Alto Jake Holdings, LLC v. Donham
2017 MT 297
| Mont. | 2017Background
- Tenants Donham and Clemm rented two mobile homes from Alto Jake Holdings; landlord sued in justice court for unlawful detainer, seeking possession, $450 back rent, damages, costs, and attorney fees.
- At bench trial, landlord introduced a signed lease and evidence estimating repairs and contamination costs (~$20,583); tenants counterclaimed for breach due to uninhabitable conditions but lost at trial.
- Justice Court entered judgment for landlord totaling $21,950 (damages + $1,426 costs/fees). After tenants moved to set aside for lack of notice, court vacated and then re-entered the November judgment on December 19, 2016.
- Tenants timely filed a notice of appeal and an in forma pauperis (IFP) motion in justice court; the record was transmitted to district court "subject to subsequent approval" of the fee waiver. District Court mailed briefing-deadline notice; tenants failed to file a brief within the rule period.
- District Court dismissed the appeal under U.M.C.R. App. 14(c) for failure to timely file a brief. On independent review, the Supreme Court affirmed dismissal for failure to prosecute but held the Justice Court exceeded its $12,000 money-jurisdiction limit and remanded to correct the judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether District Court lacked jurisdiction to dismiss appeal for failure to file brief before ruling on IFP motion | Alto Jake: briefing rules governed; district court could dismiss for failure to prosecute | Tenants: § 25-33-201/§ 25-10-404 require district court to rule on IFP before briefing deadline runs, so no jurisdiction to dismiss | Court held district court had jurisdiction on receipt of the justice-court record (subject to later IFP ruling) and did not err in dismissing under U.M.C.R. App. 14(c) |
| Whether Justice Court awarded money judgment exceeding its $12,000 jurisdictional limit | Alto Jake: damages proven supported the award as presented | Tenants: (did not preserve objection below) argued insufficiency/other defenses earlier | Court held Justice Court exceeded its $12,000 limit by awarding $20,524 in compensatory damages; reversed and remanded to enter corrected judgment of $13,426 ($12,000 damages + $1,426 costs/fees) |
Key Cases Cited
- Dime Ins. Agency v. Johnson & ISC Distributors, 279 Mont. 121 (1996) (district court may allow filing of required undertaking prior to hearing on appellee's motion to dismiss)
- Berry v. Seman, 245 Mont. 335 (1990) (strict compliance with notice of appeal and undertaking is required to vest district court jurisdiction)
- Stanley v. Lemire, 334 Mont. 489 (2006) (appellate review of justice-court records is independent; district court acts as intermediate appellate court)
- Goldsmith v. Lane, 226 Mont. 341 (1987) (addressed sufficiency of undertaking; later discussed/overruled on point by Dime Ins.)
- Jenkins v. Carroll, 42 Mont. 302 (1910) (historical authority on jurisdictional effect of appeal perfection requirements)