Justia Montana Supreme Court Opinion Summaries

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

The Supreme Court affirmed the order of the district court affirming the decision of the Stillwater Board of County Commissioners to abandon a portion of Eerie Drive, holding that the district court did not err in concluding that substantial evidence supported the Board's decision.Specifically, the Supreme Court held (1) the district court did not err in limiting its review of the record to whether there was sufficient evidence that the Board exceeded its jurisdiction to justify intruding on the Board's inherent discretion regarding road abandonment decisions; and (2) the district court did not err in concluding that the Board adequately documented its decision, as required by the statutes governing county road abandonment and caselaw. View "Williams v. Stillwater Board of County Commissioners" on Justia Law

The Supreme Court affirmed the judgment of the district court holding that the "resort service fee" that Boyne USA, Inc. charges guests is not subject to Montana's lodging facilities use tax and forfeited guests deposits collected by Boyne are not subject to either the state use tax or sales tax, holding that the district court did not err.Specifically, the Supreme Court held that the district court (1) did not err in holding that Boyne's resort services fee was not subject to the lodging facilities use tax; (2) did not err in holding that the resort services fee was subject to the sales tax; and (3) did not err by holding that forfeited guest deposits are not subject to the lodging facilities use tax or the sales tax. View "Boyne USA, Inc. v. Department of Revenue" on Justia Law

The Supreme Court affirmed the order of the district court affirming Defendant's jury conviction for driving with a blood alcohol concentration exceeding the legal limit, holding that Defendant was denied his confrontation rights.On appeal, Defendant challenged the denial of his motion to suppress evidence stemming from the stop of the vehicle and argued that the justice court improperly allowed a State witness to appear by two-way video at trial. The Supreme Court (1) affirmed the denial of Defendant's motion to suppress, holding that the trooper lawfully stopped and detained Defendant; and (2) reversed Defendant's conviction, holding that the justice court violated Defendant's right to confrontation when it allowed Defendant to testify via two-way video. View "State v. Bailey" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the district court sentencing Plaintiff to pay restitution to the Montana State Fund (MSF) for benefits it paid to a sergeant from the Gallatin County Detention Center related to an on-the-job injury, holding that the district court failed to appropriately apply Mont. Code Ann. 46-18-246 to conclude it would otherwise be unjust to require Defendant to pay the restitution imposed.Defendant was charged with felony assault on a peace officer for her actions in striking the sergeant after the sergeant requested that Defendant sit down while waiting for an initial appearance in court. Defendant pleaded guilty to misdemeanor assault. In sentencing Defendant, the district court concluded that MSF qualified as a victim and was thus entitled to restitution. The Supreme Court affirmed, holding that the district court (1) correctly concluded the MSF was an insurer victim entitled to restitution for pecuniary loss; and (2) erred by failing to adjust or otherwise waive payment by Defendant of the restitution ordered. View "State v. Lodahl" on Justia Law

The Supreme Court reversed an order of the district court affirming an administrative law judge's proposed order that trust principal consisting of a jointly owned home constituted a countable asset for the purpose of the Medicaid eligibility of Marilyn Scheidecker, holding that there were no circumstances under which payment from the trust's corpus could be made for Marilyn's benefit.The Montana Department of Public Health and Human Services denied Marilyn's application for Medicaid, concluding that Marilyn's one-half interest in the trust's principal was a countable resource placing her over Medicaid's resource limit. The ALJ upheld the denial. The district court affirmed the ALJ's ultimate conclusion that the trust was a countable asset pursuant to 42 U.S.C. 1396p(d)(3), holding that circumstances existed by which payments form the trust's corpus could be made to or for Marilyn's benefit. The Supreme Court reversed, holding that the district court was incorrect in its application of the federal statute. View "Estate of Scheidecker v. Montana Department of Public Health & Human Services" on Justia Law

In this property dispute, the Supreme Court affirmed the summary judgment order entered by the district court in favor of Old Public National Title Insurance Company and Security Title and Abstract Company (collectively, Defendants) upon the parties' stipulated "threshold legal issue" regarding Defendants' duty to Plaintiffs, holding that the district court did not err.At issue was whether Defendants owed a legal duty arising out of their issuance of a preliminary title commitment. Plaintiffs filed this action alleging negligence, professional negligence, and negligent misrepresentation on the part of Defendants when conducting a title examination. The district court concluded that Plaintiffs' claims were foreclosed because the statutes governing the issuance of a title insurance policy did not impose a duty with respect to an offer of title insurance in a preliminary commitment. The Supreme Court affirmed, holding that Plaintiffs' claims could not be sustained. View "Phipps v. Old Republic National Title Insurance Co." on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's motion to suppress his text message conversation with an undercover federal agent and to dismiss the charge of patronizing prostitution, holding that the district court did not err.From his cell phone, Defendant responded to an ad placed in a warrantless internet sting operation. Thereafter, Defendant engaged in a text message conversation with "Lily," an undercover law enforcement officer. Defendant was subsequently charged with patronizing prostitution, a misdemeanor. Defendant filed a motion to suppress his text conversation with "Lily" and for dismissal of the case due to a lack of evidence. The district court denied the motions, and Defendant entered a conditional guilty plea. The Supreme Court affirmed, holding that the warrantless use of a cloaked law enforcement officer under a fake internet advertisement for sexual services and the responsive text message conversation did not intrude upon an objectively reasonable expectation of privacy and therefore did not effect a constitutional search in violation of Defendant's right to privacy under Mont. Const. art. II, 10-11. View "State v. Staker" on Justia Law

In this original proceeding, the Supreme Court granted the petition for writ and assumed original jurisdiction over Petitioners' constitutional challenge and then held that Senate Bill 140 (SB 140 does not violate Mont. Const. art. VII, 8(2).SB 140 was passed by the 2021 Montana Legislature and signed into law by the Governor. The bill abolished Montana's Judicial Nomination Commission and the previous process to screen applicants for vacancies on the Supreme Court and the District Courts. Petitioners brought this proceeding challenging the constitutionality of SB 140. The Supreme Court held (1) Petitioners had standing to challenge the constitutionality of SB 140; (2) urgent or emergency factors justified an original proceeding in this Court; and (3) SB 140 does not violate Article VII, Section 8(2). View "Brown v. Gianforte" on Justia Law