Justia Montana Supreme Court Opinion Summaries

Plaintiff worked for Employer as a construction site supervisor. When Plaintiff left Montana for a vacation, a group of employees complained about Plaintiff as their supervisor. After an investigation, Employer terminated Plaintiff's employment. Plaintiff filed an action alleging that Employer violated the Montana Wrongful Discharge from Employment Act. The district court granted summary judgment for Employer. The Supreme Court affirmed, holding (1) the district court properly concluded that Employer had good cause to terminate Plaintiff's employment; (2) Employer properly considered hearsay evidence in deciding to terminate Plaintiff's employment; (3) the district court properly considered employee statements contained in reports in concluding that Employer had good cause to terminate Plaintiff's employment; and (4) the district court properly concluded that Employer did not violate the provisions of its employee handbook when it terminated Plaintiff's employment. View "Sullivan v. Continental Constr. of Mont., LLC " on Justia Law

Plaintiff suffered an injury in the course and scope of her employment with Employer. Employer's insurer (Insurer) accepted liability for Plaintiff's injury and paid wage loss and medical benefits. Plaintiff was later informed that Insurer would no longer approve or cover the expense of the pain patches she had been using for several years. Plaintiff filed a petition for expedited declaratory relief to reinstate medical benefits, seeking reinstatement of medical benefits for the pain patches as well as attorneys' fees and penalties. The Workers Compensation Court (WCC) determined that Plaintiff was entitled to continued payment of benefits for the pain patches but denied Plaintiff's request for attorneys' fees and for payment of the statutory penalty. The Supreme Court affirmed, holding that the WCC did not err (1) in determining Plaintiff was entitled to continued payment for the pain patches; (2) in determining Plaintiff was not entitled to reimbursement for her attorneys' fees; and (3) when it failed to impose the statutory penalty on Insurer. View "Stewart v. Liberty Northwest Ins. Corp." on Justia Law

Defendant brought her seven-week-old son, John Doe, to a medical center for injuries. A jury later convicted Defendant of assault on a minor and aggravated assault. The district court ordered a change in parenting arrangements for John Doe as part of the criminal sentence despite pending dependency and neglect proceedings. As part of Defendant's sentence, the district court ordered Defendant to pay fees, costs, and surcharges without recording findings regarding Defendant's financial situation. The Supreme Court affirmed, holding (1) because Defendant had regained custody of John Doe through the civil proceeding, her claim regarding the imposition of a condition concerning the temporary custody of John Doe was moot; however, the statement in the court's written judgment that the father should be presumed to have custody of John Doe should not have been included in the criminal sentence; and (2) the district court acted within its discretion in imposing fees. View "State v. MacDonald" on Justia Law

After Maxine's family contributed financially to help her keep her house, Maxine transferred title of the property to the Maxine Lane Irrevocable Trust. The Trust Agreement provided that if the property was sold during Maxine's lifetime, $50,000 was to be paid to each of Maxine's brothers. Later, Maxine consented to the sale of the property, and the Trust received $176,469 in net proceeds. The Trustee indicated she was obligated to make $50,000 distributions to Maxine's brothers as stated in the Trust and then use the remaining proceeds for Maxine's support. Maxine filed a declaratory judgment action against the Trustee, asking the district court to determine whether the Trust required the sale proceeds to be used to purchase another residence for Maxine, or whether the Trust required the $50,000 distributions be made. The district court granted summary judgment to Linda, concluding that the Trust mandated the Trustee to make the distributions. The Supreme Court affirmed, holding that the district court correctly concluded the Trust Agreement required the Trust to make the $50,000 distributions upon the sale of the property. View "Lane v. Caler" on Justia Law

After a jury trial, Defendant was convicted of aggravated assault, burglary, criminal endangerment, and assault on a peace officer, all felonies. Defendant appealed, arguing, among other things, that the Supreme Court should exercise plain error review of his argument that the convictions for aggravated assault and criminal endangerment violated statutory and constitutional double jeopardy protections. The Supreme Court affirmed, holding (1) sufficient evidence supported the aggravated assault conviction; (2) sufficient evidence supported the burglary conviction; and (3) charging both crimes of criminal endangerment and aggravated assault was not plain error under the facts of this case since different victims were involved. View "State v. Torres" on Justia Law

