Narrative Opinion Summary
In this case, the appellant, Stratford, challenged the Montana Fourth Judicial District Court's decision to set aside two judgments related to delinquent child support owed by Eldredge. The original obligation, established in 1999, was for Eldredge to pay $600 monthly, but he allegedly missed payments, resulting in nearly $100,000 in arrears by the time the child reached adulthood. Stratford pursued judgments for the unpaid support and attorney fees in early 2017, which Eldredge did not initially contest. However, he later filed a Rule 60(b) motion claiming improper service and errors in the support calculations. Although the District Court granted Eldredge's motion, the Supreme Court reversed this decision, emphasizing that the motion was submitted after the applicable 60-day deadline, and the District Court lacked the authority to extend it retroactively. The Supreme Court's de novo review concluded that Eldredge's motion was deemed denied as of June 18, 2017, due to the lapse in the appeal period. Consequently, the case was remanded for a corrected judgment, with the Supreme Court's ruling clarifying procedural adherence in post-judgment relief requests.
Legal Issues Addressed
Deadline for Filing Post-Judgment Motionssubscribe to see similar legal issues
Application: The Supreme Court held that the District Court erred in granting the Rule 60(b) motion filed after the 60-day deadline, as the new rules allowing a 120-day extension did not apply retroactively.
Reasoning: The 60-day deadline expired on June 17, 2017, and Eldredge's reply was filed on July 17, 2017, exceeding both the original and an extended deadline.
De Novo Review of Rule 60(b) Motionsubscribe to see similar legal issues
Application: The Supreme Court conducted a de novo review of the District Court's decision to grant the Rule 60(b) motion, ultimately reversing the decision.
Reasoning: A district court's decision to grant a Rule 60(b) motion after the expiration of the 60-day deadline established by M. R. Civ. P. 60(c)(1) and 59(f) is subject to de novo review.
Rule 60(b) Motion for Relief from Judgmentsubscribe to see similar legal issues
Application: The District Court granted Eldredge's motion to set aside the judgments under Rule 60(b) despite it being filed after the deadline, which was a focal point of the appeal.
Reasoning: Stratford contends that the District Court improperly granted Eldredge’s Rule 60(b) motion, which was filed after the deadline.
Service of Process Requirementssubscribe to see similar legal issues
Application: Eldredge challenged the judgments by asserting improper service, as he was served at an address associated with his estranged wife.
Reasoning: Eldredge filed a motion to set aside the judgments under M.R. Civ. P. 60(b), claiming lack of proper notice and service, asserting that the address used for service was that of his estranged wife.