Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the district court denying Defendant's petition for postconviction relief, holding that Defendant did not meet his burden of establishing that he received ineffective assistance of counsel.Defendant was found guilty of one count of sexual intercourse without consent and other sexual offenses. The Supreme Court affirmed. Defendant then filed a petition for postconviction relief, arguing that his counsel had rendered ineffective assistance. The district court determined that Appellant had received effective assistance of counsel. The Supreme Court affirmed, holding that Defendant did not carry his burden of establishing that the district court's findings were clearly erroneous and that his counsel's performance was unreasonable or deficient. View "Cheetham v. State" on Justia Law

The Supreme Court reversed the order of the district court denying Appellant's motion for attorney fees under either the private attorney general doctrine or Mont. Code Ann. 13-36-205, holding that the district court abused its discretion in denying fees under the private attorney general doctrine.Appellant won the primary election for the Republican nomination for Sheriff of Musselshell County. Appellant's opponent, Ronnie Burns, filed a petition for a court-ordered recount. The court ordered a recount with parameters set forth by Burns. Appellant intervened in the case and sought an emergency hearing to challenge the parameters as violations of Mont. Code Ann. 13-15-206. The district court found that the parameters were inconsistent with the requirements of the statute and vacated its prior orders. The court subsequently concluded that Appellant had not met the criteria for an award of attorney fees pursuant to the private attorney general doctrine. The Supreme Court reversed, holding that the district court abused its discretion in denying attorney fees to Appellant because the County's actions required Appellant to defend the electoral process for the benefit of all County voters, not merely to exercise his rights to be heard in the proceedings and to be present and represented at any recount. View "Burns v. County of Musselshell" on Justia Law

The Supreme Court reversed the judgment of the district court denying PointCentral, LLC's motion to dismiss third-party claims of Big Sky Vacation Rentals, Inc. (BSVR) pursuant to Mont. R. Civ. P. 12(b), holding that the district court erred in concluding that the PointCentral/BSVR arbitration agreement was invalid or otherwise unenforceable due to lack of mutuality or equitable unconscionability.BSVR and PointCentral entered into an agreement that included a broadly-worded arbitration agreement. After BSVR was sued for contract and tort claims BSVR asserted third-party claims against PointCentral for contribution and indemnification. Based on the arbitration agreement, PointCentral filed a motion for dismissal of BSVR's third-party claims. The district court denied the motion, concluding that the agreement lacked mutual consideration and was thus unenforceable as a matter of generally applicable contract law. The Supreme Court reversed, holding that the district court erred in failing to dismiss BSVR's third-party claims because the arbitration was not unenforceable due to lack of mutuality or equitable unconscionability and did not contravene the letter or underlying purpose or policy of Mont. Code Ann. 27-1-703(4)-(5). View "Big Sky Vacation Rentals, Inc. v. PointCentral, LLC" on Justia Law

In this contract dispute, the Supreme Court affirmed the judgment of the district court awarding Flathead Management Partners (FMP) $191,876 in expectancy damages, holding that the district court did not err when it denied Gary Jystad's motion for judgment on the pleadings and when it concluded that the contract at issue was enforceable.After a fire destroyed Jystad's home he entered into a contract with FMP to restore the property and to oversee the reconstruction of the main residence. After the parties worked together for a few months, Jystad informed FMP that the contract was void because it did not contain the statutorily required disclosures for a general contractor constructing a new residence. FMP filed this action claiming expectancy damages for the full contract price. The district court granted judgment for FMP, holding that FMP was not a general contractor and that the contract was not for the construction of a new residence. The Supreme Court affirmed, holding (1) the district court did not err when it determined that the contract was not for the construction of a new residence and that FMP was not a general contractor; and (2) the court did not abuse its discretion in the award of damages. View "Flathead Management Partners, LLC v. Jystad" on Justia Law

The Supreme Court affirmed the order of the district court dismissing Jennifer Hansen's petition for dissolution of marriage on the basis that she failed to establish a common law marriage with Thomas Roffe, holding that the district court correctly ruled that the parties' relationship was not spousal.Specifically, the Court held that the record reflected the parties' mutual decision to remain as life partners throughout their ten-year relationship, not spouses, and that the district court was correct in finding that Roffe did not consent to the marriage and that the public did not view Roffe and Hansen as a married couple. Therefore, the Court held that Hansen failed to meet her burden of proving by a preponderance of the evidence that a common law marriage existed with Roffe. View "In re Marriage of Hansen & Roffe" on Justia Law

