Lowrie v. State, 2025 MT 166N

Jeremiah Lowrie was subject to an Order of Protection (OOP) prohibiting direct contact with a former partner.
After being reported for violating the OOP a third time, Lowrie was arrested by Officer Nick Ransom and further criminal charges were added; his bond was revoked.
Lowrie, proceeding pro se, filed a civil complaint alleging false imprisonment, false arrest, abuse, and abduction against Ransom, County Attorney Kevin Downs, and the State of Montana, seeking dismissal of criminal charges and $10 million in damages.
Lowrie failed to comply with discovery requests; after a court order to compel and continued noncompliance, the court sanctioned him by dismissing his claims against Ransom with prejudice and awarding $500 in attorney fees.
The District Court granted summary judgment to Downs and the State, finding them immune from damages as Downs acted within his official prosecutorial capacity.
The Supreme Court of Montana affirmed the District Court’s dismissal of Lowrie’s complaint.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dismissal and attorney fees as discovery sanctions was an abuse of discretion	Sanctions were unjustified	Proper notice, noncompliance prejudicial	Dismissal/fees were appropriate, not an abuse of discretion
Whether summary judgment for State based on immunity was error	Actions violated rights; immunity inapplicable	State, acting through Downs as prosecutor, was immune	Prosecutor/State immune as acts were within official duties

Xu v. McLaughlin Research Inst., 328 Mont. 232 (Mont. 2005) (standard for reviewing discovery sanctions; courts may dismiss actions for serious discovery abuses)
Mont. State Univ. v. Mont. First Jud. Dt. Ct., 392 Mont. 458 (Mont. 2018) (defines abuse of discretion)
McAtee v. Morrison and Frampton, PLLP, 405 Mont. 269 (Mont. 2021) (summary judgment standard and burden-shifting)
Obert v. State, 419 Mont. 1 (Mont. 2024) (prosecutorial immunity from civil suit for acts within official duties)