Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court granting motions to dismiss filed by Farmers Insurance Exchange and State Farm Fire and Casualty Company, holding that the district court did not err in granting the motions to dismiss.Plaintiffs filed a complaint against State Farm and Farmers alleging, among other claims, common law bad faith and violation of the Unfair Trade Practices Act. The insurers filed motions to dismiss. The district court granted the motions to dismiss. The Supreme Court affirmed, holding that the district court did not err in dismissing Plaintiffs' bad faith claims on the basis that the liability of State Farm and Farmers was not reasonably clear. View "Shepard v. Farmers Insurance Exchange" on Justia Law

The Supreme Court affirmed the ruling of the district court that the Montana Board of Pardons and Parole did not violate Appellant's statutory or constitutional rights in denying Appellant's parole request, holding that the district court did not err.Appellant sought judicial review of the Board's decision, claiming that the Board denied him his right to know, right to participate, or right to due process when it denied him parole without first furnishing him a copy of documents on which the Board relied in making its decision. Appellant further argued that the Board unlawfully relied on a guideline without having adopted it as an administrative rule pursuant to the Montana Administrative Procedure Act. The district court granted summary judgment for the Board. The Supreme Court affirmed, holding (1) where the guideline was not the reason for the Board's decision, Appellant could not demonstrated the likelihood of a different outcome; and (2) the Board did not violate Appellant's right to know, right to participate, or due process rights. View "Miller v. Montana Board of Pardons & Parole" on Justia Law

The Supreme Court affirmed the ruling of the Workers' Compensation Court that Mont. Code Ann. 39-71-703(2) did not violate Appellant's right to equal protection by denying an impairment award to a worker with a Class 1 impairment who has suffered no wage loss, holding that the statute passes rational basis muster under the Equal Protection Clause of the Montana Constitution.Section 39-71-703(2) allows impairment awards for claimants without actual wage loss only if they have a Class 2 or higher impairment rating. Appellant, who was designated as Class 1 and was denied an impairment award, challenged the statute, arguing that it violated her constitutional right to equal protection because other workers with different injuries but the same whole-person impairment percentage would receive the award. The WCC denied the challenge. The Supreme Court affirmed, holding that the WCC did not err in its determination that section 39-71-703(2) did not violate the Equal Protection Clause. View "Hensley v. Montana State Fund" on Justia Law

The Supreme Court affirmed the order of the district court providing for the dissolution of the Johns Brothers Farms partnership, accounting of the partners' capital accounts, and settlement and distribution of partnership assets, holding that the district court did not err.Brothers Jerry Johns and Jule Nathan "Butch" Johns began farming together as a partnership in 1980. In 1994, the brothers each formed a corporation to hold their individual interests, and the corporations became the partners in Johns Brothers Farms. In 2013, the brothers agreed to dissolve the partnership and distribute the assets between the partners. The next year, Jerry commenced this action to dissolve Johns Brothers Farms, for settlement of capital accounts, and for distribution of partnership assets. In 2020, the district court issued its findings of fact, conclusions of law, and judgment. Butch appealed. The Supreme Court affirmed, holding that the district court (1) did not err by concluding that Jerry did not breach his fiduciary duty to Butch and the partnership; (2) did not err in its calculation of the capital account balances for Jerry and Butch; and (3) did not err by awarding Jerry the forty-acre parcel in its distribution of partnership assets. View "Jackpot Farms, Inc. v. Johns Farms, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated sexual intercourse without consent, holding that the district court did not abuse its discretion in failing to find Defendant's concerns of ineffective assistance of counsel "seemingly substantial" or by declining to grant a trial continuance.On appeal, Defendant argued that the district court abused its discretion by (1) denying his request for a continuance of the jury trial, and (2) failing to open a formal inquiry into the effectiveness of counsel following Defendant's pretrial expressions of lack of confidence. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by declining to grant Defendant's request for a continuance before trial; and (2) even if Defendant's lack of confidence did constitute a request for substitute counsel, the district court's response was an adequate initial inquiry to determine whether Defendant's concerns were "seemingly substantial." View "State v. Dillingham" on Justia Law

