Montana Supreme Court, 2013

The Montana Supreme Court reversed summary judgment for the lenders, holding that MERS was not a beneficiary under Montana's Small Tract Financing Act because the deed of trust secured the lender's obligation, not an obligation owed to MERS.

The Court affirmed denial of Johnson’s motion to modify his sentence. Although the District Court properly considered his pro se letter, Johnson identified no statutory basis for modifying a valid sentence, so the request was treated as a postconviction-relief application and was barred by the applicable five-year…