Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the district court denying Defendant's motion to suppress testimony regarding statements he made during a phone conversation with the victim, holding that the testimony was not subject to exclusion.A.O. and her friend Tricia alleged that Defendant had committed sexual offenses against A.O. While A.O. was at the police department, Defendant called A.O. Police officers listened in on the conversation, during which Defendant admitted to raping A.O. Defendant moved to suppress the evidence. The district court ruled that the officer testimony regarding the conversation would be excluded but that A.O. and Tricia, as private actors, could testify as to the conversation. Defendant appealed, arguing that the testimony of A.O. and Tricia as to the contents of the conversation must be excluded as attributable to an unconstitutional privacy intrusion by a government actor. The Supreme Court affirmed, holding that the district court correctly denied the motion to suppress because A.O. and Tricia's testimony resulted from their own private actions, not from unconstitutional monitoring and recording by police. View "State v. Wolfe" on Justia Law

The Supreme Court reversed the judgment of the district court ordering Defendant to pay $31,903 in restitution for losses resulting from offenses committed by another, holding that the district court erred in ordering Defendant to pay restitution.Defendant pled guilty to criminal possession of dangerous drugs and criminal possession of drug paraphernalia. At sentencing, the parties disagreed as to restitution for costs associated with remediating a co-defendant's apartment from methamphetamine contamination. The district court imposed the restitution requested by the State. On appeal, Defendant argued that the court erred in requiring him to pay restitution for losses committed by another absent evidence of criminal accountability or a causal connection between his offense and those losses. The Supreme Court agreed, holding that the State failed to establish a causal link between Defendant's admitted possession of methamphetamine and the rehabilitation claimed. View "State v. Cole" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court granting class certification in this action alleging breach of contract and violation of Montana's Unfair Trade Practices Act (UTPA), Mont. Code Ann. 33-18-101 et seq., holding that a sufficient factual basis was established to justify certification of the classes.Plaintiffs filed this action against Fergus Farm Mutual Insurance Company (FFM), alleging that FFM breached its insurance contract with Plaintiffs and all other insureds by failing to include general contractor overhead and profit in the cost to repair or replace Plaintiffs' property. The district court granted Plaintiffs' motion for class certification. The Supreme Court reversed in part, holding (1) the district court did not abuse its discretion by determining that common questions of law predominate the litigation and support certification of the class; but (2) certain conclusions reached by the district court were a "bridge too far" at this stage of litigation. View "Kramer v. Fergus Farm Mutual Insurance Co." on Justia Law

The Supreme Court affirmed in part and vacated in part the district court order temporarily enjoining two Montana election laws, holding that the court erred by enjoining a ballot deadline.At issue was the district court's grant of a preliminary injunction regarding two election laws. One law required absentee ballots to be returned to local election officers no later than 8 p.m. on Election Day and the other law restricted the delivery of such ballots by persons other than the elector. The Supreme Court affirmed the preliminary injunction against the Ballot Interference Prevention Act (BIPA) and vacated the preliminary injunction against the election-day ballot-receipt deadline, holding (1) the district court did not manifestly abuse its discretion by granting the preliminary injunction against enforcement of BIPA; and (2) the district court erred by enjoining the ballot deadline. View "Driscoll v. Stapleton" on Justia Law

The Supreme Court upheld the order of the district court prohibiting the office of the Secretary of State from qualifying the Montana Green Party as a minor party eligible for the 2020 election ballot, holding that the district court did not err.Mont. Code Ann. 13-10-601(2) requires the political party seeking to nominate its candidates through a primary election to present the petition seeking to hold a primary election to select the party's noises for office and to obtain ballot access for those nominees for the November 2020 general election to election administrators. The Montana Green Party was not involved and did not endorse the petition process at the time the signatures were gathered and presented to election administrators. The district court concluded that the petition failed to meet the requirements of section 13-10-601(2) and enjoined the Secretary from giving any effect to the petition. The Supreme Court affirmed, holding that the petition failed to satisfy the statutory requirements of section 13-10-601(2). View "Montana Democratic Party v. Stapleton" on Justia Law

