Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Defendants' motion to dismiss claims asserted against Glacier County officials (collectively, the County) in Plaintiffs' complaint due to lack of subject matter jurisdiction, holding that the district court did not err.This was the fourth case arising from a dispute between Plaintiffs and the County regarding alleged financial mismanagement and non-compliance with government budgeting, auditing, and tax laws. The County sought dismissal of certain claims under Mont. R. Civ. P. 12(b)(1), arguing that subject matter jurisdiction was lacking because no express or implied right to remedy existed. The district court denied the motion on the ground that Mont. Code Ann. 15-1-406 through -408 provided and express private right and related remedies, and thus related subject matter jurisdiction. The Supreme Court affirmed without prejudice to issues properly preserved and raised pursuant to Mont. R. Civ. P. 12(b)(6), holding that the district court did not err in denying the County's Rule 12(b)(1) motion to dismiss. View "Gottlob v. DesRosier" on Justia Law

The Supreme Court affirmed in part and reversed in part the orders of the district court holding Plaintiff liable for additional taxes Defendants owed as a result of Plaintiff's prepayment on the contract, holding that Plaintiff was obligated to pay additional taxes that were incurred by Defendants over the term of the contract.Plaintiff entered into an agreement with Defendants for the purchase of real property. Plaintiff later sued, alleging that its obligations under the agreement were satisfied and seeking an order requiring Defendants to reconvey the property to Plaintiff. Defendants counterclaimed for breach of contract. After a trial, the district court held that Plaintiff had not fulfilled all obligations under the contract. The court awarded Defendants damages and denied Defendants' request for prejudgment interest on the damage award. The Supreme Court reversed in part, holding that the district court (1) correctly found that Plaintiff did not extinguish its obligations under the contract; (2) correctly denied Defendants' motion for prejudgment interest; but (3) erred when it interpreted the relevant documents to obligate Plaintiff to pay the additional taxes that were incurred by Defendants in the year the prepayment was made instead of the total additional taxes Defendants incurred over the term of the contract. View "First National Properties, LLC v. Hilstead Trust" on Justia Law

The Supreme Court affirmed the order of the district court denying Matthew Monforton's petition for judicial review of a final agency decision by the office of the Commissioner of Political Practices (COPP) dismissing an ethics complaint that Monforton had lodged against Jonathan Motl based on statements that Motl had made during a radio interview, holding that Motl's statements did not violate Mont. Code Ann. 2-2-136(4) of the Montana Code of Ethics.In his complaint, Monforton alleged that Motl's statements during a radio interview constituted improper election advocacy in violation of section 2-2-121(3)(a), an ethics rule that prohibits public officers and employees from using "public time, facilities, [and] equipment" to "solicit support for or opposition to the...election of a person to public office." The deputy COPP dismissed the ethics complaint. The district court upheld the dismissal. The Supreme Court affirmed, holding that the district court's decision to uphold the dismissal of Monforton's ethics complaint on the basis that Motl's statements did not constitute unlawful opposition to the election at issue under section 2-2-121(3)(a). View "Monforton v. Motl" on Justia Law

The Supreme Court reversed Defendant's conviction of criminal distribution of dangerous drugs, methamphetamine, and criminal possession of dangerous drugs, methamphetamine, holding that the district court erred in denying Defendant's motion to disclose the identity of a confidential informant.After Defendant was charged, Defendant filed a motion asking the district court to compel the State to disclose the identity of the confidential informant that led to Defendant's arrest. The district court denied the motion. After a second trial, the jury convicted Defendant. On appeal, Defendant argued that she had the right to know the identity of the informant because the informant played a continuous, active, and primary role in the alleged crime. The Supreme Court agreed, holding that, considering the circumstances of the case balanced against the public's interest in withholding the confidential informant's identity, the district court erred in denying Defendant's motion to compel disclosure of the informant's identity. View "State v. Walston" on Justia Law

The Supreme Court reversed Defendant's conviction of sexual intercourse without consent, holding that the district court abused its discretion and compromised Defendant's right to a fair trial when it allowed expert witness testimony on statistics about false reports of sexual assault.On appeal, Defendant argued that the trial court's admission of the expert testimony regarding the statistics about false reports of rape prejudiced his right to a fair trial by turning the case into a "trial by statistic" rather than a case based on specific facts. The Supreme Court reversed, holding (1) the expert testimony regarding the rate of false reports of sexual assault was improper, and the district court abused its discretion in admitting the testimony; and (2) Defendant's right to a fair trial was violated by the improper admission of the false reporting statistics. View "State v. Grimshaw" on Justia Law

