Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the decision of the district court upholding a hearing officer's conclusion that Montana State University-North (MSU-N) retaliated against Dr. Randy Bachmeier for reporting and pursuing a claim of sexual harassment against his supervisor, holding that the district court erred in reinstating the hearing officer's first decision as the final agency decision in this matter.The hearing officer's original order concluded that Bachmeier failed to demonstrate that his supervisor sexually harassed him but that MSU-N retaliated against Bachmeier. The HRC rejected the hearing officer's conclusion that Bachmeier was discriminated against, upheld the hearing officer's retaliation conclusion, and remanded the case. The hearing officer issued a second decision concluding that Bachmeier had been sexually harassed. The Montana Human Rights Commission (HRC) then issued a final agency decision reducing the damages award for sexual harassment but leaving untouched the retaliation award. The district court voided the hearing officer's second decision and remanded with instructions to reinstate the hearing officer's first decision as the final agency decision. The Supreme Court reversed in part, holding that the district court (1) abused its discretion by concluding that the HRC did not have the authority to modify the hearing officer's first decision; and (2) correctly upheld the hearing officer's retaliation conclusion. View "Montana State University-Northern v. Bachmeier" on Justia Law

The Supreme Court affirmed Defendant's conviction of driving under the influence of alcohol (DUI), fourth or subsequent offense, holding that the district court did not abuse its discretion in denying Defendant's motion to dismiss for insufficient evidence and in denying Defendant's motion for mistrial.On appeal, Defendant argued that the State had failed to meet its burden of proving that he was on a "way of this state open to the public" because he was found by a police officer in a vehicle that was parked in a permitted parking spot. The Supreme Court affirmed, holding (1) there was sufficient evidence for the jury to assess whether the parking space at issue was adapted and fitted for public travel and in common use by the public, and therefore, the district court did not abuse its discretion when it denied Defendant's motion to dismiss for insufficient evidence; and (2) the district court did not abuse its discretion when it denied Defendant's motion for a mistrial based on allegations of prosecutorial misconduct. View "State v. Krause" on Justia Law

The Supreme Court affirmed the order of the Montana Water Court establishing the point of diversion for two claims owned by Carolyn Mack and Chriss Mack, 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 when it concluded that it had jurisdiction over the Macks' amended statement of claim; (2) did not abuse its discretion in concluding that the Macks did not make any judicial admissions in previous litigation; (3) did not err in assigning the burden of proof to Appellants - Glenda, Jimmy, John, and Rowdy Anderson; and (4) did not abuse its discretion in excluding the Andersons' expert witness. Lastly, the Supreme Court held that the Water Court's findings of fact were not clearly erroneous and that there was substantial evidence supporting the Water Court's conclusion establishing the point of diversion for the Macks' claims. View "Mack v. Anderson" on Justia Law

The Supreme Court affirmed Defendant's conviction of incest, holding that the district court did not err by precluding Defendant from introducing extrinsic evidence to challenge the victim's credibility.On appeal, Defendant argued that his defense was prejudiced because he was prohibited from demonstrating the victim's bias or motive to testify falsely and that the court's evidentiary ruling violated his right to confrontation under the Sixth Amendment of the United States Constitution and Mont. Const. art. II, 24. The Supreme Court affirmed, holding (1) the district court did not misapply the rules or abuse its discretion in its ruling on the admissibility of evidence; and (2) the district court properly exercised its discretion by imposing reasonable limits on Defendant's evidentiary inquiries. View "State v. Quinlan" on Justia Law

The Supreme Court affirmed the district court's dismissal of the claim brought by the Montana Independent Living Project, Inc. (MILP) that the City of Helena retaliated against it when the City lowered the priority of MILP's request for funding as a result of an unrelated discrimination MILP had filed against the City, holding that the district court properly dismissed MILP as a plaintiff for lack of standing.In granting the City's motion to dismiss, the district court concluded that Mont. Code Ann. 49-2-301 does not allow non-human entities to sue for retaliation, and therefore, MILP had no standing. The Supreme Court affirmed, holding that the district court correctly held that section 49-2-301 does not allow non-human entities to file retaliation claims under the Montana Human Rights Act. View "Maffit v. City of Helena" on Justia Law

