Justia Montana Supreme Court Opinion Summaries

Flathead Properties, L.L.C. (Appellant) owned a tract of land along Flathead Lake that became an island during certain months due to rising water levels. In 2011, Appellant received a permit from the Flathead County Planning and Zoning Office to build a bridge connecting the island to the peninsula. The Community Association for North Shore Conservation (C.A.N.S.C.) challenged the permit, arguing it violated the Montana Lakeshore Protection Act. The District Court voided the permit and ordered the bridge's removal, a decision upheld by the Montana Supreme Court.Following the Supreme Court's decision, Appellant filed a claim for inverse condemnation against Flathead County, arguing that the court-ordered removal of the bridge constituted a taking of its vested property interest, requiring compensation. The County filed a motion to dismiss under M. R. Civ. P. 12(b)(6), arguing that since the permit was void ab initio, Appellant never had a vested property interest. The District Court granted the motion, agreeing with the County's reasoning.The Supreme Court of the State of Montana reviewed the case and reversed the District Court's decision. The Court held that Appellant's complaint contained sufficient facts to support a claim for inverse condemnation or, alternatively, a regulatory takings claim. The Court noted that Appellant had a constitutionally protected property interest in the bridge once it was built and that the County's actions in issuing and then voiding the permit could be seen as a taking requiring just compensation. The case was remanded for further proceedings consistent with this opinion. View "Flathead Properties L.L.C. v. Flathead Cty" on Justia Law

Danielle Wood was charged with deliberate homicide for the shooting death of Matthew LaFriniere. The State alleged that Wood purposely or knowingly caused LaFriniere's death by shooting him with a firearm. The case involved a tumultuous relationship between Wood and LaFriniere, including a custody battle over their child. On the evening of May 2, 2018, Wood received a text message purportedly from LaFriniere, stating he was delayed and instructing her to keep their child. Later that evening, LaFriniere was found dead with multiple gunshot wounds.The Montana Twentieth Judicial District Court, Sanders County, convicted Wood of deliberate homicide. Wood appealed, raising several issues, including the sufficiency of evidence for the State's alternative theory of accountability for deliberate homicide and the clarity of the jury verdict form. The District Court had allowed the State to amend the Information to include an alternative theory of accountability, which Wood contested. The jury was instructed on both direct deliberate homicide and accountability for deliberate homicide, but the verdict form did not distinguish between the two theories.The Supreme Court of the State of Montana reviewed the case. The Court found that the District Court erroneously submitted the State's alternative theory of accountability to the jury without sufficient supporting evidence. The Court also found that the verdict form provided to the jury was ambiguous and did not allow the jury to unambiguously declare Wood's guilt or innocence regarding each of the charged offenses or theories of criminal liability. Consequently, the Supreme Court reversed Wood's conviction and remanded the case for a new trial. View "State v. Wood" on Justia Law

Appellees Gordon Tait and Michelle Janz plan to build a residence at the base of their property adjacent to Whitefish Lake. The proposed access to their home is a narrow dirt road that crosses both Appellees’ and Appellants’ lots, part of an express easement allowing all lot owners to use the road. Appellants challenged this use, arguing the easement was intended only for summer access to the lake, not for regular travel to a residence, and that their properties would be unduly burdened by the construction.The Eleventh Judicial District Court, Flathead County, ruled in favor of Appellees, determining the easement’s language was specific and did not prohibit year-round use of the road. The court granted summary judgment to Appellees, leading to this appeal.The Supreme Court of the State of Montana reviewed the case. The court examined the easement’s language and found it unambiguous regarding year-round use. The easement explicitly permitted motor vehicle traffic across a ten-foot right of way without seasonal limitations. The court noted that while the easement limited shared maintenance costs to summer use, it did not restrict the road’s use to summer months only. The court also found no basis to prohibit the use of the road for constructing a residence, as the easement did not limit the type of access provided.The court affirmed the District Court’s decision, holding that the easement allowed year-round use and did not restrict the road’s use to accessing only non-residential structures. Concerns about potential overburdening of the easement due to construction were deemed speculative and not ripe for adjudication. View "Archer v. Tait" on Justia Law

