Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the district court's imposition of certain conditions on Defendant's sentence and reversed the court's determination that Defendant must pay the costs of his public defender, holding that the district court erred.Defendant pled guilty sexual assault and evidence tampering. In sentencing Defendant, the district court imposed conditions limiting Defendant's ability to possess a phone, a computer, or access to the internet. The district court further ordered Defendant to pay the cost of his public defender without conducting a meaningful inquiry into his ability to pay such expense. The Supreme Court reversed in part, holding (1) the sentencing conditions were overbroad insofar as they completely restricted Defendant's ability to access the internet and certain electronic devices; and (2) the district court erred in ordering Defendant to pay the cost of his public defender without conducting a meaningful inquiry into his ability to pay. View "State v. Hotchkiss" on Justia Law

The Supreme Court affirmed the order of the district court granting Defendants' motion for summary judgment and dismissing Plaintiff's claim alleging breach of contract and breach of implied covenant of good faith and fair dealing, holding that the district court properly concluded that there was no dispute of material fact and that Defendants were entitled to a judgment as a matter of law.Bar 11 Enterprises, LLC, a company created by Deschamps, entered into a gravel pit sublease agreement with FarWest Rock Products. Mining operations later ceased, Bar 11 was dissolved, and Deschamps received notice of termination of lease. Deschamps filed a complaint, listing himself and Bar 11 as plaintiffs. Thereafter, Deschamps filed articles of organization to create a business entity named Bar 11 Enterprises, LLC. The district court dismissed all claims based on a lack of standing by both Deschamps and Bar 11. The Supreme Court affirmed, holding that the district court correctly found that (1) the Bar 11 entity named as a party to this suit was not the same as the original Bar 11 that entered into the disputed agreement with Farwest Products; (2) Deschamps lacked standing to sue in his personal capacity; and (3) Defendants were entitled to a judgment as a matter of law. View "Deschamps v. Farwest Rock, Ltd." on Justia Law

The Supreme Court dismissed the charges against Defendant, holding that Defendant was denied his constitutional right to a speedy trial and was presumptively prejudiced by the delay.The State filed an information charging Defendant with burglary and theft of more than $800. Nearly five years after his arrest Defendant had still not been brought to trial. Defendant filed a pro se motion to dismiss the charges, arguing that the five-year delay violated his right to a speedy trial. The district court denied the motion. Defendant pleaded guilty, reserving the right to appeal the denial of his speedy trial motion. The Supreme Court dismissed the charges against Defendant, holding that Defendant was denied his constitutional right to a speedy trial. View "State v. Chambers" on Justia Law

The Supreme Court affirmed the order of the district court denying Defendant's motion to exclude evidence obtained during a traffic stop and to dismiss the charges against him, holding that an officer has a lawful right of access to reach into a vehicle and seize plainly visible contraband observed by the officer during a lawful traffic stop.Defendant was charged with criminal possession of dangerous drugs and criminal possession of drug paraphernalia. Defendant moved to exclude the evidence obtained during the traffic stop and to dismiss the charges, arguing that the deputy sheriff's warrantless seizure of a plastic bag found on Defendant's lap was unlawful. The district court denied the motion. Defendant then pled guilty, preserving his right to appeal the denial. The Supreme Court affirmed, holding that because the officer's warrantless seizure of the bag was not unlawful because the officer was lawfully present next to Defendant's truck during the traffic stop, could plainly see readily apparent contraband fall onto Defendant's lap, and had a lawful right of access to that contraband. View "State v. Tenold" on Justia Law

In this termination of parental rights matter, the Supreme Judicial Court reversed the district court's order, holding that the court abused its discretion by terminating Mother's parental rights without a conclusive determination of her two children's tribal membership status and enrollment eligibility with the United Keetoowah Band of Cherokee Indians tribe.Specifically, the Supreme Court held (1) the district court erred by terminating Mother's parental rights in the absence of a conclusive tribal determination regarding the children's status as Indian children of the United Keetoowah tribe; (2) the Montana Department of Public Health and Human Services engaged in reasonable efforts to prevent removal and reunite Mother with her children; and (3) the district court did not err by determining that the conduct or condition rendering Mother unfit, unable, or unwilling to parent was unlikely to change within a reasonable time. The Supreme Court remanded the case to allow the tribe to make a conclusive determination regarding the children's membership and enrollment eligibility. View "In re M.T." on Justia Law

