Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's conviction of one count of sexual intercourse without consent, holding that the district court did not err in denying Defendant's motion to strike a prospective juror for cause.After the district court denied Defendant's motion to remove the prospective juror for cause Defendant used a peremptory challenge to strike her from the panel and exhausted all of his peremptory challenges. Defendant appealed, arguing (1) the prospective juror's voir dire statements demonstrated an inability to act fairly and impartially in his trial, and therefore, the district court abused its discretion in denying his for-cause challenge; and (2) because he had to exercise a peremptory strike to remove the juror and subsequently exhausted his peremptory challenges, the error was prejudicial. The Supreme Court disagreed, holding that the district court did not abuse its discretion in accepting the prospective juror's assurances that she could fairly and impartially weigh the evidence despite her initial statements of prejudice. View "State v. Morales" on Justia Law

The Supreme Court held that a provision in the Office of the State Public Defender's contract with private attorneys specifying that hourly compensation rates can unilaterally be changed by the State permits prospective changes in a contract attorney's compensation rate for existing cases.Appellants, private attorneys who contract with OPD to provide legal services for indigent clients, filed a class action complaint against the State, the Governor, and the Director of the Office of the State Public Defender (OPD) alleging that Defendants were liable for breach of contract or in violation of the Contract Clause stemming from the OPD's act of reducing rates for all contracted services and reducing pay for case-related travel. The district court granted the State's motion for summary judgment, ruling that the OPD did not breach its contract with Appellants because the contract specifically identified that the fee arrangement was subject to change by the Director. The Supreme Court affirmed, holding that summary judgment was properly granted for the State. View "Brooke v. State" on Justia Law

The Supreme Court reversed the judgment of the district court designating Defendant as a persistent felony offender (PFO) and imposing an enhanced sentence under Mont. Code Ann. 46-18-502 , holding that the PFO designation failed.Defendant was convicted of distributing dangerous drugs. The State sought to designate Defendant as a PFO based on a 2014 Montana conviction for burglary and a 1994 federal conviction for bank robbery. The district court sentenced Defendant to the minimum PFO sentence enhancement. The Supreme Court reversed, holding that Defendant's federal bank robbery conviction was not reasonably equivalent to a Montana robbery conviction, and therefore, it may not be used as a predicate violent offense under Mont. Code Ann. 46-1-202(18) to impose a persistent felony offender sentence enhancement. View "State v. Scott" on Justia Law

The Supreme Court reversed the order of the district court dismissing Plaintiff's complaint against Defendant, his student loan servicer, as expressly preempted by the Higher Education Act (HEA), 20 U.S.C. 1098g, holding that Plaintiff's state law claims were not expressly or implicitly preempted by the HEA.Plaintiff raised claims that Defendant violated the Consumer Protection Act, was negligent in its accounting of his payments, breached the implied covenant of good faith and fair dealing, and engaged in deceit, negligent misrepresentation, or constructive fraud. The district court dismissed the complaint, determining that the HEA expressly preempted Plaintiff's claims. The Supreme Court reversed, holding that Plaintiff's state law claims as pleaded were neither expressly preempted by 20 U.S.C. 1098g, nor were they preempted under conflict preemption, and thus the claims survived dismissal. View "Reavis v. Pennsylvania Higher Education Assistance Agency" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court awarding $2,353,463 in damages to Junkermier, Clark, Campanella, Stevens, P.C. (JCCS), a Montana accounting firm, after a bench trial on remand, holding that the district court did not err by awarding prejudgment interest but erred with regards to the date interest began accruing.Appellants, five of six shareholders in JCCS' Bozeman office, were employed under the terms of an Employment Agreement that contained a covenant restricting competition (Covenant). Appellants later began working at a newly formed accounting firm and solicited clients from JCCS' Bozeman client list. JCCS filed a complaint against Appellants to declare the Covenant enforceable and to recover damages. On remand, the district court determined that the Covenant was reasonable, Appellants were jointly and severally liable for damages arising out of the Covenant's breach, and JCCS was entitled to prejudgment interest. The Supreme Court largely affirmed, holding that the district court did not err by (1) concluding that Appellants were jointly and severally liable for JCCS' damages; (2) concluding that the Covenant was reasonable; (3) awarding prejudgment interest but erred with regards to the date interest began accruing; and (4) by denying Appellants' motion for discovery sanctions. View "Junkermier, Clark, Campanella, Stevens, P.C. v. Alborn" on Justia Law

