Justia Montana Supreme Court Opinion Summaries

The case involves Michael Goguen, an engineer and businessman, who was the subject of two civil suits alleging sexual and criminal misconduct. The New York Post published an article detailing these lawsuits, which Goguen claimed was defamatory. Goguen filed a defamation lawsuit against New York Post's parent company, NYP Holdings, and others. In response, NYP Holdings argued that their article was protected by New York’s fair report privilege, a law that protects media from defamation suits if they are reporting on official proceedings.However, the District Court in Montana, where Goguen resides, applied Montana law and denied NYP Holdings' motion to dismiss, finding that whether the article was privileged was a question of fact for the jury. On appeal, the Supreme Court of Montana determined that under Montana's choice of law rules, New York law should be applied to determine the fair report privilege. The Court found that all the contested statements in the article fairly and accurately reported the lawsuits against Goguen and were thus protected by New York's fair report privilege. Therefore, the Court held that NYP Holdings was entitled to dismissal of Goguen’s complaint.The Court also upheld the District Court's decision to dismiss Goguen's defamation claim against former police chief Bill Dial, ruling that Dial's statements in the article were protected opinions and not actionable. View "Goguen v. NYP Holdings" on Justia Law

The Supreme Court affirmed the orders of the district court denying the motion for judgment on the pleadings filed by the Associated Press and other news reporting outlets (collectively, the AP) and granting a motion to dismiss filed by Barry Usher, holding that the district court did not err.During the state's biennial legislative session in 2021, Usher, who was the Chair of the Judiciary Committee of the Montana House of Representatives, and other Republican members of the Committee met privately to discuss pending legislation. Because Usher denied the AP access to the gathering, the AP brought this lawsuit, seeking a declaratory judgment that this denial of access was a constitutional violation. The district court granted Usher's motion to dismiss, concluding that the gathering was controlled by the open meeting statute, Mont. Code Ann. 2-3-202, and that applying the statute in this case did not violate the AP's Mont. Const. art. II, 9 right to access a gathering of Judiciary Committee members. The Supreme Court affirmed, holding that the district court did not err in applying the statutory definition of a "meeting" to the AP's constitutional right to access a gathering of Judiciary Committee members. View "Associated Press v. Usher" on Justia Law

The Supreme Court affirmed the judgment of the district court awarding attorney's fees to two media organizations after they secured for public release the names of three Billings police officers who were disciplined for having sexual relations with a city clerk, holding that the district court did not abuse its discretion in making a statutory award of fees.The Billings Gazette ran a story reporting that three City police officers had been suspended without pay for having sex on City property. Each of the three officers filed a separate motion for temporary restraining order (TRO) seeking protection of his identity. The district court issued the TROs. The media companies sought a declaration that the public's right to know clearly outweighed the alleged privacy interests the officers asserted and requested attorney's fees and costs pursuant to Mont. Code Ann. 2-3-221. The district court ordered release of the officers' identities and granted the media companies' request for fees and costs. The Supreme Court affirmed the award of attorney's fees, holding that the district court properly exercised its discretion in awarding fees and costs. View "City of Billings v. Billings Gazette" on Justia Law

The Montana Public Service Commission, which requires that certain regulated telecommunications companies publicly disclose the salary information of their executive or managerial employees earning more than $100,000 per year, denied the motions for protective orders filed by Southern Montana Telephone Company and Lincoln Telephone Company to keep the salary information confidential. The district court affirmed. The Supreme Court reversed, holding that the Commission’s “rubric,” by which the Commission judged companies’ motions for protective orders of employee compensation information, constituted a de facto rule within the meaning of the Montana Administrative Procedure Act (MAPA) and that the Commission was obligated to comply with MAPA’s rulemaking procedures before implementing the rubric. View "Southern Montana Lincoln Telephone Co. v. Montana Public Service Commission" on Justia Law