The State of Montana charged Matthew Jason Welch with six counts of Deceptive Practices and four counts of Theft by Deception. Welch faced varying prison terms depending on the value of the property involved. On January 20, 2022, Welch entered a non-binding plea agreement, pleading guilty to all counts. The agreement recommended a sentence of 10 years with five suspended for each count, with some sentences running concurrently and others consecutively. However, the District Court rejected this recommendation and sentenced Welch to 10 years for each count, all running consecutively, resulting in a net sentence of 50 years with 50 suspended. Welch appealed the four illegal sentences, leading to a remand for resentencing within statutory limits.The District Court resentenced Welch to three years for each of the four counts, all running consecutively, resulting in a total sentence of 30 years with 30 suspended and 12 years DOC. Welch then moved to withdraw his guilty plea, arguing it was involuntary due to the illegal sentence, but the District Court denied the motion.The Supreme Court of the State of Montana reviewed the case. The court held that Welch was not entitled to withdraw his guilty plea because the State accepted a reduced sentence within legal limits, and Welch received the benefit of his bargain. The court also noted that Welch was aware the court was not bound by the plea agreement. The court affirmed the denial of Welch's motion to withdraw his guilty plea but remanded to correct the restitution amounts in the amended judgment to reflect the court's oral pronouncement. View "State v. Welch" on Justia Law

The defendant, Justin Guy Zeno Shawn Wolf Mason, was convicted of felony Partner and Family Member Assault (PFMA), misdemeanor Unlawful Restraint, and misdemeanor Resisting Arrest. He received a suspended five-year sentence for the PFMA charge, with probationary conditions, and concurrent six-month suspended sentences for the misdemeanors. Mason was required to comply with all laws and maintain contact with probation and parole.The Tenth Judicial District Court, Fergus County, revoked Mason's suspended sentence after he failed to report to probation and parole and was charged with misdemeanor assault following an altercation with a security guard. Mason argued that the court erred in finding him in violation of his probation terms, denying his motion to introduce video evidence, and revoking his suspended sentence.The Montana Supreme Court reviewed the case and found that the State had demonstrated by a preponderance of the evidence that Mason violated the conditions of his suspended sentence by being charged with misdemeanor assault. The court noted that a single violation is sufficient to support revocation. The court also held that the exclusion of the body camera footage was not prejudicial to Mason, as his testimony established conduct meriting revocation. Additionally, the court declined to exercise plain error review regarding the banishment provision, as it was part of a separate pre-trial diversion agreement and not directly related to the conditions Mason was accused of violating.The Montana Supreme Court affirmed the revocation of Mason's suspended sentence, concluding that the State met its evidentiary burden, the exclusion of the video was not prejudicial, and the District Court did not commit plain error. View "State v. Mason" on Justia Law

A disabled woman, T.M.B., was sexually assaulted by an employee of West Mont, a nonprofit organization contracted by the State of Montana to provide community-based services for developmentally disabled individuals. T.M.B. sued both the State and West Mont, alleging they owed her a nondelegable duty of care. The District Court granted summary judgment in favor of both defendants, concluding neither owed a nondelegable duty of care for the employee’s criminal acts. T.M.B. appealed.The District Court of the First Judicial District, Lewis and Clark County, found that the State had satisfied its statutory obligations by contracting with West Mont to provide services and did not owe a nondelegable duty to T.M.B. because she was not under state custody or control. The court also found that West Mont did not owe a nondelegable duty, as there was no statute or rule explicitly stating such a duty existed for state contractors operating community homes.The Supreme Court of the State of Montana reviewed the case. It affirmed the District Court’s decision regarding the State, agreeing that the State did not have a close, continuing relationship with T.M.B. that would impose a nondelegable duty. However, the Supreme Court reversed the decision regarding West Mont, finding that the relationship between West Mont and T.M.B. was sufficiently close and continuing to impose a nondelegable duty under Restatement (Second) of Agency § 214. The court held that West Mont had a duty to protect T.M.B. from harm due to her dependence on their care and supervision. The case was remanded for further proceedings consistent with this opinion. View "T.M.B v. West Mont" on Justia Law

Donald Fleming filed a lawsuit against Caribou Creek Log Homes, Inc. and North Idaho Insulation, LLC, alleging that spray foam insulation installed by North Idaho Insulation caused significant structural damage to his residence in Montana. Fleming's claims included negligence, violations of residential construction defect statutes, the Montana Consumer Protection Act, and breach of warranties. North Idaho Insulation then filed a third-party complaint against Southwest Distributing Co. (Southwest), alleging that Southwest manufactured and sold the defective spray foam insulation and seeking indemnification and contribution.The Montana Nineteenth Judicial District Court denied Southwest's motion to dismiss for lack of personal jurisdiction, concluding that it had specific personal jurisdiction over Southwest under Montana Rule of Civil Procedure 4(b)(1). Southwest then petitioned the Montana Supreme Court for a writ of supervisory control, arguing that the District Court erred in its jurisdictional ruling.The Montana Supreme Court reviewed the case and determined that the District Court erred in concluding it had specific personal jurisdiction over Southwest. The Supreme Court found that Southwest did not transact business in Montana related to the claims and that the claims did not arise from Southwest's activities in Montana. Additionally, the Court held that the stream-of-commerce theory did not apply, as Southwest did not purposefully direct its activities toward Montana. Consequently, the Supreme Court granted the petition for a writ of supervisory control, reversed the District Court's order, and remanded the case for further proceedings consistent with its opinion. View "Southwest v. 19th Judicial Dist." on Justia Law

