Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of sexual intercourse without consent, tampering with witnesses and informants, privacy in communications, and stalking, holding that there was no prejudicial error in the proceedings below.At issue on appeal was whether the district court abused its discretion by allowing the State to file a third amended information in the middle of trial and whether the district court's jury instruction on consent warranted reversal for plain error. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it allowed the State to file its third amended information mid-trial; and (2) the district court did not abuse its discretion in instructing the jury on consent. View "State v. Lafournaise" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of Depositors Insurance Company in its declaratory judgment action to determine any obligation it had relative to Patrick Sandidge pursuant to Ridley v. Guaranty National Insurance Co., 951 P.2d 987 (Mont. 1997), holding that the district court did not err.Specifically, the Supreme Court held that the district court (1) did not err by holding a hearing on the parties' cross-motions for summary judgment; (2) did not err by holding that Depositors had standing to bring a declaratory action pursuant to Ridley; (3) did not err by granting Depositors' motion for summary judgment; and (4) did not abuse its discretion by denying Sandidge attorney fees and costs. View "Depositors Insurance Co. v. Sandidge" on Justia Law

The Supreme Court affirmed the orders of the district court denying the motion for judgment on the pleadings filed by the Associated Press and other news reporting outlets (collectively, the AP) and granting a motion to dismiss filed by Barry Usher, holding that the district court did not err.During the state's biennial legislative session in 2021, Usher, who was the Chair of the Judiciary Committee of the Montana House of Representatives, and other Republican members of the Committee met privately to discuss pending legislation. Because Usher denied the AP access to the gathering, the AP brought this lawsuit, seeking a declaratory judgment that this denial of access was a constitutional violation. The district court granted Usher's motion to dismiss, concluding that the gathering was controlled by the open meeting statute, Mont. Code Ann. 2-3-202, and that applying the statute in this case did not violate the AP's Mont. Const. art. II, 9 right to access a gathering of Judiciary Committee members. The Supreme Court affirmed, holding that the district court did not err in applying the statutory definition of a "meeting" to the AP's constitutional right to access a gathering of Judiciary Committee members. View "Associated Press v. Usher" on Justia Law

The Supreme Court reversed the judgment of the district court finding Defendant guilty of attempted deliberate homicide and sentencing him to serve an eighty-year prison term with no time suspended, holding that the district court prejudicially erred in one of its evidentiary rulings.On appeal, Defendant argued that the district court abused its discretion by allowing the State to reference and elicit testimony regarding Defendant's prior child sex abuse comments and references in an explicit and repetitive manner. The Supreme Court agreed and remanded this case for a new trial, holding that the district court (1) did not abuse its discretion in denying Defendant's motion in liming to categorically exclude all references to Defendant's prior child sexual abuse comments and references; but (2) erred by failing to carefully limit the subject prior bad acts evidence to avoid its manifestly inherent risk of unfair prejudice. View "State v. Lake" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Yellowstone Disposal, LLC's petition for writ of mandamus, holding that the district court did not err.Yellowstone Disposal filed a petition for writ of mandamus to compel the Montana Department of Environmental Quality (DEQ) to issue a license or, in the alternative, issue a final decision approving or denying its application for a class II solid waste management systems (SWMS) license to operate a SWMS in Richland County. The district court granted DEQ's motion to dismiss the petition for failure to state a claim. The Supreme Court affirmed, holding that Yellowstone Disposal did not satisfy the requirements for issuance of a writ of mandamus. View "Yellowstone Disposal, LLC v. State, Department of Environmental Quality" on Justia Law

The Supreme Court affirmed the order of the district court terminating Mother's parental rights to her son, C.K., holding that the district court did not abuse its discretion when it failed to amend Mother's treatment plan or when it determined that Mother was unlikely to change within a reasonable time.After a termination hearing, the district court terminated Mother's parental rights pursuant to Mont. Code Ann. 41-3-609(1)(f). On appeal, Mother argued, among other things, that the district court abused its discretion when it failed to amend her treatment plan to enumerate specific parenting tasks related to raising a child with autism and to provide for related services. The Supreme Court affirmed, holding that the district court did not abuse its discretion (1) in refusing to amend Mother's treatment plan on the day of the termination hearing; and (2) in finding that Mother was unlikely to change in a reasonable time. View "In re C.K." on Justia Law

In this medical malpractice action arising from a circumcision, the Supreme Court affirmed the order of the district court precluding Plaintiff from presenting evidence as to either using incorrect scissors or incorrect use of scissors during the subject surgical procedure, holding that the court did not err.Plaintiff, for the benefit of her son, brought this action against Defendant, alleging that Defendant was negligent in performing her son's circumcision. The district court entered judgment in favor of Defendant. The Supreme Court affirmed the district court's evidentiary rulings and the subsequent defense verdict, holding that the district court did not abuse its discretion in excluding portions of Plaintiff's expert's testimony not disclosed in accordance with Mont. R. Civ. P. 26 and the scheduling order. View "Higgins v. Augustine" on Justia Law

The Supreme Court reversed Defendant's conviction for sexual intercourse without consent, a felony, and affirmed his remaining convictions for aggravated kidnapping and assault with a weapon, holding that defense counsel's deficient performance undermined this Court's confidence in the outcome of the proceedings as it pertained to Defendant's conviction for sexual intercourse without consent.At issue on appeal was whether Defendant received ineffective assistance of counsel when his attorney failed to object to expert testimony on the statistical likelihood that Defendant's accuser was lying. The Supreme Court held that while the testimony may have improperly bolstered the complaining witness's testimony regarding the element of consent as to the sexual intercourse without consent charge it had no bearing on the kidnapping and assault with a knife charges. View "State v. Quiroz" on Justia Law

The Supreme Court affirmed the order of the Water Court that adjudicated the priority dates for certain of its water rights in Basin 40B in Petroleum County, holding that the Water Court did not err.Specifically, the Supreme Court held that the Water Court (1) did not err in concluding that the water rights to much of the irrigated acreage owned by Twin Creeks Farm & Ranch had been abandoned been the initial claimed priority date of 1903 and later irrigation development around 1968; and (2) was correct to grant Twin Creeks an implied claim with a 1968 priority date rather than tying the later irrigated acreage to the original 1903 claim. View "Twin Creeks Farm & Ranch, LLC v. Petrolia Irrigation District" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of nine counts of assault on a minor and one count of perjury, holding that sufficient evidence existed to support Defendant's conviction for perjury and that the district court did not err in denying Defendant's motion to dismiss due to a speedy trial violation.Specifically, the Supreme Court held (1) viewing the light most favorable to the State, a rational trier of fact could have found the essential elements of perjury beyond a reasonable doubt based on Defendant's testimony, a jail phone call made by Defendant, and trial testimony; and (2) the district court did not err in concluding that the State did not violate Defendant's right to a speedy trial. View "State v. Burnett" on Justia Law