Justia Montana Supreme Court Opinion Summaries

Articles Posted in Civil Procedure
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In the case before the Supreme Court of the State of Montana, the plaintiff, Kevin Barber, appealed against his former employer, Bradford Aquatic Group, LLC, alleging wrongful termination. Bradford Aquatic Group, a North Carolina-based company, had employed Barber as a Regional Business Development Manager for its Rocky Mountain region, which includes Montana. The employment contract between Barber and the company included a choice-of-law and forum selection clause, specifying that any disputes arising from the agreement would be governed by North Carolina law and adjudicated in North Carolina courts.Barber, a resident of Montana, argued that Montana law should apply to his claims of wrongful discharge, breach of contract, and bad faith, and that the suit should be heard in Montana. The district court dismissed Barber's claims due to improper venue, based on the choice-of-law and forum selection clauses in the employment agreement.Upon review, the Supreme Court of the State of Montana affirmed the district court's decision. The court found that the choice-of-law provision in the employment agreement was valid and that North Carolina law should apply to Barber's claims. The court also upheld the validity of the forum selection clause, concluding that it is enforceable under North Carolina law. Therefore, the court determined that the dispute should be adjudicated in North Carolina, not Montana. View "Barber v. Bradford Aquatic" on Justia Law

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The Supreme Court affirmed the order of the district court dismissing Appellant's complaint against eighteen defendants relating to the installation of heating, ventilation, and air conditioning (HVAC) units at a property owned by Yellowstone Lodging, LLC, holding that Appellant did not meet the constitutional or prudential requirements of standing.Yellowstone, which owned and operated a hotel in West Yellowstone, hired and entered into contracts with several HVAC contractors to upgrade the HVAC system at the motel. Appellant, the sole member of Yellowstone, brought this complaint alleging thirty-nine claims related to the HVAC system, as well as claims of legal malpractice against the law firm and attorney Appellant originally engaged to pursue these claims on behalf of Yellowstone. The district court concluded that Appellant lacked standing to sue. The Supreme Court affirmed, holding that Appellant may not, through an assignment, bring Yellowstone's claims on his own behalf and without counsel. View "Sagorin v. Sunrise Heating & Cooling, LLC" on Justia Law

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The Supreme Court affirmed the decision of the district court denying Plaintiffs' motions for default judgment and for summary judgment and granting the summary judgment of Defendants, holding that there was no error.In the midst of a dispute over real property, Plaintiffs filed an action to quiet title. The district court denied Plaintiffs' motion for summary judgment and granted Defendants' motion for summary judgment on Plaintiffs' quiet title claim. The Supreme Court affirmed, holding that the district court (1) did not manifestly abuse its discretion by declining to enter a default judgment in favor of Plaintiffs after Defendants did not complete service of their answer until one day after the deadline of Mont. R. Civ. P. 12; and (2) did not err when it determined that Plaintiffs' claims were barred by the doctrine of laches. View "Carter v. Badrock Rural Fire District" on Justia Law

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The Supreme Court affirmed the order of the district court vacating its prior order to expunge Justin Dickey's misdemeanor records, holding that the Montana Rules of Civil Procedure apply to proceedings brought under the Misdemeanor Expungement Clarification Act and that the district court properly determined that venue was not proper under Mont. Code Ann. 46-18-1105.Dickey filed a petition for expungement of his misdemeanor criminal records, referred only to "misdemeanor criminal record(s)" generally. The district court granted the petition. On reconsideration, the district court vacated its prior expungement order and dismissed the matter, determining that venue was improper. The Supreme Court affirmed, holding (1) the Rules of Civil Procedure apply to a proceeding brought under the Expungement Act; and (2) the district court did not err in determining that Dickey's prior speeding violation in Kalispell was insufficient to establish proper venue in the Eleventh Judicial District for expungement of misdemeanors under section 46-18-1105. View "In re Dickey" on Justia Law

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The Supreme Court held that service is not required when the Montana Department of Labor and Industry, Employment Relations Division (DLI) files an application for enforcement of judgment when it seeks enforcement of a final agency decision in a wage claim action.DLI applied to the district court for enforcement of judgment against a Billings restaurant on behalf of Jordan Carillo for unpaid wages pursuant to Mont. Code Ann. 39-3-212(1). DLI did not serve the restaurant under Mont. R. Civ. P. 4. The district court concluded that the filing of an application for enforcement of judgment initiates as lawsuit that that due process requires service of process. DLI petitioned the Supreme Court for a writ of supervisory control. After considering DLI's petition as one of a declaratory judgment, the Supreme Court held (1) DLI need not follow Mont. R. Civ. P. 4 service of process requirements when applying for enforcement of judgment in Montana's district courts in wage claim matters pursuant to section 39-3-212(1); but (2) the statutes do not exempt DLI from compliance with Mont. R. Civ. P. 5. View "Montana Department of Labor & Industry v. Montana Thirteenth Judicial District Court" on Justia Law

