Justia Government & Administrative Law Opinion Summaries

Plaintiffs worked within the Child Support Enforcement Division of the Department of Public Health and Human Services and constituted the majority of Compliance Specialists, Pay Band 6, employed by the State. Plaintiffs, who belonged to a Union, filed a grievance with the Board of Personnel Appeals (BOPA) alleging that their pay was not “internally equitable” in comparison with Pay Band 6 Compliance Specialists in other state agencies. A Hearing Officer issued a recommended order holding that Plaintiffs were aggrieved and awarded damages. BOPA, however, rejected the recommended order and dismissed the grievance, concluding that Plaintiffs had no independent right to internally equitable pay with other Pay Band 6 Compliance Specialists, but, instead, internal equity was a factor to be considered during the collective bargaining process. The district court vacated and reversed BOPA’s final order, agreeing with the Hearing Officer that Plaintiffs had a right to pay that was internally equitable with other Pay Band 6 Compliance Specialists. The Supreme Court vacated the district court’s order and reinstated BOPA’s final order, holding that the statutory factor of “internal equity” is not a stand-alone right that may be pursued independently and in preemption of the work of the collective bargaining process. View "Mashek v. Dep’t of Pub. Health & Human Servs." on Justia Law

Fellows filed the underlying complaint challenging the Water Commissioner’s administration of water under the Perry v. Beattie decree. The district court dismissed Fellows’s complaint for failure to state a claim. The Supreme Court reversed and remanded, concluding that Fellows’s allegations were sufficient to state a claim. Fellows then requested the district court to certify a question to the Water Court. The district court granted the request. The Water Court entered a final order that tabulated the water rights necessary to address Fellows’s underlying complaint. By the time of its certification order, the water claims had been adjudicated in a temporary preliminary decree, and therefore, the Water Court ordered that the matter be closed and returned to the district court. The Perry Defendants filed a motion to alter or amend the Water Court’s judgment. The Water Court denied the motion. The Supreme Court affirmed, holding (1) the Water Court correctly followed the law of the case; (2) Fellows’s petition for certification was proper; and (3) the Water Court did not err in defining the scope of the controversy, in determining the purpose of the tabulation, and in tabulating the applicable rights involved in the controversy. Remanded. View "Fellows v. Saylor" on Justia Law

In 2014, the Montana Environmental Information Center (MEIC) filed suit challenging the decision of the Montana Department of Environmental Quality (DEQ) to approve the expansion of Golden Sunlight Mines, Inc.’s (GSM) gold mine to include a nearby pit. DEQ and GSM (together, Appellees) asserted that MEIC should be collaterally estopped from relitigating the question of whether the Montana Constitution and the Montana Metal Mine Reclamation Act (MMRA) require lands disturbed by a mining operation to be fully reclaimed because this precise issue had already been litigated, with MEIC receiving an adverse ruling from the district court. The district court agreed and entered judgment in favor of Appellees. The Supreme Court affirmed, holding (1) the district court correctly found that collateral estoppel precluded MEIC from relitigating whether the Montana Constitution or the MMRA requires land disturbed by the taking of natural resources to be fully reclaimed to its previous condition; and (2) the district court did not err by upholding the DEQ’s decision. View "Mont. Envtl. Info. Ctr. v. Mont. Dep’t of Envtl. Quality" on Justia Law

This appeal concerned individual objectors to the Crow Water Compact, an agreement to distribute and manage water rights among the United States, the Crow Tribe, and the State of Montana. The Supreme Court affirmed the Water Court’s order, holding (1) the Water Court applied the proper legal standard of review in approving the Compact in the final order; (2) the Objectors failed to meet their burden of showing that the Compact was unreasonable and materially injured their interest; and (3) the Compact negotiation process did not violate the Objectors’ due process rights. View "In re Crow Tribe Water Compact" on Justia Law

In 1982, Teton Co-Operative Canal Company (Teton Canal) filed a statement of claim for existing water rights for the Eureka Reservoir. Teton Cooperative Reservoir Company (Teton Reservoir) objected to Teton Canal’s claims. The Water Master held a hearing in 2012 and, in 2015, adjudicated Teton Canal’s claims. Teton Reservoir appealed. The Supreme Court reversed the Water Court’s order regarding Teton Canal’s water right claims to the Eureka Reservoir, holding that the Water Court erred in determining that off-stream water storage in the Eureka Reservoir was included as part of Teton Canal’s April 18, 1890 Notice of Appropriation. Remanded to the Water Court to assign a new priority date to Teton Canal’s rights to the Eureka Reservoir and for further proceedings. View "Teton Co-op Canal Co. v. Teton Coop Reservoir Co." on Justia Law

