Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed in part and affirmed in part the judgment of the district court concluding that Appellant was not entitled to underinsured motorist (UIM) and medical payment (MP) coverages under his automobile policy with USAA Casualty Insurance Company, holding that the court erred in part.The district court granted summary judgment for USAA on both coverages. The Supreme Court reversed in part, holding (1) as to the UIM coverage, the district court erred by interpreting the contract and determining its terms were not contrary to public policy; and (2) as to the MP coverage, the district court properly granted summary judgment in favor of USAA. View "Goss v. USAA Casualty Insurance Co." on Justia Law

The Supreme Court reversed the order of the district court denying as untimely the motion of the Montana Secretary of State to substitute a judge, holding that the Secretary's motion to substitute a judge was timely, and the district court erred by denying the motion.Plaintiff brought this action challenging HB 325, a bill that would alter the election process for state Supreme Court justices if passed by ballot referendum in November 2022, alleging that the bill violated the Montana Constitution. The Secretary moved to substitute the district court judge. The district court denied the substitution motion as untimely. The Supreme Court reversed, holding that a lawsuit filed against the Secretary of State is a lawsuit against "the State," such that service of process is not complete until the date the Attorney General is served. View "McDonald v. Jacobsen" on Justia Law

The Supreme Court reversed the judgment of the district court convicting Defendant of indecent exposure to a minor, sexual abuse of children in violation of Mont. Code Ann. 45-5-625(1)(c) and (4), and sexual abuse of children, in violation of Mont. Code Ann. 45-5-625(1)(c) and (2)(b), holding that Defendant's counsel provided record-based ineffective assistance of counsel that required reversal and remand for a new trial.Specifically, the Supreme Court held (1) Defendant's trial counsel provided ineffective assistance by failing to challenge the statutory basis for Count I when the statute upon which the charge was based did not go into effect until after one of the alleged incidents occurred; and (2) the ex post facto application of Mont. Code Ann. 45-5-625(1)(c) for Count II and Count III required remand for a new trial. View "State v. Tipton" on Justia Law

The Supreme Court affirmed the decision of the district court denying Plaintiffs' motions for default judgment and for summary judgment and granting the summary judgment of Defendants, holding that there was no error.In the midst of a dispute over real property, Plaintiffs filed an action to quiet title. The district court denied Plaintiffs' motion for summary judgment and granted Defendants' motion for summary judgment on Plaintiffs' quiet title claim. The Supreme Court affirmed, holding that the district court (1) did not manifestly abuse its discretion by declining to enter a default judgment in favor of Plaintiffs after Defendants did not complete service of their answer until one day after the deadline of Mont. R. Civ. P. 12; and (2) did not err when it determined that Plaintiffs' claims were barred by the doctrine of laches. View "Carter v. Badrock Rural Fire District" on Justia Law

The Supreme Court affirmed in part the judgment of the district court dismissing Plaintiffs' request for class certification, holding that the district court did not abuse its discretion by holding that Plaintiffs' certification request did not meet the requirements of Mont. R. Civ. P. 23.Plaintiff lived in apartment complexes owned and operated by Defendants. Plaintiffs alleged that their leases contained multiple provisions violating Montana law. Plaintiffs sought certification as a class under Rule 23 to include other tenants who entered into similar lease agreements with Defendants. The district court dismissed most claims but denied the dismissal of two claims as to one plaintiff. The district court also denied Plaintiffs' request for class certification. The Supreme Court affirmed in part and remanded for further proceedings, holding that the district court did not err in dismissing Plaintiffs' request for class certification. View "Vulles v. Thies & Talle Management, Inc." on Justia Law

The Supreme Court affirmed the sentencing order of the district court requiring Defendant to pay $3,025 in restitution for his extradition from Georgia and to surrender his medical marijuana card, holding that Defendant failed to show that the district court's sentence was illegal or that it abused its discretion.On appeal, Defendant argued that the district court erred in ordering him to pay restitution when his only income consisted of Army disability benefits and erred in requiring him to surrender his medical marijuana card pursuant to Mont. Code Ann. 46-18-202(1)(f). The Supreme Court affirmed, holding (1) Defendant's sentence was lawful; and (2) the condition of Defendant's sentence that he surrender his medical marijuana card was constitutional and lawful. View "State v. Corriher" on Justia Law

The Supreme Court reversed the judgment of the district court denying Defendant's motion for a new trial on the offense of partner or family members assault (PFMA), third or subsequent offense, holding that the district court committed reversible error.The State charged Defendant with third or subsequent offense PFMA based on incriminating audio-video camera footage capturing Defendant's belligerent verbal and physical interaction with his teenage son and subsequent incriminating statements made in a post-arrest interrogation interview conducted by a sheriff's deputy. After he was convicted, Defendant filed a motion for a new trial on the ground that the court erroneously allowed the video playbacks to the jury without notice to the parties. The district court denied the motion. The Supreme Court reversed, holding that the district court erred in denying Defendant's motion for a new trial based on a violation of Mont. Code Ann. 46-16-503(2) and the related common law rule limiting the rehearing or replay of testimonial evidence during jury deliberations. View "State v. Hoover" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of sexual assault, holding that the district court did not err or abuse its discretion.After a jury trial, Defendant was convicted of sexually assaulting his minor stepdaughters. On appeal, Defendant argued that the district court deprived him of his right to present a complete defense and requested either dismissal of his case or a new trial. The Supreme Court affirmed, holding that the district court (1) did not err when it ruled that the State did not deliberately destroy potentially exculpatory evidence; (2) did not err when it prevented Defendant from presenting evidence to the jury relating to the State's alleged destruction of evidence; and (3) did not abuse its discretion when it limited the scope of testimony by Defendant's expert witness. View "State v. Villanueva" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court denying Defendant's motion to suppress illegal drug evidence seized as a result of a protective pat-down search for weapons and in a subsequent search of his vehicle, holding that the district court erred in concluding that the protective pat-down search of Defendant was justified.Specifically, the Supreme Court held (1) the district court erroneously held that the pat-down search of Defendant was justified under Terry v. Ohio, 392 U.S. 1 (1968) and Mont. Code Ann. 46-5-401(2)(b), whether incident to a valid Terry investigative stop or analogous community caretaker doctrine stop, but did not err in concluding that the exclusionary rule did not apply to the illegal drug evidence seized in the warrantless pat-down and vehicle searches at issue; and (2) therefore, the district court erred in denying Defendant's motion to suppress evidence found in his coat pocket as a result of the initial pat-down search but correctly denied Defendant's motion to suppress evidence found in the subsequent consent search of his vehicle. View "State v. Laster" on Justia Law

The Supreme Court affirmed the order of the district court convicting Defendant of sexual intercourse without consent, holding that the district court did not abuse its discretion by permitting admission of evidence regarding other acts and statements made by Defendant.Defendant filed a motion in liming to preclude the admission of evidence involving the occurrence of any other sexual acts or statements regarding the victim. The district court denied the motion, concluding that evidence of Defendant's sexual conduct with the victim, apart from the conduct alleged in the information, was relevant and admissible. The Supreme Court affirmed, holding that the district court did not abuse its discretion in admitting the evidence. View "State v. Murphy" on Justia Law