Justia Montana Supreme Court Opinion Summaries

The City of Great Falls unilaterally revised its drug and alcohol policy in 2019, expanding the scope of employees subject to random testing and imposing stricter penalties without negotiating with the affected labor unions. The unions filed unfair labor practice complaints, alleging that the City's actions violated the Montana Public Employees Collective Bargaining Act (MPECBA). The Montana Board of Personnel Appeals (MBPA) consolidated the complaints and referred them to a hearing examiner, who ruled in favor of the unions, concluding that the City's unilateral policy changes constituted unfair labor practices.The City did not file exceptions to the hearing examiner's proposed decision, which became the final agency decision by default. Instead, the City petitioned for judicial review, arguing that the hearing examiner's decision involved purely legal questions that should be reviewed by the court. The District Court of the Eighth Judicial District, Cascade County, dismissed the petition, citing the City's failure to exhaust administrative remedies by not seeking final agency review.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The Court held that the City's failure to exhaust the final agency review remedy provided by MPECBA and the Montana Administrative Procedure Act (MAPA) precluded judicial review. The Court clarified that there is no jurisprudential exception to the exhaustion requirement for purely legal or constitutional questions in the context of MAPA contested case proceedings. The City's petition for judicial review was thus correctly denied and dismissed. View "Great Falls v. Assoc. of Firefighters" on Justia Law

Jeremy Christopher Holmquist was charged with failing to register as a sexual offender in Flathead County, Montana. The case proceeded to a jury trial on September 15 and 16, 2021. During the trial, Detective Buls testified about Holmquist's registration status in Missoula, despite not having personal knowledge of it. The defense objected to this as hearsay, but the court overruled the objection. Holmquist was convicted by the jury and sentenced to five years in Montana State Prison as a persistent felony offender.Holmquist appealed, arguing that the District Court erred in admitting the hearsay statement, which prejudiced his right to a fair trial. The State contended that any error in admitting the statement was harmless. The Montana Supreme Court reviewed the case and determined that even if the District Court erred, the error was harmless.The Montana Supreme Court held that the State provided sufficient admissible evidence proving Holmquist failed to register or keep his registration current. This included Holmquist's own admissions to a police officer that he was noncompliant and had not registered despite being informed of the requirement. The court found that the quality of the admissible evidence was superior to the hearsay statement and that there was no reasonable possibility that the hearsay statement contributed to Holmquist's conviction.The Montana Supreme Court affirmed Holmquist's conviction, concluding that the case was controlled by settled law and the clear application of applicable standards of review. View "State v. Holmquist" on Justia Law

Saul James Dooling was charged with felony theft and several misdemeanors after being apprehended following a high-speed chase in a stolen sedan in Ravalli County, Montana. The vehicle was initially stolen from Jerry’s Transmission in Missoula County. Dooling moved to dismiss the theft charge, arguing that he should be charged in Missoula County where the theft occurred. The District Court denied the motion, reasoning that the State could charge Dooling in Ravalli County because he exerted unauthorized control over the stolen vehicle there.The District Court of the Twenty-First Judicial District, Ravalli County, presided over the case. Dooling entered a plea agreement, pleading guilty to the theft charge and three misdemeanors while reserving the right to appeal the venue issue. The District Court sentenced him to three years with the Department of Corrections, with credit for 181 days served. Dooling did not appeal the misdemeanor convictions.The Montana Supreme Court reviewed the case. Dooling argued that the theft should be prosecuted in Missoula County, where the vehicle was stolen, citing State v. Eagle Speaker. The State countered that Dooling exerted unauthorized control in Ravalli County, making venue there appropriate. The Court held that under Montana law, a person commits theft by either obtaining or exerting unauthorized control over property. Since Dooling exerted unauthorized control in Ravalli County, the charge was proper there. The Court distinguished Eagle Speaker, noting it involved jurisdiction between sovereign nations, not venue within the state. The Court affirmed the District Court’s judgment, concluding that venue was proper in Ravalli County. View "State v. Dooling" on Justia Law