The Supreme Court affirmed the order of the district court denying Appellant's petition compelling Appellee, the Missoula County Clerk and Recorder, to record Appellant's certificate of survey (COS), holding that Appellee did not have a clear legal duty to record the COS.The district court dismissed Appellant's petition for writ of mandamus, finding that Appellee was not under a clear, non-discretionary, legal duty to record Appellant's COS bearing language certifying that a subdivision qualified for an exemption that the relevant reviewing authority found to be inapplicable and declined to approve. The Supreme Court affirmed holding that the district court was correct in dismissing the petition for writ of mandamus because Appellee was not under a clear legal duty to record a COS bearing a certification of exemption from sanitary review that Appellant was not approved for. View "Richards v. Gernant" on Justia Law

The Supreme Court affirmed the order of the district court that Dan Cook's last will and testament be confirmed and admitted to probate and that Kim Smith be appointed personal representative of the estate, holding that, although the district court erred in applying an incorrect burden of proof to determine the validity of the will, the error was harmless.Specifically, the Supreme Court held (1) the district court did not err in concluding that Smith did not exceed her general power of attorney granted her by Cook when she transferred Cook's money; (2) the district court did not err in finding that Cook had the requisite capacity to enter into a valid marriage with Smith shortly before his death; and (3) while the court erred in applying an incorrect burden of proof in determining the validity of Cook's will, the error was harmless because the court's findings of fact were sufficient under the correct burden of proof to support the conclusion that Cook was competent to create and amend a valid will. View "In re Estate of Cook" on Justia Law

The Supreme Court overruled the decision of the Public Service Commission (PSC) rejecting a proposed development of an eighty-megawatt solar energy facility near Billings, Montana, holding that the PSC violated the requirements of the federal Public Utility Regulatory Policies Act (PURPA) and state law precluding discrimination against solar energy projects.The district court reversed and remanded the PSC's order setting terms and conditions of MTSUN, LLC's proposed eighty megawatt solar project based on findings of violations of due process, PURPA, and Montana's mini-PURPA. The Supreme Court affirmed, holding that the district court (1) did not err in concluding that the PSC's determinations were arbitrary and unlawful; and (2) relied on record evidence in determining the existence of a legally-enforceable agreement and the avoided-cost rates. View "MTSUN, LLC v. Montana Department of Public Service Regulation" on Justia Law

In a split decision, the Supreme Court reversed Defendant's negligent homicide convictions but upheld his convictions on nine counts of criminal endangerment and eleven counts of criminal distribution of dangerous drugs, holding that there was insufficient evidence to establish that Defendant's actions in prescribing narcotics was the cause in fact of the deaths of two of his patients.After a jury trial, Defendant, a licensed medical doctor, was convicted of several crimes related to the repeated prescribing of copious amounts of opiates and other narcotics to eleven individuals. Two of Defendant's patients died from drug overdoses. The Supreme Court reversed in part and affirmed in part the convictions, holding (1) the State did not present sufficient evidence to establish that Defendant's actions were the direct cause of the two drug overdose deaths; and (2) Defendant was operating outside the bounds of a professional medical practice, and therefore, the exemption for medical practitioners acting within the course of a professional practice did not apply to the facts of this case. View "State v. Christensen" on Justia Law

The Supreme Court held that Mont. Code Ann. 46-5-105 prohibits detention center employees who are booking a person into the general population of a detention facility from conducting a visual body cavity search without reasonable suspicion to believe that person is concealing contraband, a weapon, or evidence of the commission of a crime.William Rogers, leading ninety-six named plaintiffs, brought this action challenging the Lewis and Clark County Detention Center policy to conduct an unclothed visual body cavity search of every detainee prior to placement in the general population of the facility as a violation of Mont. Const. art. II, 10 and 11 and Mont. Code Ann. 46-5-105. The district court granted summary judgment for Defendants as to ninety-two of the named plaintiffs and denied the motion as to four plaintiffs who were never placed in the general population of the facility after they were strip searched. The Supreme Court affirmed in part and reversed in part, holding (1) Plaintiffs' diminished privacy interests did not outweigh the legitimate penological interests of the Detention Center; and (2) the plain language of section 46-5-105 unequivocally prohibits suspicionless strip searches of those arrested for minor offenses in any situation. View "Rogers v. Lewis & Clark County" on Justia Law