Justia Montana Supreme Court Opinion Summaries

When Kent Roose was injured in an automobile crash his wife was an employee of Lincoln County, which provided health benefits via a group health plan (the Plan) that was part of Joint Powers Trust (JPT). Employee Benefit Management Services, Inc. (EBMS administered the Plan. The Plan contained an exclusion stating that medical benefits would not be paid when any automobile or third-party liability insurance was available to pay medical costs. EBMS denied Roose’s request for reimbursement for medical expenses he paid out of the liability insurance payment he received from the tortfeasors’ insurer. Roose subsequently brought suit against EBMS and JPT. The Supreme Court held that the exclusion violated Mont. Code Ann. 2- 18-902(4). Appellants subsequently reimbursed Roose the requested amount. In 2014, Roose filed a motion for partial summary judgment and class certification, arguing that Appellants violated section 2-18-902 through systematic practices that amounted to seeking subrogation against the tortfeasor’s liability carrier before Roose was made whole. Roose also sought class certification on behalf of every member of Appellants’ plans subject to Montana law that contained the coverage exclusion. The district court granted Roose’s motion. The Supreme Court affirmed, holding that the district court did not abuse its discretion in certifying the class or in defining the class. View "Roose v. Lincoln County Employee Group Health Plan" on Justia Law

Plaintiffs were laborers who worked on the construction and rehabilitation of two multi-family housing projects. Plaintiffs filed this wage and hour action and moved for certification of a proposed class including all laborers, tradesmen, and craftsmen who worked for Monfric, Inc., the general contractor, or its subcontractors and who were not paid prevailing wages during the construction and rehabilitation of the housing projects. The district court denied Plaintiffs’ motion for class certification, concluding that Plaintiffs failed to demonstrate numerosity of the proposed class. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it concluded that Plaintiffs failed to establish that their proposed class was so numerous as to make joinder of its remaining members in a single action impracticable. View "Morrow v. Monfric" on Justia Law

Plaintiff was injured in an accident while driving a business vehicle owned by Mattress King, Inc. and insured by Mountain West Farm Bureau. Plaintiff, whose personal vehicles were insured by Safeco Insurance Company of Illinois, filed a claim with Safeco for medical payment benefits. Plaintiff received medical payment benefits from Safeco and an undisclosed amount of underinsured motorist benefits from Mountain West. Believing Safeco wrongfully refused to pay additional claimed benefits, Plaintiff brought a class action suit against Safeco. The district court ultimately ruled in favor of Safeco. The Supreme Court affirmed, holding that the “other insurance” clauses in Plaintiff’s automobile liability policy were valid and, as applied in this case, did not constitute de facto subrogation. View "Scheafer v. Safeco Ins. Co. of Ill." on Justia Law

Plaintiff was involved in a motor vehicle accident caused by another driver. As a result of the accident, Plaintiff sustained both bodily injury and property damage. Plaintiff carried an automobile insurance policy through United Services Automobile Association General Indemnity Company (USAA). USAA paid vehicle repair and car rental costs, after which it sought subrogation for the property damage expenses from the tortfeasor’s automobile liability insurer. Plaintiff subsequently filed an action on behalf of himself and a putative class of plaintiffs, alleging that USAA violated Montana law by seeking subrogation for property damage loss before its insured had been made whole with respect to related personal injuries. The U.S. district court certified a question to the Montana Supreme Court, which answered by holding that Montana law does not prohibit an insurer from exercising its right of subrogation under the limited, specific circumstances presented in the certified question. View "Orden v. United Servs. Auto. Ass'n" on Justia Law

In the 1990s, Defendants (Employers) created a sick-leave policy allowing employees to bank their sick leave in a continued illness bank (CIB). In 2002, Employers modified the terms of the CIB to create the CIB pay-out benefit, which allowed a capped amount of unused CIB hours to be paid to departing employees who completed twenty-five years or more of service. In 2008, Employers terminated the CIB pay-out benefit, and only employees who had reached twenty-five years of employment with Employers were entitled to their earned but unused CIB hours upon termination. Plaintiffs in this case represented employees who had not reached twenty-five years of service before the benefit ended. Plaintiffs brought a class action complaint against Employers. The district court granted summary judgment for Employers. The Supreme Court affirmed, holding that the district court did not err in determining that (1) Employers’ policies did not constitute a standardized group employment contract; (2) the CIB pay-out benefit was not deferred compensation or wages under the Montana Wage and Wage Protection Act; and (3) the covenant of good faith and fair dealing did not apply to Plaintiffs’ claims. View "Chipman v. Northwest Healthcare Corp." on Justia Law

