Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the order of the district court dismissing Plaintiff's complaint on the ground that his state common-law tort claims for slander and emotional distress were preempted by the federal Civil Reform Act (the Act), holding that the district court prematurely dismissed the case without the factual record needed to determine preemption.While working at the Montana Veterans Administration Health Care System (Montana VA), Plaintiff had consensual sex with fellow employee Tori Marino. Marino reported that Plaintiff had sexually assaulted her and later recanted her allegation. Marino later told Plaintiff that two other employees of the Montana VA who served as a union president and union steward had told her to falsely accuse Plaintiff in order to avoid losing her job. Plaintiff filed a complaint against Marino, the two employees, and the union seeking damages for slander and emotional distress. The union defendants moved to dismiss the complaint, arguing that the Act preempted Dickson's state-law tort claims. The district court agreed, holding that the union defendants' conduct constituted a "prohibited personnel practice," and therefore, the Act preempted Plaintiff's claims. The Supreme Court reversed, holding that the district court erred in concluding on the allegations of Plaintiff's complaint alone that his claims were preempted by the Act. View "Dickson v. Marino" on Justia Law

The Supreme Court affirmed Defendant's conviction of felony strangulation of his girlfriend, holding the evidence was sufficient to support the conviction, and Defendant did not receive ineffective assistance of counsel.Specifically, the Supreme Court held (1) the evidence was sufficient to sustain Defendant's conviction of felony strangulation; (2) Defendant failed to meet the prejudice standard set forth in Strickland v. Washington, 466 U.S. on his claim that his counsel was ineffective by opening the door to evidence of Defendant's prior violence; and (3) this Court declines to review for plain error Defendant's argument challenging the district court's instruction on the mental state for strangulation. View "State v. Dineen" on Justia Law

The Supreme Court reversed the district court's entry of summary judgment in favor of Elk Grove Development Company (Elk Grove) and the Elk Grove Homeowners Association (HOA) and entry of an injunction enjoining the Four Corners County Water and Sewer District from using the Elk Grove Subdivision's water "sourced from any of the wells located within the Subdivision and from the Water Right for use upon property outside the Subdivision, holding that the district court erred in determining that the Subdivision Covenant was a reasonable restraint upon the alienation of a water right.On appeal, the Water District argued that the Covenant was an unreasonable restraint on alienation because it usurped the State's jurisdiction over its water and violated the state water law requirement that waters be put to beneficial use. The Supreme Court reversed, holding that the district court erred to the extent that it held the Covenant was a reasonable restraint on the alienation of the Subdivision's water and Water Right and so enjoined the Water District. View "Elk Grove Development Co. v. Four Corners County Water & Sewer District" on Justia Law

The Supreme Court affirmed but on different grounds the summary judgment granted by the district court ruling that the equitable doctrine of unjust enrichment precluded the claim brought by Mountain Water Company for a general property tax refund on taxes that accrued during the pendency of a condemnation action initiated by the City of Missoula, holding that Mountain Water contractually waived its right to property tax proration and reimbursement from or against the City under Mont. Code Ann. 70-30-315.Specifically, the Supreme Court held (1) the district court erred in concluding that the doctrine of unjust enrichment precluded relief on Mountain Water's claim for property tax proration and relief under Mont. Code Ann. 70-30-315; (2) the district court erred in concluding that, but for application of equitable unjust enrichment, section 70-30-315 would entitle Mountain Water to a general property tax refund under Mont. Code Ann. 15-1-402(1)-(2), (6)(b)(i) and -406(1)-(3); (3) Mountain Water contractually waived its right to property tax proportion and reimbursement from the City under section 70-30-315; and (4) the district court correctly concluded that Mountain Water's subsequent assertion of a general property tax refund claim did not breach the parties' 2017 condemnation action settlement agreement. View "Mountain Water v. Department of Revenue" on Justia Law

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