Nancy Jeanne Cahoon was pulled over on September 3, 2021, for expired vehicle registration. She was unable to produce her license, registration, or insurance information and indicated her license might be suspended. The state trooper confirmed her license was suspended and discovered a warrant for her arrest. The trooper noted items in the vehicle consistent with drug use and obtained Cahoon's consent to search the vehicle, finding methamphetamine and drug paraphernalia. Cahoon was arrested and charged with possession of methamphetamine, possession of drug paraphernalia, driving with a suspended license, and failure to have liability insurance.The Twenty-First Judicial District Court, Ravalli County, denied Cahoon's motion to suppress the evidence, arguing the stop was unconstitutionally prolonged. Cahoon failed to appear at the suppression hearing, and her counsel did not object to the court deciding the motion based on the briefs. The District Court concluded the stop was permissibly extended due to Cahoon's active warrant and denied the motion. Cahoon pled guilty without a plea agreement, reserving her right to appeal the denial of the motion to suppress.The Supreme Court of the State of Montana reviewed the case and affirmed the District Court's decision. The Court held that Cahoon failed to preserve her argument regarding her constitutional right to be present at the suppression hearing because it was not properly raised in the lower court. The Court noted that the District Court decided the motion based on the briefs without objection from Cahoon's counsel and that the record was insufficient to address Cahoon's constitutional claim on appeal. The Court affirmed the District Court's denial of the motion to suppress. View "State v. Cahoon" on Justia Law

The City and County of Butte-Silver Bow, Montana (BSB) hired Rhonda Staton as a police officer in 2001, promoting her to detective in 2008. Staton received two verbal reprimands in 2017 and 2018 for tardiness and refusal to investigate underage drinking, respectively. In 2019, Staton filed a hostile work environment complaint, which was not substantiated. In early 2020, Staton lost her department-issued taser, leading to a Fit for Duty Evaluation (FFDE) by Dr. George Watson, who found her unfit for duty. Staton was terminated in August 2020 based on this evaluation and her performance issues.The Butte Police Protective Association (BPPA) filed a grievance on Staton’s behalf, leading to arbitration. Arbitrator A. Ray McCoy found Watson’s FFDE unreliable and ruled that BSB had not established just cause for Staton’s termination. McCoy ordered Staton’s reinstatement, back pay, and an additional evaluation to determine rehabilitative strategies. BSB did not comply with the reinstatement or compensation but arranged for an Independent Medical Evaluation (IME) by Dr. William Patenaude, which did not provide a diagnosis or rehabilitative recommendations.BSB petitioned to vacate the arbitration award, arguing it was a manifest disregard of Montana law. The Second Judicial District Court denied the motion to vacate but remanded the matter to the arbitrator to reconcile the award with Staton’s inability to return to service. BSB appealed.The Supreme Court of the State of Montana reviewed the case and held that the arbitrator’s award did not violate Montana law or public policy. The court found that the District Court abused its discretion by remanding the matter, as it exceeded the permissible scope of review for arbitration awards. The Supreme Court reversed the District Court’s order and remanded with instructions to confirm the original arbitration award. View "Butte v Butte Police" on Justia Law

Craig Thomas Headdress appealed from the Fourth Judicial District Court, Missoula County’s order revoking his suspended sentence and imposing a three-year Department of Corrections (DOC) supervision. Headdress had pled guilty to stalking in 2012 and was sentenced to a three-year suspended DOC commitment, to run consecutively to a sentence he was already serving. He began serving his suspended sentence on March 20, 2020, with several conditions, including obtaining permission before leaving his assigned district, submitting monthly reports, and abstaining from alcohol and illegal drugs.The District Court found that Headdress violated these conditions multiple times. He failed to complete the Enhanced/Transitional Supervision Services (ETSS) program, absconded, and tested positive for methamphetamine. He also failed to maintain contact with his probation officer, Bruce Barstad, and was found in various locations without permission. The State petitioned to revoke his suspended sentence, and the District Court held an evidentiary hearing where Barstad testified about Headdress’s non-compliance.The Montana Supreme Court reviewed the case and affirmed the District Court’s decision. The Court found that Headdress had absconded between August 11, 2021, and December 22, 2021, as he made no attempts to contact his probation officer during this period. The Court determined that Barstad made reasonable efforts to locate Headdress, including issuing a hold order and regularly contacting Headdress’s family. The Court concluded that the District Court did not abuse its discretion in revoking Headdress’s suspended sentence and denying him credit for elapsed time, as he was non-compliant throughout his supervision. View "State v. Headdress" on Justia Law

Lake County sought reimbursement from the State of Montana for costs incurred in enforcing state criminal jurisdiction on the Flathead Indian Reservation under Public Law 280 (P.L. 280). The County argued that the State was obligated to cover these costs, citing financial strain and the diversion of resources from other services.The District Court of the Twentieth Judicial District dismissed Lake County’s claims for unfunded mandate and unjust enrichment, ruling that the statutes of limitations had expired. The court determined that the claims accrued in January 2017, when the County expressed its inability to continue bearing the financial burden of P.L. 280. The court also ruled that the continuing tort and equitable tolling doctrines did not apply to toll the statutes of limitations. The court denied the State’s motion to dismiss the declaratory judgment claim but later granted summary judgment in favor of the State, ruling that the State was not obligated to appropriate any specific amount to reimburse the County.The Supreme Court of the State of Montana affirmed the District Court’s rulings. It held that Lake County’s claims were justiciable but that the continuing tort doctrine did not apply because the County sought monetary damages, not abatement. The Court also ruled that the equitable tolling doctrine did not apply as the County did not pursue a legal remedy within the doctrine’s scope. Finally, the Court held that § 2-1-301(2), MCA, only required the State to reimburse the County to the extent funds were appropriated by the Legislature, which retained discretion over such appropriations. The Court affirmed the dismissal of the unfunded mandate and unjust enrichment claims and the summary judgment on the declaratory judgment claim. View "Lake County v. State" on Justia Law

