Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the district court’s dismissal of Appellant’s complaint, holding that Appellant’s original complaint was not improper serial litigation and, therefore, was not barred under Mont. Code Ann. 3-1-502.Appellant filed this case against Appellees for abuse of process and malicious prosecution. In a separate, previously filed action, Appellees filed suit against a mortgage company that Appellant owned to foreclose on a defaulted loan. Before the resolution of the foreclosure claims, Appellant filed the action at issue in this case. The district court granted Appellees’ motion to dismiss the complaint with prejudice, concluding that the suit was based upon the same facts and transactions as those alleged in the foreclosure litigation and was therefore impermissible under section 3-1-502. The Supreme Court disagreed, holding that Appellant’s complaint was not barred because the claims asserted in this separate action accrued after Appellees filed the previous action. View "McAtee v. Whitefish Credit Union" on Justia Law

The Supreme Court reversed the judgment of the district court granted summary judgment for New West Health Services (New West) in this action brought by Plaintiff and the class she represented alleging breach of contract, violation of made-whole rights, and unfair claims settlement practices. At issue in this appeal was the district court’s grant to New West leave to amend its answer to include the affirmative defense of ERISA preemption. The district court subsequently allowed Plaintiff to amended her complaint to include ERISA claims. Ultimately, the district court concluded that ERISA preemption required dismissal of Plaintiff’s state law and ERISA claims and entered summary judgment for New West. The Supreme Court reversed, holding that, under the extraordinary circumstances of this case, the district court abused its discretion by granting New West leave to amend its answer to assert ERISA preemption. View "Rolan v. New West Health Services" on Justia Law

The Supreme Court affirmed the district court’s dismissal of this putative class action for lack of standing.Taxpayers, owners of real property and payers of property taxes in Glacier County, paid their taxes under protest 2015 in response to an independent audit that revealed deficiencies in the County’s budgeting and accounting practices. Taxpayers sued the County and the State, alleging that both entities failed to comply with budgeting and accounting laws. The district court denied class certification and dismissed the case for lack of standing, concluding that Taxpayers failed to demonstrate that they had suffered a concrete injury. The Supreme Court affirmed, holding that the district court correctly determined that Taxpayers lacked standing to sue either the County or the State. View "Mitchell v. Glacier County" on Justia Law

The Supreme Court affirmed the district court’s order granting HSBC Bank USA’s two motions for summary judgment and motion to exclude Richard Anderson’s expert in this judicial foreclosure action against Anderson and Limegrove Overseas, Ltd. Specifically, the court held that the district court (1) did not abuse its discretion in excluding Anderson’s expert witness; (2) did not err when it concluded that Montana law governs HSBC’s underlying foreclosure and that New York law governs any defenses and counterclaims; (3) did not err in granting HSBC summary judgment to foreclose; and (4) did not err in granting HSBC summary judgment on Anderson’s counterclaims. View "HSBC Bank USA, N.A. v. Anderson" on Justia Law

The Supreme Court reversed the order of the district court granting Continental Resources, Inc.’s motion to dismiss the lawsuit filed by the estate of Zachary Buckles in which the estate alleged that Continental and other defendants were liable for Zachary’s death. The district court dismissed the complaint on the grounds that Continental, an Oklahoma corporation authorized to do business in Montana, was not subject to personal jurisdiction in Montana. The Supreme Court disagreed and remanded the case for an evidentiary hearing, holding that material jurisdictional facts existed, requiring a preliminary hearing by the district court pursuant to Mont. R. Civ. P. 12(d) to determine whether Continental was subject to the court’s jurisdiction. View "Estate of Buckles v. Continental Resources, Inc." on Justia Law

The Supreme Court affirmed in part and remanded in part the district court’s denial of Bryan Sandrock’s motion to set aside a default and a subsequent default judgment entered against him. The clerk of the district court entered Sandrock’s default after Sandrock failed to answer a complaint within the designated time. Sandrock, through counsel, filed a motion to set aside default and default judgment based upon an alleged fraud upon the court committed by the other party and counsel’s own failure to pay sufficient attention to the matter. The court denied the motion, concluding that the “good cause” standard set forth in Mont. R. Civ. P. 55(c) was not satisfied and that Sandrock’s brief did not support his argument of a fraud upon the court. Sandrock appealed the denial of his motion to set aside default judgment and the district court’s calculation of damages. While it affirmed the denial of Defendant’s motion to set aside default and default judgment, the Supreme Court remanded the matter for a recalculation of damages and identification of evidence supporting the recalculation, as the court was unable to discern how the various sources used by the district court established the amount of damages awarded. View "DeTienne v. Sandrock" on Justia Law