When Mary Stewart failed to pay real property taxes on her property, the Flathead County Treasurer held a tax lien sale for the delinquent taxes. The County was listed as the purchaser of the tax lien. In 2013, RN & DB, LLC paid the delinquent taxes, penalties, interests, and costs for the property and applied for a tax deed. The County issued a tax deed to RN & DB, after which RN & DB filed an action to quiet title in the property. The district court granted RN & DB’s motion for summary judgment and entered a decree quieting title in favor of RN & DB. The Supreme Court affirmed, holding (1) the district court did not err in not applying the statutory homestead exemption to the tax lien sale on Stewart’s property; (2) Stewart’s claim that the district court should have considered the tax assessor’s failure to investigate Stewart’s complaints regarding irregular tax assessments on Stewart’s property was barred; and (3) the district court did not abuse its discretion in granting summary judgment without holding a hearing. View "RN & DB, LLC v. Stewart" on Justia Law

After Jon Cruson resigned from his position with Missoula Electric Cooperative, Inc., he filed a claim for unemployment benefits with the Montana Department of Labor and Industry’s Unemployment Insurance Division (Department). The Department ultimately granted Cruson unemployment insurance benefits beginning on the date of his resignation. The Hearings Bureau reversed, concluding that Cruson was disqualified from receiving benefits because the reason he offered for quitting did not constitute good cause attributable to his employment. The Board of Labor Appeals affirmed. The district court denied Cruson’s appeal, determining that the Board correctly applied the law to the facts when it determined that Cruson did not voluntarily leave his employment with good cause attributable to his employer. The Supreme Court affirmed, holding that the Board’s factual findings were supported by substantial evidence, and its legal conclusion that “good cause attributable to the employer” had not been shown was correct. View "Cruson v. Missoula Elec. Coop." on Justia Law

Westmoreland Resources Inc. (WRI) mines coal owned by the Crow Tribe and pays coal severance and gross proceeds taxes to the Tribe. In 2005, WRI filed a tax return with the Department of Revenue for coal produced and sold at its Absaloka Mine, located on the Crow Reservation, during tax year 2004. The return deducted the coal severance and gross proceeds taxes it had paid to the Tribe. The Department disallowed WRI’s deduction. WRI filed a complaint with the State Tax Appeal Board. WRI and the Department later filed a joint petition for an interlocutory adjudication of a substantive question of law with the district court. At issue was whether WRI’s coal severance and gross proceeds deduction was proper. The district court held in favor of the Department, concluding that WRI may not deduct taxes paid to the Tribe as “taxes paid on production” from the “contract sales price” when calculating the Resource Indemnity Trust and Ground Water Assessment Tax. The Supreme Court affirmed, holding that the phrase “any tax paid to the federal, state, or local governments” within Mont. Code Ann. 15-35-102(11) does not include those taxes WRI pays to the Tribe. View "Westmoreland Res., Inc. v. Dep't of Revenue" on Justia Law

This case arose from a restriction placed on a certain parcel of real property providing that the land would be used exclusively for agricultural purposes. Greg Hampton, a developer, requested the consent of Lewis and Clark County to revoke the agricultural covenant. The County approved the lifting of the covenant subject to thirteen conditions. Hampton then began working on developing his residence on the parcel. The County later filed a complaint requesting injunctive relief and an order requiring Hampton to complete the conditions. A jury determined that Hampton had notice of the thirteen conditions prior to building his home and that he failed to complete four conditions prior to development. The district court then entered final judgment, ordering Hampton to pay the proportionate share of the cost to upgrade Lodgepole Road to County road requirements, among other orders. The Supreme Court largely affirmed, holding (1) the district court did not err in ruling on summary judgment that the County consented to revocation of an agricultural covenant on Hampton’s property; (2) the district court erred in determining that Hampton was only proportionally responsible for the cost of upgrading Lodgepole Road; and (3) the district court did not err in the remainder of its judgment. View "Lewis & Clark County v. Hampton" on Justia Law

In 1980, the Montana Board of Livestock (Board) adopted the 12-Day Rule, which prohibits the sale of milk in Montana more than twelve days after pasteurization. In 2008, Core-Mark International, Inc. filed a petition with the Board seeking to amend or repeal the 12-day Rule. The Board held an administrative proceeding regarding Core-Mark’s petition, part of which involved a formal evidentiary hearing conducted by an independent hearing examiner. The hearing examiner issued a proposed decision recommending that the Board consider repealing the 12-day Rule. However, the Board voted unanimously to retain the 12-day Rule without modification. The district court denied Core-Mark’s petition for judicial review. The Supreme Court affirmed, holding that the district court did not err (1) in concluding that the administrative proceeding was not a contested case proceeding and therefore not subject to judicial review; (2) by applying the arbitrary and capricious standard of review and in determining that the Board’s decision did not violate that standard; and (3) in concluding that the 12-day Rule is a valid exercise of the Board’s authority. View "Core-Mark Int'l, Inc. v. Mont. Bd. of Livestock" on Justia Law