Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of one count of incest, holding that Defendant was not entitled to reversal of his convictions based on any of his allegations of error.Specifically, the Supreme Court held (1) the district court did not err in finding that Defendant had not demonstrated that the victim's allegations against other male relatives were false and thus inadmissible under the Rape Shield statute; (2) Defendant's ineffective assistance of counsel claim was inappropriate for review on direct appeal; and (3) this Court declines to exercise plain error review to consider whether Defendant received a fundamentally fair trial when the district court did not sua sponte exclude testimony of false reporting statistics. View "State v. McCaulou" on Justia Law

The Supreme Court affirmed the judgment of the district court regarding several orders unfavorable to Plaintiff in this dispute over the development of a subdivision on property containing a floodplain within Lewis and Clark County, holding that there was no error or abuse of discretion.In its challenged orders, the district court dismissed Plaintiff's negligence and negligent misrepresentation claims, denied Plaintiff's motion for a declaratory judgment that Mont. Code Ann. 76-5-109(4) is unconstitutional, dismissed Plaintiff's claims for inverse condemnation and nuisance, and dismissed Plaintiff's suit against the Montana Department of Transportation. The Supreme Court affirmed, holding that the district court (1) did not err in dismissing Plaintiff's inverse condemnation claim; (2) did not err in dismissing Plaintiff's unjust enrichment claim; (3) did not err in finding Mont. Code Ann. 76-5-109(4) was constitutional; and (4) did not err in dismissing Plaintiff's remaining nuisance claims. View "Hamlin Construction & Development Co. v. Mont. Dep't of Transportation" on Justia Law

The Supreme Court affirmed the judgment of the district court rejecting Plaintiff's appeal of the Montana Human Rights Commission's rejection of his claims grounded in political discrimination, holding that while the district court erred in ruling that Appellant had to pursue his 42 U.S.C. 1983 claim under the exclusive remedy of the Montana Human Rights Act (MHRA), claim preclusion now barred him from relitigating that claim.Plaintiff, the undersheriff of Missoula County, was reassigned to the position of senior deputy when his opponent in an election race won the office of Missoula County Sheriff. Plaintiff brought a human rights complaint alleging, inter alia, retaliation, discrimination, and constructive discharge based on his demotion. The Commission denied the complaint. Thereafter, Plaintiff brought this complaint alleging wrongful discharge, intentional infliction of emotion distress, unlawful political discrimination, and unlawful retaliation. The district court dismissed the complaint, holding that the MHRA was Plaintiff's exclusive remedy. The Supreme Court affirmed, holding (1) the district court improperly dismissed Plaintiff's section 1983 claim; and (2) because the underlying facts in Plaintiff's amended complaint were the same as his human rights complaint, the claims were precluded by the final judgment of the administrative proceedings. View "Clark v. McDermott" on Justia Law

The Supreme Court reversed Defendant's conviction of sexual abuse of children, holding that the trial court erred by denying Defendant's motion to suppress, and the error was not harmless.On appeal, Defendant challenged the denial of his motion to suppress the evidence discovered by his parole officer when the officer conducted a warrantless search of Defendant's phone. Defendant argued that the search was unreasonable because it exceeded the scope of his consent and because his parole officer lacked a valid exception to the warrant requirement. The Supreme Court agreed and reversed Defendant's conviction, holding that the probation officer's warrantless search of Defendant's digital photo gallery was not a valid probation search under the Montana Constitution, and the contraband discovered as a consequence of the unlawful search should have been suppressed under the exclusionary rule. View "State v. Mefford" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Defendant of sexual intercourse without consent, holding that Defendant was not entitled to relief on his claims of error.Specifically, the Supreme Court held (1) the district court did not abuse its discretion by excluding evidence related to Defendant's accuser's pending DUI charge in another county; (2) the district court did not violate Defendant's constitutional right to confront the witnesses against him or present his defense by limiting cross-examination of Defendant's accuser regarding alleged leniency she may have received related to her pending DUI case in return for her testimony against Defendant; and (3) the chief prosecutor’s prior representation of Defendant did not deprive the entire Lake County Attorney’s Office of authority to prosecute Defendant. View "State v. James" on Justia Law