Craig Baugh acquired a 20-acre tract of land in 1983 and another adjoining 20-acre tract in 1993, both located in a remote, forested area in Flathead County, Montana. In 2006, Baugh consolidated and subdivided the 40-acre aggregate into two new 20-acre tracts (Tract 1 and Tract 2) by certificate of survey (COS), which included a 20-foot wide access and utility easement on an existing road. Baugh sold Tract 2 to Florian Skyland in 2019, who later sold it to H2S2, LLC. H2S2 planned to develop a 32-unit short-term "glamping" business on Tract 2, which Baugh opposed, leading to a lawsuit.The District Court of the Eleventh Judicial District, Flathead County, initially denied Baugh's request for a preliminary injunction but later granted summary judgment in his favor. The court concluded that H2S2's planned commercial use of the easement would exceed the intended scope of the easement, which was meant for single-family residential use. The court permanently enjoined H2S2's planned use and awarded Baugh prevailing party attorney fees, deeming H2S2's counterclaims for damages as frivolous.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's summary judgment that H2S2's proposed commercial use exceeded the authorized scope of the express easement. The court held that the easement's intended use was limited to single-family residential purposes, and H2S2's planned commercial use would significantly exceed this scope. However, the Supreme Court reversed the District Court's award of attorney fees to Baugh, concluding that the central issue was a bona fide dispute on the merits of the permissible use and scope of the easement, and thus, H2S2's counterclaims were not frivolous. The case was remanded for entry of a corresponding final judgment. View "Baugh v. H2S2, LLC" on Justia Law

The case involves Lewis Leon Bryson, who was convicted of sexual intercourse without consent (SIWOC) following a jury trial. On May 2, 2020, Bryson's neighbor observed him spraying a naked and screaming Valerie Moreni with a hose in his backyard. When police arrived, Moreni was found unresponsive and covered by a blanket. She later claimed Bryson had raped her. Medical examination revealed she was highly intoxicated and had injuries consistent with her allegations. Bryson was arrested and charged with aggravated sexual intercourse without consent (ASIWOC), SIWOC, tampering with evidence, and obstructing a peace officer.The Eighth Judicial District Court, Cascade County, presided over the trial. Bryson and Moreni provided conflicting testimonies about their relationship and the events leading up to the incident. Bryson claimed their interactions were consensual and that Moreni was aware of their sexual activities. The jury found Bryson guilty of SIWOC and obstructing a peace officer.The Supreme Court of the State of Montana reviewed the case. Bryson argued that his trial counsel was ineffective for not proposing correct jury instructions and that the District Court erred by excluding evidence about Moreni’s drinking habits and alcohol withdrawal symptoms. The Supreme Court held that the jury instructions were correct and that Bryson’s counsel was not deficient. The court also found that the District Court did not abuse its discretion in excluding certain evidence about Moreni’s past drinking habits, as it allowed sufficient evidence regarding her condition and credibility.The Supreme Court affirmed Bryson’s conviction, concluding that the instructions and evidentiary rulings were appropriate and did not prejudice Bryson’s defense. View "State v. Bryson" on Justia Law

A group of 16 youths sued the State of Montana, the Governor, and multiple state agencies, alleging that the State's actions exacerbated the harm they were experiencing from climate change. They sought declaratory and injunctive relief, specifically challenging certain provisions of Montana's State Energy Policy Act and the Montana Environmental Policy Act (MEPA) as unconstitutional. The plaintiffs argued that these provisions violated their constitutional right to a clean and healthful environment by promoting fossil fuel development and prohibiting the consideration of greenhouse gas (GHG) emissions in environmental reviews.The First Judicial District Court found in favor of the plaintiffs, declaring the challenged provisions unconstitutional and enjoining the State from acting in accordance with them. The court concluded that the right to a clean and healthful environment includes a stable climate system and that the MEPA Limitation violated this right. The court also denied the State's motion for psychiatric examinations of the plaintiffs, finding no good cause for such examinations.The Supreme Court of the State of Montana affirmed the District Court's decision. The court held that the right to a clean and healthful environment under the Montana Constitution includes a stable climate system. The court found that the plaintiffs had standing to challenge the MEPA Limitation, as it infringed on their constitutional rights. The court also held that the MEPA Limitation was unconstitutional because it arbitrarily excluded GHG emissions from environmental reviews, thereby violating the plaintiffs' right to a clean and healthful environment. The court affirmed the permanent injunction against the State from acting in accordance with the unconstitutional provisions. View "Held v. State" on Justia Law