The Supreme Court affirmed Defendant's felony conviction of criminal possession with intent to distribute, holding that the district court did not err in determining that the State was not required to disclose the identity of its confidential informant.After Defendant was charged, he moved to dismiss the case on the basis that the State had failed to disclose the confidential informant's identity within the discovery timeframe. The district court summarily denied Defendant's motion to dismiss, declining to require disclosure of the confidential informant's identity. Defendant pled guilty, reserving his right to appeal the denial of his motion to dismiss. The Supreme Court affirmed, holding that the district court did not err as a matter of law in denying Defendant's motion to dismiss and did not abuse its discretion in denying disclosure of the confidential informant's identity. View "State v. Soto" on Justia Law

The Supreme Court affirmed the order of the district court revoking Defendant's deferred sentence for criminal possession of dangerous drugs, holding that the district court did not violate Defendant's Sixth Amendment right to confront witnesses during his revocation and did not abuse its discretion in determining that Defendant absconded.Specifically, the Supreme Court held (1) the district court did not violate Defendant's Sixth Amendment right to confront witnesses against him by relying on statements made in a report of violation by Defendant's previous probation officer; and (2) the State presented sufficient evidence at Defendant's revocation hearing to establish that Defendant failed to report for the purpose of avoiding supervision and that the probation office made reasonable efforts to contact him. View "State v. Fetveit" on Justia Law

The Supreme Court affirmed the judgment of the district court concluding that the Montana Public Service Commission (PSC) arbitrarily and unlawfully reduced solar qualifying facility (QF) standard-offer rates by excluding carbon dioxide emissions costs and NorthWestern Energy's avoided costs of operating its internal combustion engine resource units from the avoided-cost rate, holding that the district court did not err.Specifically, the Supreme Court held that the district court did not err in determining that the PSC did not comply with the Public Utility Regulatory Policies Act (PURPA) and Montana's mini-PURPA when it set the standard-offer contract rates and maximum contract lengths for qualifying small (QF-1) solar power producers. The PSC's decision to reduce the standard-offer QF-1 rates was arbitrary and unreasonable because the PSC failed to consider future carbon costs and failed to provide a reasoned decision in departing from its recent precedent. Further, the PSC unreasonably failed to consider NorthWestern's cost of operating its new internal combustion engine resources when setting the avoided-cost rate. View "Vote Solar v. Montana Department of Public Service Regulation" on Justia Law

The Supreme Court reversed the judgment of the district court holding Trinity Lutheran Church liable under a theory of unjust enrichment, holding that the district court erred as a matter of law in determining that Trinity Lutheran was unjustly enriched.Montana Digital, LLC contracted with Trinity Lutheran to provide unlimited telephone and internet services to Trinity Lutheran. Trinity Lutheran's system was later hacked and used by a theft to make international telephone calls to Africa at a service cost of $47,977. Montana Digital was invoiced for the cost of the calls, and Montana Digital paid the full amount of the invoice. Montana Digital then initiated this action against Trinity Lutheran, asserting a claim for unjust enrichment. The district court found Trinity Lutheran liable and awarded Montana Digital the same of $47,977. The Supreme Court reversed, holding that, under the circumstances, a claim of unjust enrichment was not established against Trinity Lutheran as a matter of law. View "Montana Digital, LLC v. Trinity Lutheran Church" on Justia Law

The Supreme Court reversed Defendant's conviction of sexual intercourse without consent (SIWC), a felony, holding that the district court abused its discretion in allowing the State to cross-examine Defendant regarding a prior SIWC allegation as rebuttal evidence and in precluding Defendant from impeaching the testimony of the State's complaining witness with evidence of marijuana use prior to reporting the alleged offense.On appeal, Defendant argued, among other things, that the district court abused its discretion in allowing the State to cross-examine him regarding an unsubstantiated 2003 SIWC allegation for the purpose of rebutting his self-serving good character testimony and erroneously precluded him from impeaching the testimony of the State's complaining witness with evidence of marijuana use prior to reporting the alleged offense. The Supreme Court agreed and remanded the case for a new trial, holding that, under the circumstances of this case, the district court erred as to both issues and that the errors were prejudicial. View "State v. Pelletier" on Justia Law