Wilson v. State
249 P.3d 28 (Mont. 2010)
In Wilson v. State,[1] the Montana Supreme Court held that the Montana State Prison (“MSP”) did not violate a defendant’s constitutional rights when it denied him prescribed psychiatric medication.[2] The Court upheld the district court’s denial of post-conviction relief, finding that the defendant failed to prove MSP “consciously disregarded a substantial risk of serious harm” or acted in a manner that “greatly exacerbate[d] [his] mental illness.”[3] Therefore, the Court held that MSP did not violate the defendant’s Eighth Amendment right against cruel and unusual punishment or his right to individual dignity under the Montana Constitution.[4] Continue reading
Walters v. Flathead Concrete Products, Inc.
249 P.3d 913 (Mont. 2011)
In Walters v. Flathead Concrete Products, Inc.,[1] the Montana Supreme Court affirmed the constitutionality of the Workers’ Compensation Act (“WCA”)—specifically, the constitutionality of the WCA’s exclusive remedy provision and the provision providing a $3,000 lump sum payment to non-dependent parents of a deceased worker.[2] Carol Walters (“Walters”), the mother of a deceased employee, asserted wrongful death and survivorship claims against her son’s employer, Flathead Concrete Products, Inc. (“FCP”).[3] The Court affirmed the district court’s grant of summary judgment for FCP, finding that the WCA’s exclusive remedy provision barred Walters’ claims.[4] Continue reading
State v. Stiffarm
250 P.3d 300 (Mont. 2011)
In State v. Stiffarm,[1] the Montana Supreme Court held that a district court cannot revoke a suspended sentence prior to the commencement of that sentence.[2] The Court relied upon a strict interpretation of Montana Code Annotated § 46–18–203(2), which required that a petition for revocation of a suspended sentence “be filed with the sentencing court during the period of suspension or deferral.”[3] In doing so, the Court overruled a line of cases that allowed a district court to file a revocation petition before the period of suspension.[4] In addition to redefining the permissible period for a district court to revoke a suspended sentence,[5] Stiffarm demonstrates that stare decisis will not sustain a statutory interpretation that contradicts the plain language of a statute.[6] Continue reading
State v. Pearson
251 P.3d 152 (Mont. 2011)
In State v. Pearson,[1] the Montana Supreme Court held that methamphetamine discovered during an unlawful search of a defendant’s fanny pack was admissible under the inevitable discovery doctrine.[2] The Court determined that the officers initiated lawful investigatory proceedings and intended to arrest the defendant prior to the unlawful search.[3] Therefore, a routine inventory search at the police station would have inevitably revealed the methamphetamine.[4] Continue reading
State v. Norquay
248 P.3d 817 (Mont. 2011)
In State v. Norquay,[1] the Montana Supreme Court reached two noteworthy holdings, each matters of first impression in Montana.[2] First, the Court held that admitting a videotaped deposition of the State’s expert DNA witness did not violate the defendant’s right to confront the witness because pregnancy prevented the witness from attending trial.[3] The Court reasoned that since the State made a good faith effort to procure the witness, the district court properly allowed the videotaped testimony.[4] Second, the Court held that the district court’s Allen instruction (a pattern instruction given to encourage deadlocked juries to come to a resolution) did not unduly pressure the jury to reach a unanimous verdict.[5] Nonetheless, the Court adopted significant changes to the Allen instruction.[6] Continue reading
State v. Maine
255 P.3d 64 (Mont. 2011)
In State v. Maine,[1] the Montana Supreme Court modified the requirements that a defendant must meet to render a prior conviction unusable for sentence enhancement.[2] The Court declined to adopt the rigid standard used by the United States Supreme Court, which bars defendants from challenging prior convictions unless they were denied their right to counsel.[3] The Montana Supreme Court acknowledged that the State has an interest in the finality of decisions and modified the existing standard to place a higher burden on defendants to offer affirmative evidence to demonstrate the invalidity of a prior conviction.[4] To render a prior conviction constitutionally infirm—and therefore unusable for purposes of an enhanced punishment on a pending charge—a defendant must prove by a preponderance of the evidence that a previous conviction violated the Constitution.[5] Continue reading
Montana v. Wyoming
131 S. Ct. 1765 (2011)
In Montana v. Wyoming,[1] the United States Supreme Court held that under Article V(A) of the Yellowstone River Compact (“Compact”) neither the doctrine of prior appropriation nor the doctrine of recapture prohibit upstream water-rights users from increasing the efficiency of their irrigation systems, even if the increased use is detrimental to downstream water-rights holders of otherwise equal seniority.[2] In doing so, the Court affirmed the findings of the Special Master and held that Montana’s complaint regarding the increased efficiency of irrigation systems in Wyoming failed to state a claim under Article V(A) of the Compact.[3] Continue reading
Keller v. Liberty Northwest, Inc.
246 P.3d 434 (Mont. 2010)
The risk of misdiagnosis presents a special difficulty to the settlement of Workers’ Compensation claims. Claimants commonly request rescission of settlement contracts based upon mutual mistake regarding their injuries.[2] In Keller v. Liberty Northwest, Inc.,[1] the Montana Supreme Court clarified the burden of proof required to assert mutual mistake in such cases. The Court established that a settlement may be rescinded due to mutual mistake, even if the parties knew about the theory of injury, as long as that theory existed when the parties settled and was “disregarded, forgotten, or not considered.”[3] Continue reading
In re Estate of William F. Big Spring, Jr.
255 P.3d 121 (Mont. 2011)
In the Montana Supreme Court decision, In re Estate of William F. Big Spring, Jr.,[1] the Court revised its subject-matter jurisdiction analysis for regulatory and adjudicatory actions that arise within the exterior boundaries of an Indian reservation.[2] The Court reversed the Ninth Judicial District Court’s denial of the appellants’ motion to dismiss for lack of subject matter jurisdiction over the probate of the estate of William F. Big Spring, Jr., an enrolled member of the Blackfeet Tribe.[3] The estate was located within the exterior boundaries of the Blackfeet Indian Reservation.[4] In an attempt to reconcile clouded Montana caselaw, the Court overruled its precedent and articulated a fresh interpretation of controlling law for Montana courts to determine jurisdiction.[5] The Court held that the proper jurisdictional analysis asks whether the State’s exercise of jurisdiction is preempted by federal law and, if the State’s jurisdiction is not preempted, whether the State’s assumption of jurisdiction would infringe on tribal self-government.[6] Continue reading
Gordon v. Kuzara
245 P.3d 37 (Mont. 2010)
In Gordon v. Kuzara,[1] the Montana Supreme Court held that an operating agreement’s (“OA”) arbitration clause does not apply to judicial dissolution of a limited liability company (“LLC”) when the OA contains no provision addressing judicial dissolution.[2] Policy arguments favoring arbitration were not persuasive to the Court because the OA did not implicate interstate commerce or the Federal Arbitration Act.[3] As a matter of first impression in Montana, the Court determined that because the parties never agreed to arbitrate in the event of a judicial dissolution, the general rule that arbitration agreements between two parties are valid and enforceable did not apply. [4] Continue reading