The Supreme Court affirmed in part and reversed in part Defendant's convictions for deliberate homicide and tampering with physical evidence, holding that Defendant's constitutional right of confrontation was violated, requiring reversal of his conviction of tampering with physical evidence.On appeal, Defendant argued that he was denied his right under the United States and Montana Constitutions to confront witnesses against him when the State presented a foundational witness in real time by two-way videoconference. The Supreme Court reversed in part, holding (1) furtherance of an important public policy to allow the witness to testify via two-way videoconferencing was not demonstrated in this case, and therefore, the first prong of the analysis set forth in Maryland v. Craig, 497 U.S. 836 (1990), was not satisfied; and (2) Defendant's right to a fair trial was not undermined by the prosecutor's closing argument. View "State v. Mercier" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the district court resentencing Defendant to life without parole for three counts of deliberate homicide committed when he was a juvenile, holding that the district court erroneously concluded that Defendant was irreparably corrupt and permanently incorrigible.Defendant was convicted for three murders he committed when he was seventeen years old and was sentenced to three consecutive life terms without the possibility of parole. Defendant later filed a petition for postconviction relief asserting that his sentence was unconstitutional in light of the Supreme Court's decisions in Miller v. Alabama, 567 U.S. 460, and Montgomery v. Louisiana, 577 U.S. __ (2016). After a hearing, the district court resentenced Defendant to three consecutive life terms. The Supreme Court reversed in part and remanded the case for resentencing, holding that the district court (1) did not err when it appointed a neutral expert for the resentencing hearing; (2) did not err when it denied Defendant's request for a jury to determine whether he was irreparably corrupt and permanently incorrigible; and (3) erred when it refused to consider post-offense evidence of rehabilitation at the resentencing hearing. View "State v. Keefe" on Justia Law

The Supreme Court affirmed Defendant's three convictions for sexual abuse of children (possession of child pornography), holding that Mont. Code Ann. 46-11-410(2)(a) does not prohibit multiple convictions for possession of child pornography when the images were discovered on a single day on a single device.Defendant admitted to downloading several photos and videos depicting child pornography and pled guilty to four counts, reserving his right to appeal the district court's denial of his motion to dismiss as to three of the counts. The Supreme Court affirmed, holding that the district court properly concluded that Mont. Code Ann. 45-5-625(1)(e) allows conviction for each image of child pornography that Defendant possessed. View "State v. Felde" on Justia Law

The Supreme Court affirmed the district court's findings of fact, conclusions of law, and order terminating Mother's parental rights to her three children, holding that Mother's attorney did not provide ineffective assistance of counsel.At issue was whether counsel provided constitutionally ineffective assistance when he stipulated to the request of the Department of Public Health and Human Services, Child and Family Services Division that no reunification services be provided to Mother. The Supreme Court affirmed the district court's termination of Mother's parental rights, holding (1) Mother was not prejudiced by any alleged failure on her attorney's part to object to the Department's request not to provide reunification services; (2) the district court had grounds to terminate Mother's parental rights and made the findings necessary to support termination; and (3) the district court did not err in finding that termination would be in the children's best interests. View "In re D.A.D." on Justia Law

The Supreme Court affirmed the judgment of the district court affirming the order of the City of Missoula Municipal Court denying Appellant's motion to dismiss a petition to revoke sentence, holding that the district court correctly affirmed the municipal court's revocation of Appellant's suspended sentence.In 2017, the City filed a petition to revoke Appellant's sentence for Appellant's compliance violations. Appellant moved to dismiss the petition, arguing that the amendment to Mont. Code Ann. 46-18-2013 removed the municipal court's authority to revoke suspended sentences for compliance violations without first showing the probation office had exhausted all statutory alternatives. The municipal court denied the motion and revoked and reimposed Appellant's twelve-month suspended sentence, concluding that the 2017 changes to the statute do not apply to misdemeanors. The district court affirmed, holding (1) the 2017 amendments to section 46-18-2013 certain only to revocation of felony probation and parole; and (2) the municipal court acted within its authority when it revoked Appellant's suspended sentence for violating its terms and conditions. View "City of Missoula v. Pope" on Justia Law