Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed Defendant's conviction for sexual assault, holding that the municipal court erred when it instructed the jury on a definition of "consent" from the 2017 sexual assault statute and not the applicable 2015 statute, and the erroneous jury instruction prejudicially affected Defendant's substantial rights.At trial, the court instructed the jury, over Defendant's objection, on the definition of consent contained in recent amendments to the sexual assault statute. On appeal, Defendant argued that the municipal court failed to apply the correct law when instructing the jury on the elements of the claimed offense. The district court denied the appeal. The Supreme Court reversed, holding (1) the instructions, as a whole, did not fully and fairly instruct the jury on the law applicable to the case; and (2) Defendant's substantial due process right was prejudiced by the erroneous jury instruction. View "City of Missoula v. Zerbst" on Justia Law

The Supreme Court reversed the order of the district court granting Continental Resources, Inc.'s motion to dismiss for lack of specific personal jurisdiction Plaintiff's complaint alleging that Continental was liable for the death of Zachary Buckles, holding that Plaintiff raised sufficient facts to withstand a motion to dismiss.Buckles died at a North Dakota oil well site owned by Continental, allegedly from exposure to high levels of hydrocarbon vapors while manually gauging tanks. The district court concluded that Continental, an Oklahoma corporation authorized to do business in Montana, was not subject to specific personal jurisdiction because the events leading to Buckles' death did not satisfy Montana's long-arm statute and because exercising jurisdiction over Continental would violate the United States Constitution's Due Process Clause. The Supreme Court reversed, holding that Continental failed to present a compelling case that jurisdiction would be unreasonable should Plaintiff prove her claims. View "Buckles v. Continental Resources, Inc." on Justia Law

The Supreme Court reversed Defendant's drug-related convictions, holding that the district court abused its discretion in admitting evidence regarding Defendant's prior DUI convictions, and the error was not harmless.Defendant was convicted of criminal possession of dangerous drugs, methamphetamine, a felony; criminal possession of dangerous drugs, marijuana, a misdemeanor; and criminal possession of drug paraphernalia, a misdemeanor. On appeal, Defendant argued, among other things, that the district court erred in allowing testimony concerning her prior DUI convictions. The Supreme Court reversed the convictions and remanded the case for a new trial, holding that because the probative value of the evidence was substantially outweighed by the danger of unfair prejudice, the evidence was inadmissible under Mont. R. Evid. 403. View "State v. Clausen" on Justia Law

In this property dispute, the Supreme Court reversed the decision of the district court granting Defendant's motion to stay proceedings without holding a hearing on Plaintiff's motion for a preliminary injunction, holding that the district court abused its discretion by staying proceedings and denying Plaintiff's motion for preliminary injunction without a hearing.Plaintiff filed suit against Title Insurer seeking damages for breach of contract and bad faith. In a separate suit, Plaintiff sued Defendant seeking a declaration that Moss Agate Road was either a county road, public highway, or that the public enjoys a prescriptive easement across Moss Agate. Plaintiff filed a motion for a temporary restraining order and preliminary injunction seeking to enjoin Defendant from interfering with Plaintiff's access to its property over Moss Agate. Defendant then filed a motion to stay proceedings. Without holding a hearing, the district court stayed proceedings in Plaintiff's case against Defendant pending the resolution of Plaintiff's case against Title Insurer. The Supreme Court reversed, holding that because the bad faith case did not cover all the issues in the instant matter, the district court manifestly abused its discretion by denying Plaintiff's motion for preliminary injunction without holding a hearing. View "Flying T Ranch, LLC v. Catlin Ranch, LP" on Justia Law

The Supreme Court affirmed the post-judgment order of the district court requiring David Ruis to pay his ex-wife, Twila Ruis, a cash equalization payment plus interest in accordance with the court's earlier dissolution decree, holding that the court did not abuse its discretion or otherwise err in awarding Twila the cash equalization payment originally determined in the decree, together with judgment interest.David appealed, arguing that the eventual sale of the parties' marital home rendered the cash equalization payment inequitable, which made the award of post-judgment interest on that payment amount an abuse of discretion. The Supreme Court affirmed, holding (1) the district court did not act arbitrarily or exceed the bounds of reason when it awarded Twila the cash equalization payment originally contemplated in the decree even though David did not refinance and retain the property; and (2) the district court did not err in awarding Twila judgment interest or err in its calculation of judgment interest. View "In re Marriage of Ruis" on Justia Law

