Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the district court vacating its prior order to expunge Justin Dickey's misdemeanor records, holding that the Montana Rules of Civil Procedure apply to proceedings brought under the Misdemeanor Expungement Clarification Act and that the district court properly determined that venue was not proper under Mont. Code Ann. 46-18-1105.Dickey filed a petition for expungement of his misdemeanor criminal records, referred only to "misdemeanor criminal record(s)" generally. The district court granted the petition. On reconsideration, the district court vacated its prior expungement order and dismissed the matter, determining that venue was improper. The Supreme Court affirmed, holding (1) the Rules of Civil Procedure apply to a proceeding brought under the Expungement Act; and (2) the district court did not err in determining that Dickey's prior speeding violation in Kalispell was insufficient to establish proper venue in the Eleventh Judicial District for expungement of misdemeanors under section 46-18-1105. View "In re Dickey" on Justia Law

The Supreme Court affirmed in part and reversed in part the sentence and financial assessments imposed by the district court in connection with Defendant's conviction for driving under the influence (DUI), fourth or subsequent offense, holding that the district court erred by assessing a $500 surcharge in compliance with Mont. Code Ann. 46-18-236(1)(b).The district court imposed the statutory minimum fine of $5,000 for felony DUI and sentenced him to a thirteen-month commitment to the Department of Corrections, followed by a three-year suspended sentence subject to certain terms and conditions. Defendant appealed, challenging the denial of his sentencing objections. The Supreme Court affirmed, holding that the district court (1) did not err by assessing the $5,000 fine; (2) did not err by assessing the cost of imprisonment, probation, and alcohol treatment pursuant to Mont. Code Ann. 61-8-731(4)(b); (3) did not err by assessing a $100 fine pursuant to Mont. Code Ann. 46-18-232(1); but (4) erred by assessing the $500 surcharge without considering Defendant's ability to pay. View "State v. Ingram" on Justia Law

The Supreme Court reversed the jury verdict of the district court following Defendant's conviction of incest against his ten-year-old stepdaughter, holding that the district court erred when it granted the State's motion in limine excluding the testimony of Defendant's expert witness regarding general information of false reports in child sexual abuse cases.In granting the State's motion in limine, the district court deemed Defendant's expert witness unqualified to testify under State v. Scheffelman, 820 P.2d 1293 (Mont. 1991), which allows a party to elicit expert testimony that directly comments on an alleged victim's credibility if the expert satisfies certain criteria. The Supreme Court reversed, holding that the district court erred by applying the Scheffelman exception criteria to exclude the expert witness's testimony, and the error was not harmless. View "State v. Reams" on Justia Law

The Supreme Court reversed the holding of the district court that Farmers Insurance Exchange had no duty to defend the Insureds in this case but reversed the district court's holding that the duty to indemnify was not justiciable, holding that when there is no duty to defend there cannot be a duty to indemnify.Defendants in two underlying lawsuits (together, the Insureds) tendered the claims to Farmers, with whom they had a homeowners insurance policy. Farmers concluded that coverage was not available because the claims asserted intentional conduct by the Insureds and filed the instant declaratory judgment action to confirm that it did not have a duty to defend or indemnify. The district court granted summary judgment to Farmers, concluding that there was no coverage under the policy and that the issue of indemnification was not justiciable. The Supreme Court affirmed in part and reversed in part, holding that the district court (1) correctly concluded there was no coverage under the policy; (2) did not abuse its discretion in denying the Insureds more time for discovery; but (3) erred in concluding that the issue of whether Farmers had a duty to indemnify was not justiciable. View "Farmers Insurance Exchange v. Wessel" on Justia Law

The Supreme Court affirmed the judgment of the district court granting motions to dismiss filed by Farmers Insurance Exchange and State Farm Fire and Casualty Company, holding that the district court did not err in granting the motions to dismiss.Plaintiffs filed a complaint against State Farm and Farmers alleging, among other claims, common law bad faith and violation of the Unfair Trade Practices Act. The insurers filed motions to dismiss. The district court granted the motions to dismiss. The Supreme Court affirmed, holding that the district court did not err in dismissing Plaintiffs' bad faith claims on the basis that the liability of State Farm and Farmers was not reasonably clear. View "Shepard v. Farmers Insurance Exchange" on Justia Law

