Stensvad v. Newman Ayers Ranch, 557 P.3d 1240

Vernon K. Stensvad entered a grazing lease with Newman Ayers Ranch, Inc. (Ayers Ranch) for grazing his cattle, with a written lease covering summer rates but no fixed winter rate.
Stensvad performed labor for Ayers Ranch in lieu of some lease payments, but the credit value for his work was disputed and not documented in writing.
A memo, allegedly written by Ayers Ranch but disavowed by it, memorialized a lower winter rate, creating further dispute over payment owed.
In October 2023, Ayers Ranch filed an agister’s lien for over $78,000, seized Stensvad’s cattle, and refused further property access based on unpaid fees.
Stensvad sought and obtained a preliminary injunction ordering his cattle moved to a neutral feed lot. Ayers Ranch appealed, arguing, among other points, that proper findings for a preliminary injunction were not made.
The Supreme Court of Montana remanded for supplemental findings, clarifying the appropriate standard for preliminary injunctions under recently amended Montana law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Must courts address all four factors for preliminary injunctions under new statute?	All four statutory factors should be analyzed and met.	Court failed to make written findings on all four; only addressed irreparable injury.	District court erred by not addressing all four; remanded for supplemental findings.
Is a preliminary injunction proper to challenge an agister’s lien?	Injunctive relief is available and necessary due to potential irreparable harm and disputed amounts due.	Statutory agister’s lien procedures should be exclusive, precluding injunction.	Preliminary injunction can supplement, not displace, statutory proceedings.
Did the district court err in finding no adequate remedy at law?	Harm to herd, reputation, and inability to recover cattle aren't compensable by money damages alone.	Damages are adequate for breach of contract; money, not an injunction, is the remedy.	Injunctive relief proper where harm extends beyond monetary damages.
What is the correct standard for preliminary injunctions?	Adopt flexible 'serious questions' test to align with federal and especially Ninth Circuit practice.	Strict conjunctive application of Winter/U.S. Supreme Court standard required by statute.	'Serious questions' sliding-scale approach adopted as consistent with Ninth Circuit and equitable purpose, but requiring sufficient showing on all four factors.

Sweet Grass Farms v. Board of County Commissioners, 300 Mont. 66 (Mont. 2000) (sets prior Montana standard for preliminary injunctions and emphasizes flexibility)
Winter v. Natural Resources Defense Council, Inc., 555 U.S. 7 (U.S. 2008) (establishes the federal four-part conjunctive test for preliminary injunctions)
Alliance for the Wild Rockies v. Cottrell, 632 F.3d 1127 (9th Cir. 2011) (upholds the "serious questions" test within the federal preliminary injunction framework)
Planned Parenthood of Montana v. State, 409 Mont. 378 (Mont. 2022) (interprets standards for extraordinary remedies and applies the test for preliminary injunctions)