Steve Sangwin, a State employee, was a qualified subscriber and beneficiary of the State of Montana Employee Benefits Plan (Plan), which was administered by Blue Cross and Blue Shield of Montana (BCBS). Steve's daughter, McKinley, was also a beneficiary under the Plan. This case arose after BCBS denied a preauthorization request for a medical procedure for McKinley on the grounds that the procedure was "experimental for research." Steve and his wife (collectively, the Sangwins) initiated this action by filing an amended complaint setting forth five counts, including a request for certification of a class action. The Sangwins defined class members as other beneficiaries of the Plan who had their employee benefits denied by the State based on the experimental exclusion for research in the past eight years. The district court granted the Sangwins' motion for class certification. The State appealed. The Supreme Court (1) affirmed the district court's order defining the class; but (2) reversed and remanded with respect to the question certified for class treatment, holding that the district court abused its discretion in specifying for class treatment the question of whether the State breached its contract of insurance with the plaintiffs. View "Sangwin v. State" on Justia Law

This interlocutory appeal arose from the district court's order certifying a class in Plaintiff's class action against Defendant, Allstate Insurance Company. Plaintiff's class action claim arose out of the Supreme Court's remand of his initial non-class third-party claim against Allstate in Jacobsen I. In Jacobsen I, Plaintiff filed a complaint against Allstate for, among other causes of action, violations of the Montana Unfair Trade Practices Act. Plaintiff sought both compensatory and punitive damages. The Supreme Court ultimately remanded the case for a new trial. On remand, Plaintiff filed a motion for class certification, proposing a class definition encompassing all unrepresented individuals who had either third- or first-party claims against Allstate and whose claims were adjusted by Allstate using its Claim Core Process Redesign program. The district court certified the class. The Supreme Court affirmed the class certification but modified the certified class on remand, holding that the district court did not abuse its discretion by certifying the Mont. R. Civ. P. 23(a)(2) class action but that the certification of class-wide punitive damages was inappropriate in the context of a Rule 23(b)(2) class. Remanded. View "Jacobsen v. Allstate Ins. Co." on Justia Law

Plaintiff, who carried health insurance through New West Health Services (New West), was injured in an automobile accident resulting in medical expenses totaling approximately $120,000. The tortfeasor's insurer paid approximately $100,000 of Plaintiff's medical bills. Plaintiff later filed a complaint against New West alleging individual and class claims, asserting that New West failed to pay approximately $100,000 of her medical expenses because the third party liability carrier had paid the majority of the bills. The district court certified the class complaint. The Supreme Court affirmed, holding that the district court did not abuse its discretion by adopting the class definition proposed by Plaintiff and denying New West's motion to modify the class definition. View "Rolan v. New West Health Servs." on Justia Law

Plaintiffs were insured through the State group insurance plan administered by Defendants. Both Plaintiffs were injured in automobile accidents caused by tortfeasors whose insurers accepted liability. The third-party insurers paid Plaintiffs' medical providers, but in both cases, the State and Defendants allegedly exercised their rights of subrogation without confirming that Plaintiffs under the State plan had been made whole. Plaintiffs filed a class complaint seeking a declaratory ruling that Defendants' practices violated the State's made-whole laws. On remand, the district court defined the class to include only those insureds who had timely filed claims for covered benefits, thus excluding from the class all non-filing insureds. The Supreme Court affirmed, holding that the incorporation of the filing limitation did not constitute an abuse of discretion. View "Diaz v. State" on Justia Law

Plaintiff was injured in an automobile accident and received medical treatment at Benefis Health System, Inc. Plaintiff had healthcare coverage as a TRICARE beneficiary and also had medical payments coverage through his insurance carrier, Kemper. Plaintiff's medical treatment costs totaled $2,073. Benefis accepted $662 from TRICARE as payment in full satisfaction of the bill pursuant to a preferred provider agreement (PPA) between Blue Cross Blue Shield and Benefis. Benefis subsequently received $1,866 from Kemper, upon which Benefis reimbursed TRICARE's payment in full. Plaintiff filed an individual and class action complaint, claiming that he was entitled to the additional $1,204 that Benefis received from Kemper over and above the TRICARE reimbursement rate. Plaintiff filed a motion for judgment on the pleadings, asking the district court to find Benefis breached its contract with TRICARE and that Benefis was liable for Plaintiff's damages. The district court converted the motion into a motion for summary judgment and granted summary judgment to Plaintiff. The Supreme Court reversed the grant of summary judgment, holding (1) Plaintiff was not entitled to pocket the difference between the TRICARE reimbursement rate and the amount Benefis accepted from Kemper; and (2) Plaintiff failed to establish any damages that resulted from the alleged breach. View "Conway v. Benefis Health Sys., Inc." on Justia Law