The Supreme Court reversed the judgment of the district court dissolving Sam Mahlum's marriage to Terri Elder and equitably apportioning the parties' marital estate, holding that the district court erroneously characterized and divided Sam's early disability retirement benefit as a divisible marital estate asset rather than the equivalent of post-dissolution employment income.Before the district court, the only significant matter in dispute was the status of Sam's disability retirement benefits from the Montana Sheriff's Retirement System (SRS) and whether the benefits were a divisible marital asset or the indivisible equivalent of future earnings. The district court concluded that Sam's SRS disability benefits were a divisible marital asset. The Supreme Court reversed, holding that the district court erred in characterizing Sam's post-dissolution SRS disability retirement benefits as a marital estate under Mont. Code Ann. 40-3-202(1). View "In re Marriage of Elder & Mahlum" on Justia Law

The Supreme Court affirmed the order of the district court terminating Father's parental rights to his child, A.L.P., holding that the district court erred when it based its finding that Father's treatment plan was unsuccessful solely on Father's incarceration, but the error was harmless.In terminating Father's parental rights, the district court found that Father had not successfully completed his treatment plan. The court further found clear and convincing evidence to conclude that the child was adjudicated as a youth in need of care, that Father had not successfully completed his treatment plan, that his conduct or condition was unlikely to change within a reasonable time, and that it was in the best interests of the child to terminate Father's parental rights. The Supreme Court affirmed, holding (1) the court erred in finding that Father failed successfully to complete his treatment plan resulting solely from his incarceration, but the error was harmless in light of the fact that the district court made express findings that rendered a treatment plan unnecessary; and (2) the district court did not abuse its discretion when it concluded that it was in the child's best interests to terminate Father's parental rights. View "In re A.L.P." on Justia Law

The Supreme Court affirmed the district court's order granting summary judgment in favor of Sisters of Charity of Leavenworth Health System, Inc. (SCL) on Cheryl Bratton's claims, holding that the district court did not err by granting summary judgment to SCL.This case stemmed from SCL's practice of issuing refunds to its patients, for such reasons as overpayment on an account, in the form of prepaid MasterCard debit cards issued through Bank of America. Plaintiff brought this suit alleging, among other claims, constructive trust based on unjust enrichment, unfair trade practices under the Montana Consumer Protection Act (MCPA), money had and received, and declaratory judgment. During discovery, SCL asked Bank of America to issue checks to Bratton for her refunds, which Bank of America did. The district court granted summary judgment for SCL. The Supreme Court affirmed, holding that the district court did not err by granting summary judgment to SCL on Bratton's claims and by denying Bratton's cross motions for summary judgment. View "Bratton v. Sisters of Charity of Leavenworth Health System, Inc." on Justia Law

The Supreme Court affirmed the order of the district court denying Defendant's request for credit for time served while he was released on bail during the pendency of his probation revocation proceeding, holding that a district court did not abuse its discretion in denying credit for "street time" served under the sentence.Defendant was sentenced for two counts of felony partner or family member assault. Later, the district court found that Defendant had violated the terms of his suspended sentence. Defendant requested that the district court grant him credit against his sentence under Mont. Code Ann. 46-18-203(7)(b) for four months of "street time" he had served on his sentence between his release on bond and sentencing. The district court denied the request. The Supreme Court affirmed, holding that the district court did not err by denying street time credit because there was evidence in the record that Defendant committed a violation of his sentence during the relevant period. View "State v. Jardee" on Justia Law

The Supreme Court affirmed all but one of Defendant's convictions for six felonies stemming from a Ponzi scheme he devised that defrauded investors of $2 million, holding that one of the convictions violated the "multiple charges statute," Mont. Code Ann. 46-11-410, but the rest of the convictions may stand.Defendant was convicted of exploitation of an older person (common scheme), theft by embezzlement, (common scheme), failure to register as a securities salesperson (common scheme), failure to register a security (common scheme), fraudulent practices (common scheme), and operating a pyramid promotion scheme (common scheme). Defendant appealed, arguing that section 46-11-410(2)(a) precluded his convictions on five of the six counts with which he was charged because they were "included offenses" or "specific instances" of fraudulent practices. The Supreme Court held (1) Defendant's conviction for theft by embezzlement violates section 46-11-410 and must be vacated; but (2) Defendant's remaining convictions do not violate the multiple charges statute. View "State v. Brandt" on Justia Law