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The Supreme Court accepted supervisory control over this matter and affirmed the district court's ruling denying Philadelphia Indemnity Insurance Company's motion to dismiss for lack of personal jurisdiction, holding that the district court did not err by holding that Montana had specific personal jurisdiction over Philadelphia under Montana's long arm statute and the due process clause of the Fourteenth Amendment.In the underlying action, Appellees were sued for failing to distribute to employees eighteen to twenty percent service charges (the Walter Class Action). Appellees submitted a claim to Philadelphia requesting defense and indemnity, but Philadelphia denied the claim. After Appellees settled the Walter Class Action and paid the judgment entered against them Appellees brought suit against Philadelphia arguing that Philadelphia had a duty to defend them in the Walter Class Action. Philadelphia filed a motion to dismiss for lack of personal jurisdiction, which the district court denied. The Supreme Court affirmed, holding (1) the case qualifies for and merits review pursuant to the Court's constitutional power of supervisory control; and (2) a Montana court may exercise specific personal jurisdiction over Philadelphia regarding Plaintiffs' claims. View "Gateway Hospitality Group Inc. v. Philadelphia Indemnity Insurance Co." on Justia Law

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The Supreme Court reversed the order of the district court granting Continental Resources, Inc.'s motion to dismiss for lack of specific personal jurisdiction Plaintiff's complaint alleging that Continental was liable for the death of Zachary Buckles, holding that Plaintiff raised sufficient facts to withstand a motion to dismiss.Buckles died at a North Dakota oil well site owned by Continental, allegedly from exposure to high levels of hydrocarbon vapors while manually gauging tanks. The district court concluded that Continental, an Oklahoma corporation authorized to do business in Montana, was not subject to specific personal jurisdiction because the events leading to Buckles' death did not satisfy Montana's long-arm statute and because exercising jurisdiction over Continental would violate the United States Constitution's Due Process Clause. The Supreme Court reversed, holding that Continental failed to present a compelling case that jurisdiction would be unreasonable should Plaintiff prove her claims. View "Buckles v. Continental Resources, Inc." on Justia Law

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The Supreme Court reversed the order of the district court denying as untimely Defendant's motion for substitution of judge, holding that the substitution motion was timely because federal law halts any proceedings in the state court once a notice of removal is filed unless and until the case is remanded.Plaintiffs sued Defendant in the Seventh Judicial District Court based on Defendant's denial of an insurance claim. After a summons was issued and served upon Defendant, Defendant filed a notice of removal to the United States District Court for the District of Montana on the basis of diversity of citizenship. The federal district court granted Plaintiffs' motion for remand to state court after determining that the parties lacked complete diversity. Ninety-five days after it was served Defendant filed a motion for substitution of judge. The trial court ruled the motion was untimely. The Supreme Court reversed, holding that because Defendant filed its motion for substitution the same day the state court clerk received notice that the federal court had ordered remand and returned the original state court documents, the motion was timely. View "Sage Financial Properties, LLC v. Fireman's Fund Insurance Co." on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Roseburg Forest Products Company's motion to set aside default judgment, holding that the district court did not slightly abuse its discretion in denying Roseburg's motion to set aside default judgment.Jerome Frye, a former employee at Roseburg, filed a complaint alleging violations of the Wrongful Discharge from Employment Act. The clerk of court entered default against Roseburg after Roseburg did not file an appearance or an answer to the complaint with the district court. Roseburg later moved to set aside the entry of default judgment. The district court denied the motion, determining that Roseburg failed to proceed with diligence and that Roseburg's neglect was not excusable. The Supreme Court affirmed, holding that Roseburg's neglect in answering the complaint was not excusable. View "Frye v. Roseburg Forest Products Co." on Justia Law

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The Supreme Court reversed the judgment of the district court holding that Montana law precluded a jury trial on Plaintiff's federal discrimination claims even though federal law allows a jury trial for federal claims, holding that the district court erred when it concluded that Montana procedural law applied under the Montana Human Rights Act (MHRA) and denied Plaintiff a jury trial on his federal claims.Plaintiff, who has a visual disability, brought claims alleging that the Montana Department of Public Health and Human Services engaged in intentional employment discrimination on the basis of his sex and/or disability, in violation of state and federal anti discrimination statutes. The district court concluded that state law precluded a jury trial on Plaintiff's federal discrimination claims because Montana's antidiscrimination statutes do not provide for a trial by jury and because state procedural rules govern procedures in state courts. The Supreme Court reversed, holding that Plaintiff's claims were separate and distinct from his state law claims and that Plaintiff had a right to a jury trial on his federal claims in state district court. View "Spillers v. Third Judicial District Court" on Justia Law