The Supreme Court affirmed the ruling of the district court that the Montana Board of Pardons and Parole did not violate Appellant's statutory or constitutional rights in denying Appellant's parole request, holding that the district court did not err.Appellant sought judicial review of the Board's decision, claiming that the Board denied him his right to know, right to participate, or right to due process when it denied him parole without first furnishing him a copy of documents on which the Board relied in making its decision. Appellant further argued that the Board unlawfully relied on a guideline without having adopted it as an administrative rule pursuant to the Montana Administrative Procedure Act. The district court granted summary judgment for the Board. The Supreme Court affirmed, holding (1) where the guideline was not the reason for the Board's decision, Appellant could not demonstrated the likelihood of a different outcome; and (2) the Board did not violate Appellant's right to know, right to participate, or due process rights. View "Miller v. Montana Board of Pardons & Parole" on Justia Law

The Supreme Court affirmed the ruling of the Workers' Compensation Court that Mont. Code Ann. 39-71-703(2) did not violate Appellant's right to equal protection by denying an impairment award to a worker with a Class 1 impairment who has suffered no wage loss, holding that the statute passes rational basis muster under the Equal Protection Clause of the Montana Constitution.Section 39-71-703(2) allows impairment awards for claimants without actual wage loss only if they have a Class 2 or higher impairment rating. Appellant, who was designated as Class 1 and was denied an impairment award, challenged the statute, arguing that it violated her constitutional right to equal protection because other workers with different injuries but the same whole-person impairment percentage would receive the award. The WCC denied the challenge. The Supreme Court affirmed, holding that the WCC did not err in its determination that section 39-71-703(2) did not violate the Equal Protection Clause. View "Hensley v. Montana State Fund" on Justia Law

The Supreme Court affirmed the order of the district court providing for the dissolution of the Johns Brothers Farms partnership, accounting of the partners' capital accounts, and settlement and distribution of partnership assets, holding that the district court did not err.Brothers Jerry Johns and Jule Nathan "Butch" Johns began farming together as a partnership in 1980. In 1994, the brothers each formed a corporation to hold their individual interests, and the corporations became the partners in Johns Brothers Farms. In 2013, the brothers agreed to dissolve the partnership and distribute the assets between the partners. The next year, Jerry commenced this action to dissolve Johns Brothers Farms, for settlement of capital accounts, and for distribution of partnership assets. In 2020, the district court issued its findings of fact, conclusions of law, and judgment. Butch appealed. The Supreme Court affirmed, holding that the district court (1) did not err by concluding that Jerry did not breach his fiduciary duty to Butch and the partnership; (2) did not err in its calculation of the capital account balances for Jerry and Butch; and (3) did not err by awarding Jerry the forty-acre parcel in its distribution of partnership assets. View "Jackpot Farms, Inc. v. Johns Farms, Inc." on Justia Law

The Supreme Court affirmed Defendant's conviction of aggravated sexual intercourse without consent, holding that the district court did not abuse its discretion in failing to find Defendant's concerns of ineffective assistance of counsel "seemingly substantial" or by declining to grant a trial continuance.On appeal, Defendant argued that the district court abused its discretion by (1) denying his request for a continuance of the jury trial, and (2) failing to open a formal inquiry into the effectiveness of counsel following Defendant's pretrial expressions of lack of confidence. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by declining to grant Defendant's request for a continuance before trial; and (2) even if Defendant's lack of confidence did constitute a request for substitute counsel, the district court's response was an adequate initial inquiry to determine whether Defendant's concerns were "seemingly substantial." View "State v. Dillingham" on Justia Law

The Supreme Court affirmed the order of the district court denying Defendant's motion to dismiss the charge of vehicular homicide while under the influence, holding that Mont. Code Ann. 61-8-411 does not violate either the substantive due process or equal protection guarantees of the state and federal constitutions.Defendant filed a motion to dismiss the charges, arguing that section 61-8-411 was facially unconstitutional as a violation of his substantive due process rights. The district court denied the motion to dismiss. On appeal, Defendant argued that the legislature could have made a more scientifically based policy choice to keep drivers impaired by THC off the road and that the statute unconstitutionally creates classifications. The Supreme Court affirmed, holding that Mont. Code Ann. 61-8-411 is rationally related to the government's compelling interest in keeping drug-impaired drivers off the road. View "State v. Jensen" on Justia Law