Justia Montana Supreme Court Opinion Summaries

Appellants Mike Touris and Chuck Sneed filed a petition for judicial review after the County Board of Commissioners denied Appellants' request for a zoning change. Appellants subsequently moved to dismiss the action (Touris I) with prejudice, and the district court granted the motion. Appellants then filed the current action (Touris II), setting forth a factual scenario identical to Touris I and asserting eleven counts. The County moved to dismiss Touris II, and the district court entered an order dismissing some but not all of the counts. The County then amended its answer in Touris II to include res judicata as an affirmative defense. The County moved for summary judgment on the remaining counts in Touris II, asserting the action was barred by res judicata. The district court entered an order dismissing Touris II. On appeal, the Supreme Court affirmed, holding (1) the district court correctly concluded that res judicata barred Appellants' claims, and (2) the County did not waive its right to assert res judicata.

After child R.M.T. had been in the custody of the Montana Department of Public Health and Human Services for two years, the Department petitioned for termination of Father's and Mother's rights. After finding that Father's attempts to comply with his treatment plan failed to reach the level necessary to complete the plan, the court determined that the termination of Father's parental rights was in R.M.T.'s best interest. The court then terminated both Father's and Mother's parental rights. Father appealed. The Supreme Court affirmed, holding (1) the lower court did not abuse its discretion when it terminated Father's rights; and (2) the lower court violated Father's due process rights when at the termination hearing the court declined Father's request to cross-examine the guardian ad litem, who submitted a factual report to the court, but because the report provided no new information to the court, the exclusion of the guardian ad litem's testimony did not cause substantial injustice to Father.

Harold Caldwell was injured when he fell at an airport where he worked as manager. The airport's insurer, MACo, paid Caldwell's medical and wage-loss benefits. MACo, however, denied Caldwell rehabilitation benefits based on Mont. Code Ann. 39-71-710. Caldwell challenged the constitutionality of the statute on the basis that its categorical termination of benefits based on a claimant's eligibility for social security violated equal protection principles. The Workers' Compensation Court (WCC) agreed, concluding that the statute creates two similarly situated classes and treats them disparately without being reasonably related to a legitimate government interest. MACo appealed. The Supreme Court affirmed, holding (1) the statute creates two similarly situated classes and treats them differently, and (2) the categorical elimination of rehabilitation benefits in the statute based solely on age-defined eligibility for social security does not rationally relate to any governmental interest. Therefore, the statute violates the Equal Protection clause insofar as it deems disabled workers ineligible to receive rehabilitation benefits based on their eligibility for social security benefits.