The Supreme Court affirmed the judgment of the district court finding that a common law marriage existed between the parties in this case and awarding spousal maintenance and child support and equitably dividing the property.As a result of finding a valid common law marriage, the district court awarded spousal maintenance to be paid by Karen Nelson to Lora Adami, equitably divided the parties' estate, calculated Nelson's child and medical support, and awarded Adami attorney's fees. The Supreme Court affirmed, holding that the district court (1) did not err in concluding that Adami established a common law marriage with Nelson; (2) did not commit procedural errors requiring reversal; (3) did not abuse its discretion in granting a variance from child support guidelines in its calculation of child support; and (4) did not err in awarding Adami attorney's fees. View "In re J.K.N.A." on Justia Law

The Supreme Court affirmed the jury verdict and sentence of the district court convicting Defendant of two counts of robbery, one count of conspiracy to commit deceptive practices as part of a common scheme or plan, and one count of criminal possession of dangerous drugs, holding that the district court did not err in denying Defendant's motions to suppress evidence, and the court's admission of certain cell phone location records was harmless error.Specifically, the Court held that the district court (1) did not err when it denied Defendant's motion to suppress the evidence seized from his residence; (2) did not err when it denied Defendant's motion to suppress evidence found in Defendant's truck by law enforcement; (3) did not err when it denied Defendant's motion to suppress the evidence found in his truck by an auction lot employee after the truck was searched and released from law enforcement custody; and (4) erred in admitting records containing the location of Defendant's cell phone during the robberies, but the error was harmless. View "State v. Burchill" on Justia Law

The Supreme Court affirmed the judgment of the district court terminating Father's rights to his two children, holding that the district court did not abuse its discretion.Specifically, the Court held (1) the district court erred by proceeding without applying the requirements and standards of the Indian Child Welfare Act (ICWA) during the first year of the case, but the violations did not require invalidation of the proceedings; (2) even if the Department of Public Heath and Human Services, Child and Family Services Division (Department) failed to provide proper notice of the proceedings to the Little Shell Tribe as required by ICWA, any error was harmless; (3) the Department provided Father with active efforts to reunify his family; and (4) the district court applied the correct standards when terminating Father's parental rights, and the court's finding that Father was unlikely to change in a reasonable period of time was supported by substantial evidence and not an abuse of discretion. View "In re S.B." on Justia Law

The Supreme Court reversed the district court's entry of summary judgment in favor of the Estate of Allen J. Longsoldier, Jr. declaring that Hill County was vicariously liable for the negligence of the Northern Montana Hospital (NMH) under the non-delegable duty doctrine, holding that Hill County could not be held vicariously liable for NMH's medical negligence.Longsoldier, who was being detained at the Hill County Detention Center, died at NMH due to the effect of alcohol withdrawal syndrome. Longsoldier's Estate filed this negligence action against Hill County, arguing that it had a non-delegable duty to provide Longsoldier with reasonable medical care and was therefore vicariously liable for NMH's medical negligence. The district court concluded that Hill County was vicariously liable for NMH's actions on the ground that public policy dictated the creation of a non-delegable duty. The Supreme Court reversed, holding that under the proper tests, Hill County was not vicariously liable for NMH's medical negligence. View "Estate of Longsoldier v. Blaine County" on Justia Law

The Supreme Court reversed the district court's order granting summary judgment to Arnold Bakie and determining that Mines Management, Inc.'s (MMI) use of an adit and underground tunnel traversing Defendants' unpatented mining claims constituted trespass, holding that the district court erred in determining that Bakie possessed valid unpatented mining claims, thus entitling him to summary judgment, and in determining that MMI's use of the adit and underground tunnel constituted a trespass.MMI filed a complaint against Bakie and other defendants seeking a declaratory judgment that the mining claims owned by Defendants were invalid. Defendants countersued, alleging that MMI's use of the adit and underground tunnel constituted a trespass. The district court granted summary judgment to Bakie, determining that Bakie's claims were valid unpatented mining claims and that MMI was liable for trespass. The Supreme Court reversed, holding (1) the district court erred in granting summary judgment for Bakie because there was no evidence of valuable mineral deposits on the claims at issue; and (2) for the same reasons, the district court erred in determining that MMI committed trespass by using the adit and underground tunnel. View "Mines Management, Inc. v. Fus" on Justia Law