The Supreme Court reversed the judgment of the district court adjudicating that Defendant satisfied the judgment debt on Plaintiff's successful breach of contract claim, holding that the district court erred in adjudging Plaintiff's judgment fully satisfied without inclusion of additional post-judgment interest that continued to accrue during a stay of execution obtained by Defendant pending appeal.A jury returned a verdict awarding Plaintiff contract damages. Plaintiff appealed adversing rulings on her other claims, and Defendant cross-appealed various adverse trial rulings. Defendant then moved for a stay of execution of judgment, which the district court granted. The Supreme Court affirmed the judgment. On remand, Defendant moved for declaration that it fully satisfied Plaintiff's adverse judgment. The district court granted the motion. The Supreme Court reversed the judgment of satisfaction, holding that the district court erroneously adjudged Plaintiff's judgment fully satisfied without regard for additional post-judgment interest that accrued during the stay of execution pending appeal. View "Warrington v. Great Falls Clinic, LLP" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of Missoula County and declaring that the right-of-way next to Plaintiff's property extends from Rio Vista Drive to the Bitterroot River, as depicted in the subdivision plat, and provides legal access for the public to the river from Rio Vista Drive, holding that the district court did not err.On appeal, Plaintiff argued that the district court erred in determining that the public right-of-way from Rio Vista Drive extends to the banks of the Bitterroot River. The Supreme Court affirmed, holding that the district court correctly determined, when taken together, the subdivision plat donating a right-of-way from Rio Vista Drive to the banks of the river and the Missoula County Board of Commissioners' acceptance of that right-of-way constitute an instrument of conveyance or deed of a right-of-way to Missoula County to hold the conveyance in trust for the public. View "Callsen v. Missoula County" on Justia Law

The Supreme Court affirmed the decision of the district court denying Defendant's motion to suppress the evidence discovered during a police officer's chemical "field test" on the contents of a syringe found in Defendant's jacket pocket, holding that a rudimentary chemical field test of a lawfully seized substance is not a constitutionally protected search requiring a warrant.Defendant was placed under arrest after driving with a suspended driver's license and without vehicle insurance. While searching Defendant incident to his arrest, the arresting officer located a used syringe in Defendant's front jacket pocket. When booking Defendant into jail, the officer conducted a field test on the contents of the syringe. The field test came back positive for methamphetamine. Defendant filed a motion to suppress, arguing that the field test of the syringe's contents without a warrant constituted an unlawful search that violated his reasonable expectations of privacy. The district court denied the motion to suppress. The Supreme Court affirmed, holding that Defendant had no reasonable expectation of privacy violated by a test for the presence of methamphetamine in a syringe lawfully seized from his person, and therefore, Defendant could not assert the constitutional protections afforded to a search. View "State v. Funkhouser" on Justia Law

The Supreme Court affirmed Defendant's conviction of attempted deliberate homicide, holding that a challenged jury instruction did not undermine the fundamental fairness of the proceeding.After a jury trial, Defendant was convicted of attempted deliberate homicide. On appeal, Defendant argued that the district court's "specific purpose" jury instruction warranted review under either the doctrine of plain error or ineffective assistance of counsel and that the prosecutor's comment warranted plain error review by the Supreme Court. The Supreme Court affirmed, holding (1) the trial court's instruction did not result in a manifest miscarriage of justice, and the claimed error by trial counsel in failing to object to the instruction did not prejudice Defendant; and (2) the prosecutor's conduct did not warrant plain error review. View "State v. St. Marks" on Justia Law

The Supreme Court reversed the order of the district court granting summary judgment in favor of Farmers Insurance Exchange on Plaintiff's claim for underinsured motorist (UIM) benefits, holding that Plaintiff's UIM claim was not barred by either the doctrine of issue preclusion or claim preclusion.Plaintiff sued Darrell King alleging damages resulting from injuries he sustained when King rear-ended him. King was insured by Progressive Northwestern Insurance Company, and Plaintiff was insured by Farmers. When Farmers refused to pay Plaintiff anything under his UIM coverage Plaintiff filed a lawsuit against Farmers to recover his UIM benefits. Plaintiff's lawsuit against King subsequently went to trial, and the jury awarded Plaintiff $10,000 in damages. Before the district court entered judgment, the parties settled for $50,000 - the policy limits of King's liability coverage with Progressive. Thereafter, Farmers moved for summary judgment on Plaintiff's UIM coverage claim, arguing that because Plaintiff had settled with King, his UIM claim was barred by issue preclusion and claim preclusion. The district court granted summary judgment for Farmers. The Supreme Court reversed, holding that a contract claim for UIM benefits is wholly distinct and separate from the underlying third-party tort claim, and therefore, Plaintiff's complaint was barred by neither issue preclusion nor claim preclusion. View "Reisbeck v. Farmers Insurance Exchange" on Justia Law