The Supreme Court affirmed the order of the district court ruling in favor of Plaintiffs on cross-motions for summary judgment and enjoining the Montana Secretary of State from placing House Bill (HB) 325 on Montana's 2022 general election ballot, holding that the referendum proposal violates the Montana Constitution.In approved, HB 325 will establish seven Supreme Court districts in Montana and requires that Supreme Court justices be elected district by district, rather than statewide. Plaintiffs brought this challenge to the constitutionality of the measure. The district court granted summary judgment for Plaintiffs. The Supreme Court affirmed, holding (1) the district court did not err in determining that the question of the constitutionality of the referendum proposed by HB 325 is ripe for judicial resolution; and (2) the district court did not err in enjoining the Secretary from placing HB 325 on the ballot in the 2022 general election. View "McDonald v. Jacobsen" on Justia Law

The Supreme Court affirmed the order of the district court ruling in favor of Plaintiffs on cross-motions for summary judgment and enjoining the Montana Secretary of State from placing House Bill (HB) 325 on Montana's 2022 general election ballot, holding that the referendum proposal violates the Montana Constitution.If approved, HB 325 will establish seven Supreme Court districts in Montana and requires that Supreme Court justices be elected district by district, rather than statewide. Plaintiffs brought this challenge to the constitutionality of the measure. The district court granted summary judgment for Plaintiffs. The Supreme Court affirmed, holding (1) the district court did not err in determining that the question of the constitutionality of the referendum proposed by HB 325 is ripe for judicial resolution; and (2) the district court did not err in enjoining the Secretary from placing HB 325 on the ballot in the 2022 general election. View "McDonald v. Jacobsen" on Justia Law

The Supreme Court affirmed the judgment of the district court convicting Appellant of incest for the sexual abuse of T.N. and sentencing her to 100 years in prison, holding that there was no error or abuse of proceedings in the proceedings below.Specifically, the Supreme Court held (1) the district court did not violate Defendant's "right to access witnesses" in denying her motion to to conduct pretrial interviews with T.N. and J.M.; (2) the State's failure to lodge with the district court forensic interviews from a different case did not violate Defendant's right to a fair trial, and Defendant was not entitled to a new trial on this ground; and (3) based on the totality of the evidence, this Court declines to employ the doctrine of plain error to review Defendant's claim that the district court should have given a specific unanimity instruction. View "State v. Mathis" on Justia Law

The Supreme Court affirmed the district court's grant of a preliminary injunction temporarily enjoining the implementation of three laws the Legislature enacted in 2021 that regulate or restrict abortion services, holding that there was no error of law or manifest abuse of discretion.In 2021, the Montana Legislature passed into law and the governor signed into law bills regulating or restricting abortions services and providing for various criminal penalties and civil remedies. The district court granted a preliminary injunction, finding that Plaintiffs made a prima facie showing that the challenged laws violated their rights under the Montana Constitution and determining that Plaintiffs would suffer irreparable injury if the challenged laws took effect. The Supreme Court affirmed, holding that either ground on which the district court granted a preliminary injunction would have been sufficient to justify relief. View "Planned Parenthood of Montana v. State" on Justia Law

The Supreme Court affirmed the orders entered by the Fourth and Eighteenth Judicial District Courts denying their requests for preliminary injunctions to enjoin the masking requirements of Defendants, school districts in Missoula and Gallatin Counties, that were adopted in response to the continuing COVID-19 pandemic, holding that the district courts did not err.Plaintiffs filed complaints and motions for preliminary injunctions shortly after Defendants' adoption of the masking policies for the 2021-2022 school year, seeking to enjoin the masking requirements based upon constitutional privacy, individual dignity, and parental rights. Both district courts denied the motions. The Supreme Court affirmed, holding that the district courts did not manifestly abuse their discretion by denying the preliminary injunctions. View "Stand Up Montana v. Missoula County Public Schools" on Justia Law