In this case involving six water right claims on Big Warm Creek the Supreme Court affirmed the Water Court's final order, holding that the Water Court did not err or abuse its discretion.Specifically, the Supreme Court held that the Water Court (1) did not err by finding no ambiguity in the language of the deeds conveying portions of the Phillips Ranch, and the appurtenant water rights, from David Drum to Lloyd Knudsen, Wayne Norman, and Springdale Colony, Inc.; (2) did not err by declining to resort to extrinsic evidence of the parties’ intent; (3) did not err by apportioning the water pro-rata based on the parties’ historical use; and (4) did not abuse its discretion by denying Little Big Warm Ranch’s post-judgment motion for relief from the court’s final order. View "Little Big Warm Ranch, LLC v. Doll" on Justia Law

The Supreme Court reversed the order of the district court dismissing Plaintiff's complaint on the ground that his state common-law tort claims for slander and emotional distress were preempted by the federal Civil Reform Act (the Act), holding that the district court prematurely dismissed the case without the factual record needed to determine preemption.While working at the Montana Veterans Administration Health Care System (Montana VA), Plaintiff had consensual sex with fellow employee Tori Marino. Marino reported that Plaintiff had sexually assaulted her and later recanted her allegation. Marino later told Plaintiff that two other employees of the Montana VA who served as a union president and union steward had told her to falsely accuse Plaintiff in order to avoid losing her job. Plaintiff filed a complaint against Marino, the two employees, and the union seeking damages for slander and emotional distress. The union defendants moved to dismiss the complaint, arguing that the Act preempted Dickson's state-law tort claims. The district court agreed, holding that the union defendants' conduct constituted a "prohibited personnel practice," and therefore, the Act preempted Plaintiff's claims. The Supreme Court reversed, holding that the district court erred in concluding on the allegations of Plaintiff's complaint alone that his claims were preempted by the Act. View "Dickson v. Marino" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony strangulation of his girlfriend, holding the evidence was sufficient to support the conviction, and Defendant did not receive ineffective assistance of counsel.Specifically, the Supreme Court held (1) the evidence was sufficient to sustain Defendant's conviction of felony strangulation; (2) Defendant failed to meet the prejudice standard set forth in Strickland v. Washington, 466 U.S. on his claim that his counsel was ineffective by opening the door to evidence of Defendant's prior violence; and (3) this Court declines to review for plain error Defendant's argument challenging the district court's instruction on the mental state for strangulation. View "State v. Dineen" on Justia Law

The Supreme Court reversed the district court's entry of summary judgment in favor of Elk Grove Development Company (Elk Grove) and the Elk Grove Homeowners Association (HOA) and entry of an injunction enjoining the Four Corners County Water and Sewer District from using the Elk Grove Subdivision's water "sourced from any of the wells located within the Subdivision and from the Water Right for use upon property outside the Subdivision, holding that the district court erred in determining that the Subdivision Covenant was a reasonable restraint upon the alienation of a water right.On appeal, the Water District argued that the Covenant was an unreasonable restraint on alienation because it usurped the State's jurisdiction over its water and violated the state water law requirement that waters be put to beneficial use. The Supreme Court reversed, holding that the district court erred to the extent that it held the Covenant was a reasonable restraint on the alienation of the Subdivision's water and Water Right and so enjoined the Water District. View "Elk Grove Development Co. v. Four Corners County Water & Sewer District" on Justia Law

The Supreme Court affirmed but on different grounds the summary judgment granted by the district court ruling that the equitable doctrine of unjust enrichment precluded the claim brought by Mountain Water Company for a general property tax refund on taxes that accrued during the pendency of a condemnation action initiated by the City of Missoula, holding that Mountain Water contractually waived its right to property tax proration and reimbursement from or against the City under Mont. Code Ann. 70-30-315.Specifically, the Supreme Court held (1) the district court erred in concluding that the doctrine of unjust enrichment precluded relief on Mountain Water's claim for property tax proration and relief under Mont. Code Ann. 70-30-315; (2) the district court erred in concluding that, but for application of equitable unjust enrichment, section 70-30-315 would entitle Mountain Water to a general property tax refund under Mont. Code Ann. 15-1-402(1)-(2), (6)(b)(i) and -406(1)-(3); (3) Mountain Water contractually waived its right to property tax proportion and reimbursement from the City under section 70-30-315; and (4) the district court correctly concluded that Mountain Water's subsequent assertion of a general property tax refund claim did not breach the parties' 2017 condemnation action settlement agreement. View "Mountain Water v. Department of Revenue" on Justia Law