Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court dismissing this action for breach of contract and declaratory judgment and declining to award attorney fees to either party, holding that the district court did not err.The owners of certain condominium units brought this action against the condominium owner after the developer unilaterally amended the condominium declaration to create a new homeowners' association to which new unit owners would belong, thus leaving existing unit owners in the original homeowners' association. The developer subsequently revoked the amendment to the declaration. The district court dismissed the case as moot. The court then refused to award attorney fees, ruling that neither party was a prevailing party. The Supreme Court affirmed, holding that the district court did not err in dismissing the case as moot and did not err in refusing to award attorney fees and costs. View "Heringer v. Barnegat Development Group, LLC" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of the Montana Republican Party and denying the motion for summary judgment filed by the Commissioner of Political Practices (COPP) in this campaign finance complaint, holding that the district court did not err in determining that COPP lacked authority to issue a subpoena for production of documents.The Montana Democratic Party filed a campaign finance complaint with COPP alleging that the Montana Republican Party had failed to comply with statutory reporting and disclosure requirements. As part of its investigation, COPP issued a subpoena for production of documents, commanding the Republican Party to produce specified documents relating to campaign practices and expenditures. COPP issued the subpoena pursuant to the authority of Mont. Code Ann. 13-37-111. The district court granted summary judgment to the Republican Party, concluding that section 13-37-111 did not confer COPP with the authority to issue subpoenas for documents. The Supreme Court affirmed, holding that the district court did not err. View "Commissioner of Political Practices v. Republican Party" on Justia Law

The Supreme Court affirmed Defendant's convictions for three felony counts of privacy in communications, in violation of Mont. Code Ann. 45-8-213(1)(a), holding that there were no prejudicial errors in the proceedings below.Specifically, the Supreme Court held (1) the Privacy in Communications statute, Mont. Code Ann. 45-8-213(1)(a), is not facially overbroad, nor does it constitute a content-based restriction on speech in violation of the "freedom of speech" clauses of the Montana and United States Constitutions; (2) the district court correctly interpreted the Privacy in Communications statute; (3) there was insufficient evidence to conclude that there was jurisdiction when the threatening communication was made to a person located outside of Montana; and (4) the district court fully and fairly instructed the jury in accordance with the charges and evidence presented. View "State v. Lamoureux" on Justia Law

The Supreme Court affirmed in part and reversed in part the district court's judgment compelling Plaintiffs to survey a roadway easement adjudicated by a previous declaratory judgment in 2016 and denying their motion for clarification, holding that the court erred in failing to clarify the 2016 judgment and subject easement on the motion for clarification.In this long-running dispute over a private roadway, Plaintiffs challenged a district court order compelling them to survey a roadway easement adjudicated in 2016 by declaratory judgment, denying their motion for clarification of a subsequently discovered ambiguity between the metes and bounds description and accompanying map depiction of an easement in the underlying 1987 grant, and rescinding prior awards of attorney fees and costs. The Supreme Court reversed in part, holding that the district court erroneously failed to construe the 1987 stipulation, 2016 judgment, and resulting law of the case and thus erred in failing to clarify the 2016 judgment and subject easement on Plaintiffs' motion for clarification. View "VanBuskirk v. Gehlen" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that Erik Miller was justified when he used deadly force against Nicholas Tyson Frazier, holding that the district court did not err or abuse its discretion.Frazier, who was suicidal, was shot by Miller, a police officer, in his home after he pointed his gun at the Miller. The Estate brought this complaint against Miller alleging assault, wrongful death, negligence, and a violation of Frazier's rights under the Montana Constitution. The district court entered judgment in favor of Miller, holding that Miller's use of force was justified. The Supreme Court affirmed, holding (1) the district court did not err by refusing to submit a separate constitutional tort theory to the jury; (2) the special verdict form clearly and fairly presented the jury with the ultimate questions of fact; and (3) the district court did not abuse its discretion by failing to record all sidebar discussions of evidentiary objections. View "Estate of Frazier v. Miller" on Justia Law

The Supreme Court affirmed the order of the district court awarding temporary guardianship of Carol Merideth's two stepchildren to their maternal grandparents, Diana and Kenneth Merideth, holding that the district court did not err.After the children's father died, Diana and Kenneth filed a petition for guardianship and requesting an emergency order for temporary guardianship. The district court appointed Diana and Kenneth temporary guardians. That same day, Carol filed a petition seeking temporary guardianship and conservatorship. The district court entered an order appointing temporary guardians and conservators, determining it was in the children's best interests to appoint Diana and Kenneth as their temporary guardians and conservators. The Supreme Court affirmed, holding that because the children's mother consented to appointment of Diana and Kenneth and the district court found that the appointment was in the children's best interests the district court did not abuse its discretion. View "In re Guardianship of J.S.M." on Justia Law

The Supreme Court reversed the orders of the district court lifting its stay of execution of Defendant's sentence during his appeal and re-imposing the sentence, holding that the district court lacked the authority to impose the sentence after the State's delay in seeking to execute the sentence.The district court convicted Defendant for a first offense driving under the influence (DUI) conviction and sentenced him to six months with all but twenty-four hours suspended. The court stayed execution of the sentencing during Defendant's appeal. When Defendant's conviction was affirmed, the district court issued notice of remittitur to the parties. Eight months later, the State moved to lift the stay and require Defendant to serve his sentence. The district court granted the motion. The Supreme Court affirmed, holding (1) Defendant's sentence expired before the State sought to enforce its terms and conditions, and therefore, the State could no longer execute the terms of the sentence; and (2) the district court correctly convicted Defendant of DUI. View "State v. Nelson" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of Western Montana Community Health Center (WMMHC) and dismissing Plaintiff's claim brought under the Wrongful Discharge from Employment Act (WDEA), Mont. Code Ann. 39-2-901 - 915, holding that the district court's grant of summary judgment was not an abuse of discretion.Specifically, the Supreme Court held (1) WMMHC satisfied its burden to demonstrate that it had legitimate business reasons constituting good cause for terminating Plaintiff as program manager; (2) Plaintiff failed to meet her burden of demonstrating that the reason for the termination was false or arbitrary; and (3) WMMHC met its burden of demonstrating that it did not violate the express provisions of its written personnel policies. View "Buckley v. Western Community Mental Health Center" on Justia Law

The Supreme Court reversed the sentence imposed on Defendant after she was convicted for criminal possession of dangerous drugs (CPDD) and criminal possession of drug paraphernalia (CPDP), holding that the district court abused its discretion in sentencing Defendant.The district court sentenced Defendant to four years with the Montana Department of Corrections (DOC), all for years suspended for the CPDD conviction. On appeal, Defendant argued that the district court erred by sentencing her to a suspended sentence after determining that the State presented sufficient evidence to overcome the presumption in favor of a deferred sentence under Mont. Code Ann. 49-9-102(4). The Supreme Court agreed and remanded for resentencing, holding that the district court erred by sentencing Defendant to a four-year suspended sentence instead of deferring imposition of sentence. View "State v. Doubek" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that a Fergus County road was private because Public Land/Water Access Association, Inc. (PLWA) had not proven the existence of a public road by prescriptive easement or petition, holding that the district court did not err.Specifically, the Supreme Court held (1) the district court applied the correct legal standard for its review, the "record as a whole" standard set forth in Reid v. Park County, 627 P.2d 1210 (Mont. 1981); and (2) the district did not err in concluding that the disputed road was not a public road either by prescriptive easement or statutory methods. View "Public Land & Water Access Ass'n v. Robbins" on Justia Law