Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the district court’s denial of the portion of Plaintiffs’ motion motion for partial summary judgment seeking an order compelling Defendants to immediately remove trespassing encroachments on Plaintiffs’ property an to restore the property to its prior condition subject to Plaintiffs’ right to do so at Defendants’ expense if they failed to timely act. The court further affirmed the district court’s underlying grant of summary judgment declaring Defendants’ shop building and underground septic system to be trespassing encroachments on Plaintiffs’ property. Specifically, the court held that, at this stage in the proceedings, the district court’s interlocutory denial of preliminary or final mandatory injunctive relief was neither irreconcilable with its summary judgment declaring a trespass nor a manifest abuse of discretion. View "Davis v. Westphal" on Justia Law

The Supreme Court ordered that Appellees’ joint motion to declare John Stokes a vexatious litigant is granted in part and ordered that, before Stokes could file any pleading pro se in a Montana district court or the Montana Supreme Court, he was required to obtain pre-filing approval from the court in which he sought to file. The court ordered that any such filing may be prohibited upon a determination that the claims asserted are harassing, frivolous, or legally not cognizable. The pre-filing requirement applies to pro se filings by Stokes in cases where his counsel has withdrawn from representation. View "Stokes v. First American Title Co. of Montana, Inc." on Justia Law

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