Plaintiff purchased a vehicle and an extended service contract for the vehicle from Defendant. Plaintiff signed several transactional documents, including a buyer's guide, a retail installment contract, and a retail purchase agreement, all of which contained statements providing that Defendant would not pay for costs for any repairs and that Defendant expressly disclaimed all express and implied warranties. The vehicle subsequently required repairs, which Defendant refused to pay for. Plaintiff filed a complaint seeking damages for Defendant's alleged failure to honor implied warranties of the vehicle. The justice court held that Defendant disclaimed implied warranties for the vehicle. The district court affirmed. The Supreme Court affirmed on alternate grounds, holding (1) Defendant failed effectively to disclaim implied warranties on the vehicle; but (2) Plaintiff's breach of warranty claim failed for lack of evidence necessary to satisfy the elements of breach and causation. View "Payne v. Berry's Auto, Inc." on Justia Law

This case arose out of several business transactions entered into by parties involved in the development of condominiums on Hauser Lake. Cherrad, Merritt & Marie, and Max & V (the Hale interests) were limited liability companies owned by Conrad and Cheryl Hale. Craig Kinnaman was sole proprietor of a business called CK Design. Merritt & Marie purchased the Hauser Lake property. Subsequently, the Hales and Kinnaman agreed to develop a portion of the property. Cherrad was the developer, and Mountain West Bank (MWB) made three loans to Cherrad to develop the project. CK Design suffered delays in the project and later left the project. In 2007, Kinnaman committed suicide, and the Estate recorded a $3.3 million construction lien on the condominiums. MWB brought this action 2008 against the Hale interests and the Estate seeking foreclosure on the three secured loans. The Hale interests and the Estate cross-claimed against each other. The district court (1) declared the Estate's construction lien invalid; and (2) determined Cherrad owed the Estate $76,278 for work that CK Design performed on the project. Finding no error, the Supreme Court affirmed. View "Mountain West Bank, N.A. v. Cherrad, LLC" on Justia Law

Plaintiff asked the district court for a declaratory judgment that the Montana Department of Revenue (DOR) used improper or illegal methods of assessing Plaintiff's Montana properties for property tax purposes in 2009 and 2010. The court granted summary judgment in favor of DOR on Plaintiff's claims, ruling that Plaintiff's substantive arguments could not be brought directly in a Montana district court without first appealing to the administrative tax appeals boards. The Supreme Court affirmed, holding (1) Plaintiff's challenges to the methods and procedures of assessment used by DOR to assess Plaintiff's property must be raised through the administrative tax appeal process; (2) Plaintiff's claim that DOR failed to equalize its valuation of Plaintiff's property is the type of challenge that must be pursued administratively; and (3) the district court did not err when it granted DOR summary judgment on Plaintiff's claim that the 2009 assessment of its property was illegal or improper because the assessment was made too late. View "CHS, Inc. v. State Dep't of Revenue" on Justia Law

After a jury trial, Defendant was convicted of assault on a peace officer, a felony, for biting a detention officer on the arm. Defendant appealed, arguing that the prosecutor's comments during closing argument constituted misconduct and warranted reversal of her conviction under plain error review. Defendant argued that the prosecutor repeatedly made direct comments about the reliability of the witnesses, and thus the prosecutor vouched for the witnesses and attempted to interject his personal opinion. The Supreme Court affirmed, holding that when viewed in the context of the entire argument, the challenged comments made in closing argument did not raise the specter of prosecutorial misconduct necessitating the exercise of plain error review to protect fundamental fairness of this proceeding. View "State v. McDonald" on Justia Law

After Employee failed to ask a shopper for a loyalty card per Employer's policy, Employee was fired. Employee brought a wrongful discharge claim against Employer under Montana's Wrongful Discharge From Employment Act (WDEA). Employee accepted Employer's offer to arbitrate the dispute because she said Mont. Code Ann. 39-915 would force her to pay Employer's attorney fees if she declined the offer and later lost at trial. Employee then successfully moved to amend her complaint to add destruction of evidence and declaratory judgment claims, alleging, inter alia, that section 39-2-915 was unconstitutional. The district court subsequently dismissed Employee's amended complaint, concluding that it had lost jurisdiction over Employee's claim once she accepted the offer to arbitrate. The court also ruled that 39-2-915 was constitutional. The Supreme Court (1) affirmed the dismissal of Employee's amended complaint, as the court lost its ability to consider Employee's claim once she agreed to arbitration; and (2) set aside the district court's determination of Employee's constitutional claim, as the court lost its authority to act further once Employee agreed to arbitrate. View "Ensey v. Mini Mart, Inc." on Justia Law