After Plaintiff’s employment was terminated, he filed suit against Defendant alleging wrongful discharge, negligent infliction of emotional distress, and defamation. The district court granted Defendant’s motion to dismiss for lack of subject-matter jurisdiction, concluding that Ohio law governed or, alternatively, that Ohio was the appropriate forum to exercise jurisdiction. The Supreme Court vacated the district court’s dismissal, holding that Montana courts had subject-matter jurisdiction over Plaintiff’s claim, and remanded for further proceedings to consider whether dismissal under the doctrine of forum non conveniens was appropriate. On remand, the district court denied Plaintiff’s motion to amend the complaint and granted Defendant’s motion to dismiss under forum non conveniens. The Supreme Court affirmed, holding that the district court (1) did not act arbitrarily or exceed the bounds of reason in concluding that Plaintiff’s amendment would prejudice Defendant and that the amendment would run counter to the Supreme Court’s remand instructions in Harrington I; and (2) did not abuse its discretion by determining that resolution of Plaintiff’s claims in Ohio would promote the convenience of witnesses and the ends of justice. View "Harrington v. Energy West Inc." on Justia Law

In 2010, Havre High School’s roof partially collapsed. Dick Anderson Construction, Inc. (Anderson) built the roof and Springer Group Architects (Springer) designed it. Hill County High School District No. A filed suit against against Springer and Anderson, alleging negligence, breach of express and implied warranty, breach of contract, negligent misrepresentation, deceit, and fraud. The district court granted summary judgment in favor of Springer and Anderson, concluding that the statute of repose time-barred the School District’s claims. The Supreme Court affirmed, holding that the district court did not err in (1) concluding that the statute of repose barred the School District’s claims; (2) ruling that the period of repose could not be tolled; and (3) awarding Spring attorney fees under the contract. View "Hill County High School District No. A v. Dick Anderson Construction, Inc." on Justia Law

Appellants attempted to execute judgments obtained against Robert Fitte in their respective underlying lawsuits by attaching the proceeds of a commercial liability policy issued to Fitte by joined party Mountain West Farm Bureau Mutual Insurance Company (Mountain West). In a separate declaratory proceeding, a federal court determined that the commercial policy covered Fitte’s actions. Thereafter, Mountain West filed a motion to deposit the proceeds of the commercial policy into an existing interpleader action. The underlying proceedings filed by Appellants were consolidated. The district court granted summary judgment to Fitte and Mountain West, concluding that Appellants were not entitled to execute judgments secured outside the pending interpleader action and attach the proceeds of the commercial policy. The Supreme Court affirmed, holding (1) the district court did not err in concluding that the proceeds from the commercial policy must be distributed through the interpleader; and (2) deposit of the commercial policy proceeds was not required at the time of the interpleader proceeding to establish the interpleader court’s jurisdiction. View "Associated Dermatology & Skin Cancer Clinic of Helena, P.C. Profit Sharing & Trust Benefit of Stephen D. Behlmer, M.D. v. Fitte" on Justia Law

Appellants owned property adjacent to Whitefish Lake, which the City of Whitefish has annexed. In 2005, Appellants petitioned the City for annexation of the property, and their petition was granted. In 2010, Appellants petitioned to have their property de-annexed. The City Council denied the petition. Appellants commenced a declaratory action in the district court challenging the decision. The district court dismissed the complaint on the basis of lack of service and on the ground that the statute of limitations for Appellants’ claims would bar any re-filed action. In 2014, Appellants filed another petition for de-annexation of their property. The City Council denied Appellants’ second petition for de-annexation, and Appellants filed a second declaratory action challenging the denial of their second petition. The district court entered summary judgment for the City, concluding that Appellants’ action was barred by claim preclusion. The Supreme Court affirmed, holding that the district court did not err by granting summary judgment on the basis of claim preclusion. View "Schweitzer v. City of Whitefish" on Justia Law