The Supreme Court affirmed the order of the district court denying Defendant's motion to dismiss the charge of vehicular homicide while under the influence, holding that Mont. Code Ann. 61-8-411 does not violate either the substantive due process or equal protection guarantees of the state and federal constitutions.Defendant filed a motion to dismiss the charges, arguing that section 61-8-411 was facially unconstitutional as a violation of his substantive due process rights. The district court denied the motion to dismiss. On appeal, Defendant argued that the legislature could have made a more scientifically based policy choice to keep drivers impaired by THC off the road and that the statute unconstitutionally creates classifications. The Supreme Court affirmed, holding that Mont. Code Ann. 61-8-411 is rationally related to the government's compelling interest in keeping drug-impaired drivers off the road. View "State v. Jensen" on Justia Law

The Supreme Court affirmed in part and reversed in part the district court's dismissal of Mark Plakorus's claims against the University of Montana, holding that Plakorus's amended complaint was sufficient to state tort claims for defamation and intentional interference but that the district court properly dismissed the remaining claims.The University employed Plakorus under contract as head coach of the women's soccer team. This case arose from the University's refusal to renew Plakorus's contract after finding on Plakorus's phone records alleged private contacts with Las Vegas escort services. In his complaint, Plakorus claimed that the University unlawfully disclosed confidential information from his personnel file, violated his privacy rights, defamed him, and interfered with his future business prospects. The district court granted the University's motion to dismiss, concluding that Plakorus's tort claims arose from the employment contract and were barred by the one-year statute of limitations under Mont. Code Ann. 18-1-402(2). The Supreme Court reversed in part, holding (1) the district court erred in concluding that the duties underlying all of Plakorus's claims arose solely under the contract, and the state tort claims for defamation and intentional interference survived the State's motion to dismiss; and (2) the district court correctly dismissed the remaining claims as time barred. View "Plakorus v. University of Montana" on Justia Law

The Supreme Court affirmed in part and reversed in part the district court's ruling granting summary judgment to Park County Environmental Council and Greater Yellowstone Coalition and an order of vacatur of the challenged exploration license in this case, holding that the district court erred in part.Lucky Minerals, Inc. submitted an exploration application seeking authorization to conduct exploration activities within its privately-owned patented mine claim block. The Montana Department of Environmental Quality granted the exploration license. The district court voided Lucky's exploration license, concluding that the 2011 Montana Environmental Policy Act amendments were unconstitutional. The Supreme Court affirmed in part and reversed in part, holding that the district court did not err by vacating the exploration license and finding Mont. Code Ann. 75-1-206(6)(c) and (d) in violation of the Legislature's constitutional mandate to provide remedies adequate to prevent proscribed environmental harms under Mont. Const. Art. II, 3 and IX, 1. View "Park County Environmental Council v. Montana Department of Environmental Quality" on Justia Law

The Supreme Court affirmed the ruling of the district court determining that Brown Drake, LLC's operation of the Brown Drake Lodge did not violate the Craig Tracts Homeowners' Association's (HOA) amended covenant's requirement that the property be "used for residential purposes only," holding that the district court did not err.The HOA brought this action for injunctive and declaratory relief, alleging that Brown Drake's operation of the Lodge violated the amended covenants' requirement that property be used for residential purposes only. The district court ruled in favor of Brown Drake. The Supreme Court affirmed, holding that Brown Drake's operation of the Lodge did not violate the amendment covenants under the HOA. View "Craig Tracts Homeowners' Ass'n v. Brown Drake, LLC" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of solicitation of witness tampering and sentencing him to prison for ten years with four years suspended, holding that the district court made numerous errors during trial amounting to cumulative error requiring reversal.Specifically, the Supreme Court held that Defendant's conviction resulted, at least in part, from the prejudice of the irrelevant and extrinsic bad acts evidence erroneously admitted from void dire through the entire evidentiary presentation and that Defendant did not receive a fair trial as a result of the district court's erroneous rulings, mandating reversal of Defendant's conviction under the doctrine of cumulative error. View "State v. Smith" on Justia Law