marriage of Fuller" on Justia Law

The Supreme Court reversed the order of the district court holding that the Secret Gulch Road Easement was an easement in gross, vacating Plaintiffs' temporary restraining order, denying Plaintiffs injunctive relief, and awarding Defendants costs and attorney's fees, holding that the Secret Gulch Road Easement was appurtenant.Plaintiffs filed a complaint seeking a preliminary injunction order against Defendant. The district court denied the request, holding that the Secret Gulch Road Easement was in gross rather than appurtenant. The order awarded costs, damages and attorney's fees to Defendants. The Supreme Court reversed, holding (1) the district court erred in its determination that the Secret Gulch Road Easement was in gross because the easement was appurtenant; and (2) as such, Plaintiffs had the right to utilize the Secret Gulch Road Easement. View "Wilkinson, LLC v. Erler" on Justia Law

The Supreme Court reversed the judgment of the district court revoking the suspended portion of Appellant's sentence, holding that the district court did not err in denying Appellant's motion to dismiss for lack of subject matter jurisdiction.When Appellant was sixteen, the youth court found Appellant to be a delinquent youth, and Appellant received a juvenile disposition consisting of both a juvenile sentence and an adult sentence. After Appellant admitted to violations of the conditions of his sentence the judge implemented the adult sentence in modified form. The State later filed a second petition to revoke, and the judge revoked Appellant's deferred adult sentences and sentenced him to a term of incarceration. When Appellant was twenty-seven years old the State filed a third petition to revoke. Appellant filed a motion to dismiss, arguing that the youth court's jurisdiction over him ended when he reached the age of twenty-five and that the judge had not transferred the case to the district court. The judge denied the motion. The Supreme Court reversed, holding (1) the youth court lost jurisdiction over Appellant when he reached his twenty-fifth birthday and the case was not transferred to a district court; and (2) the lower court lacked jurisdiction and imposed an illegal sentence. View "In re S.G.-H.M. Jr." on Justia Law

In this road dispute, the Supreme Court affirmed the order of the district court granting summary judgment to Seiben Ranch Company, holding that the district court correctly concluded that Lyons Creek Road, traversing northwesterly beyond the gate installed by Sieben Ranch, was private.Sieben Ranch filed for declaratory and injunctive relief asserting that Defendants had no legal access over Sieben Ranch property via Lyons Creek Road. The district court granted summary judgment for Sieben Ranch. The Supreme Court affirmed, holding (1) the district court correctly concluded that Lyons Creek Road was a public highway up until Sieben Ranch's gate and properly granted summary judgment to Sieben Ranch; and (2) the district court correctly concluded that Defendants did not have an express easement to access Sieben Ranch's property. View "Sieben Ranch Co. v. Adams" on Justia Law

In this dispute regarding a $10.5 million loan from Comerica Bank to Masters Group International, Inc. and Masters' eventually default on that loan, the Supreme Court reversed the June 12, 2020 decision and order on attorney fees and affirmed the November 8, 2019 decision of the district court and the accompanying June 17, 2020 judgment, holding that the attorney fees award was in error.Specifically, the Supreme Court held (1) the district court's determination under Michigan law that Comerica breached the parties' forbearance agreement causing Masters to suffer contract damages was supported by substantial evidence; (2) the district court correctly found that Comerica did not affirmatively plead a defense of setoff or recoupment; (3) the district court's determination under Michigan law that Masters was entitled to prejudgment interest was legally correct; (4) because the parties' agreement did not provide for Masters to recover attorney fees and because Michigan did not have a reciprocal attorney fees statute, the district court erred by awarding Masters attorney fees; (5) Masters was not entitled under Michigan law to recover damages for lost profits or the lost value of a United Kingdom business; and (6) the district court did not err in limiting Masters' award of costs to the amount allowed by statute. View "Masters Group v. Comerica Bank" on Justia Law

The Supreme Court affirmed the judgment and commitment of the district court following Defendant's felony convictions of sexual intercourse without consent and sexual assault, holding that the district court did not commit reversible error by answering a question posed by the jury without consulting the parties.On appeal, Defendant argued (1) he received ineffective assistance of counsel; (2) the Court should exercise plain error review regarding his claims about expert testimony undermining his presumption of innocence; and (3) the district court erred by answering a jury question during deliberation without consulting the parties. The Supreme Court affirmed, holding (1) this Court declines to consider Defendant's ineffective assistance of counsel claim on direct appeal; (2) this Court declines to exercise plain error review regarding Defendant's claims about expert witness testimony; and (3) the district court did not commit reversible error by answering the jury's question without consulting the parties. View "State v. Sinz" on Justia Law

The Supreme Court affirmed the judgment of the district court affirming Defendant's judgment of conviction on the offense of criminal possession of drug paraphernalia, holding that the justice court did not illegally impose a ten-day jail term as a condition of a deferred imposition of sentence.Defendant was found guilty of criminal possession of drug paraphernalia, as charged. The court deferred imposition of sentence for a period of six months subject to the conditions that Defendant pay a $350 fine and various statutory surcharges, complete twenty hours of community service, and serve ten days in the county jail. On appeal, Defendant argued that the jail-time condition was an illegal condition of a deferred sentence, in violation of Mont. Code Ann. 45-10-103. The district court affirmed. The Supreme Court affirmed, holding that the justice court did not erroneously impose ten days of jail time as a condition of Defendant's deferred imposition of sentence. View "State v. Thibeault" on Justia Law