Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court determining that Montana law applied to the wrongful death action brought by Nicole Buckles on behalf of the estate her deceased son, Zachary Scott Buckles, whose death occurred in the State of North Dakota, holding that the district court did not err.Zachary died of exposure to high levels of hydrocarbon vapors while working on Continental Resources, Inc.'s well site located near Alexander, North Dakota. Buckles, acting as personal representative of Zachary's estate, filed a wrongful death action against Continental and other entities in a Montana district court. Two defendants filed a motion for declaration of applicable law requesting that the district court apply North Dakota substantive law to Buckles' claims. The district court denied the motion, determining that Montana law applied. The Supreme Court affirmed, holding that the district court did not clearly err in concluding that although the injury occurred outside of Montana, Montana had the most significant relationship to this litigation. View "Buckles v. BH Flowtest, Inc." on Justia Law

The Supreme Court affirmed the district court's vacatur of the Montana Department of Environmental Quality's (DEQ) 2017 issuance of Montana Pollution Discharge Elimination System (MPDES) permit to Montanore Minerals Corp. (MMC), holding that the DEQ unlawfully relied upon a 1992 order of the Board of Health and Environmental Sciences (BHES) when issuing the 2017 permit.Specifically, the Supreme Court held (1) the district court correctly concluded that the 1992 BHES order expired prior to DEQ issuing the 2017 permit; and (2) because DEQ relied upon an expired BHES order when it issued the 2017 permit, the permit was not validly issued and must be vacated. View "Montana Environmental Information Center v. Montana Department of Environmental Quality" on Justia Law

The Supreme Court affirmed Defendant's conviction for aggravated promotion of prostitution of B.M. and promoting prostitution of Z.T., holding that the district court did not abuse its discretion.On appeal, Defendant argued that the district court erred in granting the State's motion in limine prohibiting Defendant from eliciting any testimony concerning B.M. and/or Z.T.'s prior sexual conduct. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it excluded evidence related to Z.T.'s prior involvement with prostitution under Mont. R. Evid. 401, 402, and 404(b). View "State v. Thomas" on Justia Law

The Supreme Court reversed the judgment of the district court interpreting and modifying a prior 2014 judgment that previously adjudicated that Plaintiffs had established various prescriptive easement rights over certain land before Defendants acquired it in the 1980s, holding that the court misinterpreted the 2014 judgment.Specifically, the Supreme Court held (1) the district court did not err when it concluded that Mont. R. Civ. P. 59-60 did not apply to Defendants' motions for subsequent interpretation and clarification of the 2014 judgment; (2) the district court erred when it construed the 2014 judgment as ambiguous on its face or in effect; and (3) the district court erroneously altered and amended the substance of the 2014 judgment inconsistent with its manifestly intended original meaning and effect. View "Meine v. Hren Ranches, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction for felony theft, felony altering an identification number, and misdemeanor violation of license plate requirement, holding that the district court did not err.Specifically, the Supreme Court held (1) the district court did not err in denying Defendant's motion to dismiss based on the state's alleged failure to preserve exculpatory evidence; (2) the district court did not err when it allowed an out-of-court statement offered for the limited purpose of explaining an officer's conduct; and (3) after correctly instructing the jury, the district court did not abuse its discretion in referring the jury to instructions already provided. View "State v. Fillion" on Justia Law

In this case involving a grant of easement and easement agreement between Roger Peters and Carrie Peters and Douglas Hubbards and Nathan Hubbards the Supreme Court affirmed the judgment of the district court granting summary judgment in favor of the Peterses, holding that the district court did not err or abuse its discretion.The easement agreement in this case granted the Hubbards an easement to use a road crossing the Peterses' land. The Peterses later rescinded the agreement, but the Hubbards continued to use the road. The Peterses subsequently filed a declaratory judgment action seeking a declaration that the rescission was proper and that the Hubbards' rights under the agreement were terminated. The Hubbards filed a counterclaim asserting claims for a private prescriptive easement and a public prescriptive easement. The district court granted summary judgment for the Peterses on all issues. The Supreme Court affirmed, holding (1) the district court did not err in interpreting the language of the easement agreement; (2) the Hubbards did not establish either a private or public prescriptive easement across the Peterses' property covered in the easement agreement; and (3) the district court properly awarded attorney fees to the Peterses. View "Peters v. Hubbard" on Justia Law

The Supreme Court affirmed the order of the district court denying Griz One Firefighting, LLC's petition for judicial review of a default order and determination by the Department of Labor and Industry Wage and Hour Division (DLI) and awarding Matthew Sean West $11,241 in back wages, penalties, costs, and attorney fees, holding that the district court did not err.Specifically, the Supreme Court held (1) the district court did not clearly err when it concluded that DLI notified Griz One of West's wage claim; (2) Griz One was not entitled to relief on its due process and jurisdictional arguments; (3) the district court was correct in concluding that Mont. R. Evid. 605 does not apply to a DLI compliance specialist; and (4) the district court's award of attorney fees and costs to West was reasonable and based on competent evidence. The Supreme Court remanded the matter to the district court for a determination of West's costs and fees on appeal. View "Griz One Firefighting v. State Department of Labor & Industry" on Justia Law

The Supreme Court affirmed the order of the district court revoking Defendant's deferred sentence for criminal endangerment, holding that the district court did not abuse its discretion by revoking Defendant's deferred sentence after he failed to report to his probation officer for five months.Defendant pleaded guilty to criminal endangerment. The district court sentenced Defendant to five years' incarceration, with all time suspended, and imposed standard conditions of probation. The State later filed a petition to revoke Defendant's sentence, alleging that Defendant violated four conditions of his suspended sentence. The district court found that Defendant committed the violations alleged in the State's petition to revoke and imposed a five-year commitment with two years suspended. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it revoked Defendant's deferred sentence. View "State v. Fjelsted" on Justia Law

The Supreme Court affirmed the revocation of his suspended sentence by the district court, holding that the district court's sentence revocation was supported by sufficient evidence that Defendant had violated the conditions of supervision by engaging in a new criminal offense.Defendant pled guilty to aggravated assault and endangering the welfare of a child. After completing the unsuspended portion of his sentence Defendant was released to serve the suspended portion of his sentence. Later, the county attorney filed a petition for revocation of Defendant's suspended sentence, alleging that Defendant had violated a condition of probation. The district court found by a preponderance of the evidence that Defendant had committed non-compliance violations of the probationary conditions of his sentence. The court then revoked Defendant's sentence and resentenced him. The Supreme Court affirmed, holding that the district court did not err by determining that Defendant violated a sentencing condition by committing sexual abuse of children. View "State v. Howard" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing K&J Investments, LLC's petition and complaint for judicial review, rescission, and unjust enrichment against the Flathead County Board of Commissioners and Flathead County Treasurer, holding that the district court properly dismissed all claims for want of jurisdiction.K&J, an investment company, purchased a tax sale certificate from Flathead County for the property at issue for $1,512. K&J later filed an application for refund and abatement due to alleged erroneous property assessments. The Flathead County Board of Commissioners denied the application. K&J filed a petition for judicial review seeking to reverse the Commissioners' denial of tax refund and abatement and including a complaint for rescission of the tax sale certificate and seeking relief for all taxes paid under a theory of unjust enrichment. The district court dismissed the petition and complaint, ruling that it lacked subject matter jurisdiction because K&J did not follow the required process for seeking reassessment and exhausting administrative remedies. The Supreme Court affirmed, holding that Mont. Code Ann. 15-16-604 did not grant the district court authority to consider K&J's claims. View "K & J Investments, LLC v. Flathead County" on Justia Law