Richard DuCharme and Jennifer Brick are the parents of two minor children, S.D. and B.D. Their dissolution began in 2017, and since then, Brick has repeatedly refused to honor court-ordered parenting time. In June 2023, after a dispute about summer parenting time, Brick emailed S.D. claiming her father was keeping the girls illegally. Brick's behavior escalated to physical violence when she grabbed S.D.'s hair and punched her. S.D. escaped and reported the incident to the Bozeman Public Safety Center. Brick was charged with Partner Family Member Assault, and DuCharme filed for a temporary order of protection for both children.The District Court of the Eighteenth Judicial District, Gallatin County, granted a temporary restraining order and later held a hearing where S.D. testified about ongoing emotional abuse and the physical assault. The court granted a two-year Order of Protection for S.D. and a six-month Order of Protection for B.D., which was later extended indefinitely due to Brick's violation of the order.Brick appealed, presenting eight issues, including judicial bias, legal entrapment, misuse of court orders, due process violations, prosecutorial misconduct, ineffective assistance of counsel, and erroneous sentencing. The Montana Supreme Court addressed three main categories: the Order of Protection, related proceedings, and judicial bias.The court found that the District Court did not abuse its discretion in granting the Order of Protection based on the history of emotional and physical abuse. Brick's arguments related to criminal proceedings and the parenting matter were not considered as they were not properly before the court. The court also rejected Brick's claim of judicial bias, noting that adverse rulings alone do not constitute bias.The Montana Supreme Court affirmed the District Court's decision. View "Ducharme v. Brick" on Justia Law

Ned Gardner was charged with felony criminal endangerment and felony partner or family member assault in November 2020. The State of Montana did not file a notice to seek persistent felony offender (PFO) status at the omnibus hearing in January 2021. Instead, the State filed the notice under seal in September 2021, two weeks before the trial. Gardner objected to the untimely notice, arguing it did not give him ample time to prepare and that the State did not show good cause for the delay.The Fourth Judicial District Court denied Gardner's objection, reasoning that the late notice did not prejudice him and that he had ample time to object to the PFO designation. Gardner was found guilty of the partner or family member assault charge by a jury in October 2021. In February 2022, the District Court designated Gardner as a PFO and sentenced him to twenty years in prison with a ten-year parole restriction.The Supreme Court of the State of Montana reviewed the case. The court held that the State failed to provide timely notice as required by § 46-13-108(1), MCA, and did not demonstrate good cause for the delay. The court emphasized that timely notice is crucial for a defendant to understand the potential penalties and prepare a defense. The court found that Gardner was prejudiced by the untimely notice, as it affected his ability to make informed decisions about his defense.The Supreme Court reversed the District Court's order designating Gardner as a PFO and remanded the case for resentencing without the PFO designation. View "State v. Gardner" on Justia Law

An employee of Lucky Lil’s Casino in Missoula, Montana, called 911 after failing to wake a man, McClellan, who was slumped over in the driver’s seat of a running vehicle. Officer Champa responded and, after waking McClellan, observed signs suggesting impairment. McClellan could not produce identification, and a search revealed a broken methamphetamine pipe. Further investigation confirmed McClellan’s driver’s license was suspended, and a subsequent search of the vehicle uncovered methamphetamine and drug paraphernalia. McClellan was charged with Criminal Possession of Dangerous Drugs with Intent to Distribute.The District Court of the Fourth Judicial District, Missoula County, denied McClellan’s motion to suppress the evidence, ruling that the officer had particularized suspicion to expand the welfare check into an investigatory stop. McClellan pled guilty, reserving the right to appeal the denial of his motion to suppress.The Supreme Court of the State of Montana reviewed the case, focusing on whether the District Court erred in concluding that the officer had particularized suspicion to expand the welfare check into an investigatory stop. The court affirmed the lower court’s decision, holding that the officer’s actions were justified under the community caretaker doctrine and that particularized suspicion arose during the interaction, allowing the investigatory stop to proceed lawfully. The court found that the officer’s observations and McClellan’s behavior provided sufficient grounds for the investigatory stop and subsequent search. View "State v. McClellan" on Justia Law