Justia Montana Supreme Court Opinion Summaries

This appeal was the third in the course of this litigation. Plaintiffs were a group of landowners with properties on the shores of Flathead Lake and a portion of the upper Flathead River. Plaintiffs commenced this action in 1999 against Montana Power Company (MPC) and MPC's successor, PPL Montana, LLC, asserting claims of trespass, nuisance, a taking of property, and breach of easements. In Mattson II, Plaintiffs filed motions to certify the lawsuit as a class action. The district court granted the motions as to both Defendants. The Supreme Court vacated the district court's orders concerning class certification. On remand, the district court denied Plaintiffs' renewed motion for class certification. The Supreme Court reversed, holding (1) the district court erred in its application of Mattson II to the class-certification question under Mont. R. Civ. P. 23; and (2) the six criteria for certification of a class action under Rule 23 were satisfied in this case. Remanded with instructions to certify the class. View "Mattson v. Mont. Power Co." on Justia Law

Plaintiffs were employees of Defendant Kalispell Regional Medical Center (KRMC). Defendant Northwest Healthcare Corporation (NWHC) was the parent corporation of the remaining defendant entities. This case arose out of a dispute over the discontinuation of a sick leave buy-back program. Defendants appealed the order of the district court granting Plaintiffs' motion for class certification. The Supreme Court affirmed, holding (1) the district court properly determined that the named Plaintiffs had standing to bring claims against defendants they did not directly work for because the juridically linked Defendants were operating under a common scheme; and (2) the district court did not abuse its discretion in certifying the class under Mont. R. Civ. P. 23(a) and (b). View "Chipman v. Nw. Healthcare Corp." on Justia Law

This case arose from claims asserted by multiple persons against Blue Cross and Blue Shield of Montana (BCBSMT) and Montana Comprehensive Health Association (MCHA). Claimants asserted that while they were fully insured by BCBSMT or MCHA, they submitted claims that the insurers denied based upon exclusions contained in their insurance policies. These exclusions were subsequently disapproved by the Montana Commissioner of Insurance (Commissioner) and the insureds sought the previously-denied benefits. The matter evolved into a class action and three of the claimants, Krista Lucas, Brittany Smith, and Alice Speare, were named class representatives. Subsequently, a settlement was negotiated. Three other claimants, Tyson Pallister, Kevin Budd and Jessica Normandeau, objected to the settlement and sought review by the Second Judicial District Court. The District Court approved the settlement. Pallister, Budd and Normandeau appealed asserting numerous errors by the District Court including but not limited to the court’s error in denying Pallister’s motion to conduct discovery. Upon review, the Supreme Court reversed and remanded on a discrete issue of discovery and vacated the District Court’s approval of the Settlement Agreement. View "Pallister et al v. Blue Cross & Blue Shield of Montana" on Justia Law

Blue Cross and Blue Shield of Montana (BCBS) and New West Health Services (collectively TPAs) administered a self-funded employee healthcare benefit plan for the State's employees. Jeannette Diaz and Leah Hoffmann-Bernhardt (Plaintiffs), who were both injured in accidents, filed suit against the state, BCBS, and New West for allegedly violating their made-whole rights by failing to conduct a made-whole analysis before exercising subrogation rights. Plaintiffs moved for class certification seeking to include in the lawsuit individuals who had their benefits reduced under the State plan, as well as individuals who had their benefits reduced under policies independently issued and administered by the TPAs. The district court denied class certification and determined that Montana's made-whole laws did not apply to TPAs. The Supreme Court (1) affirmed the district court's finding that BCBS and New West, in their capacities as TPAs in the present case, were not subject to the made-whole laws under either the subrogation statutes or under a third-party beneficiary theory; and (2) reversed the district court denial of class certification, as Diaz and Hoffmann-Bernhardt demonstrated that the requirements of Mont. R. Civ. P. 23 were met. View "Diaz v. Blue Cross & Blue Shield" on Justia Law

Timothy Hop's automobile was damaged in an accident with a driver insured by Safeco Insurance Company. In addition to the costs of repair, Hop sought "residual diminished value" (RDV) for his vehicle. When Safeco failed to pay RDV, Hop filed a class action complaint for declaratory relief in the district court, seeking a declaration that Safeco was required to investigate and pay class members, people whose vehicles were damaged by a Safeco insured and who were not paid RDV by Safeco, for RDV of their vehicle. The district court granted Hop's motion for class certification. The Supreme Court reversed, holding that the district court abused its discretion in certifying a class action before Hop had satisfied the statutory requirements to bring an individual third party action against Safeco. Remanded with instructions to dismiss Hop's class action without prejudice.

Plaintiff, on behalf of a class of similarly situated plaintiffs who received Medicaid assistance and were subject to a Medicaid lien pursuant to 53-2-612, MCA, sued defendant alleging that defendant had collected a greater amount than it was entitled from plaintiffs' recoveries from other sources. The parties raised several issues on appeal. The court held that Ark. Dept. of Health & Human Servs. v. Ahlborn applied retroactively to all class members' claims and that defendant must raise affirmative defenses with respect to individual class members to avoid Ahlborn's effect. The court held that the applicable statute of limitations to be 27-2-231, MCA, which provided for a five-year limitations period. The court declined to disturb the district court's order requiring defendant to compile data on individual class members' claims. The court reversed the district court's determination as to interest assessed against defendant, and concluded that no interest could be assessed until two years after any judgment had been entered, under 2-9-317, MCA. The court concluded that the term "third party" in the Medicaid reimbursement statutes included all other sources of medical assistance available to Medicaid recipients, including private health or automobile insurance obtained by the Medicaid recipient. The court reversed the district court's grant of summary judgment to the class on its proffered distinction between "first party" and "third party" sources. The court affirmed the district court's conclusion that plaintiffs' "made whole" claim was immaterial in light of Ahlborn.