Marriage of Carle v. Steyh
2015 MT 193
| Mont. | 2015Background
- This Montana Supreme Court case involves William T. Steyh appealing a district court ruling on judicial admissions and evidentiary preclusion in a post-dissolution property dispute.
- The marriage of Julie A. Carle Steyh and William Steyh ended in a March 16, 2012 final dissolution hearing, with the Hobson Street house a central asset.
- William defaulted on Julie’s dissolution petition, and the district court adopted Julie’s asset distribution including a $30,000 equalization payment.
- During the 2012 hearing, the court questioned the financing and equity in the Hobson Street home, referencing appraisals around $235k and $265k.
- On remand after prior reversal, the parties conducted discovery and prepared for a bench trial focused on the house’s value and condition; evidence timing became central.
- The district court later held William’s 2012 statements about the home’s value constituted judicial admissions, precluding post-2012 evidence, which the Supreme Court later reversed and remanded on the valuation issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the 2012 statements were judicial admissions. | Steyh contends the statements were not unequivocal admissions of fact. | Steyh asserts the statements were factual admissions by the party. | Not a judicial admission; statements were not unequivocal facts. |
| Whether excluding post-2012 evidence on value was reversible error. | Steyh argues he was entitled to present valuation evidence upon remand. | Steyh's opponents contend admissions foreclose further evidence. | Reversed on remand to permit valuation evidence consistent with remand direction. |
Key Cases Cited
- Bilesky v. Shopko Stores Operating Co., LLC, 338 P.3d 76 (Mont. 2014) (defines judicial admissions and requires unequivocal statements of fact)
- Stevens v. Novartis Pharms. Corp., 247 P.3d 244 (Mont. 2010) (unequivocal fact statements required for binding admissions)
- Kohne v. Yost, 818 P.2d 360 (Mont. 1991) (judicial admissions require explicit concession of truth)
- Weaver v. State, 310 P.3d 495 (Mont. 2013) (review of judicial admission determinations as findings of fact and law)