Justia Montana Supreme Court Opinion Summaries

Bottrell Family Investments Limited Partnership and Defendants entered into a contract providing that Defendants would buy Bottrell’s interest in an LLC. Defendants failed to close and forfeited their share to Bottrell according to the terms of the contract. Bottrell later sold some of the LLC’s physical assets and transferred employees to other subsidiaries. Bottrell brought this action seeking damages under the contract as well as a declaratory judgment that the contract was still effective and that Defendants breached the contract. The district court awarded summary judgment to Defendants, concluding that Bottrell elected to pursue the remedy of forfeiture and rescinded the contract and that the doctrine of laches would bar Bottrell’s suit. The Supreme Court reversed, holding (1) the contract did not limit Bottrell to the remedies provided in the contract; and (2) Defendants did not show extraordinary circumstances or prejudice sufficient to justify the application of laches. Remanded for the district court to enter judgment in Bottrell’s favor and to calculate damages. View "Bottrell Family Invs. Ltd. P’ship v. Diversified Fin., Inc." on Justia Law

The Montana Public Service Commission determined that Whitehall Wind, LLC had not established a legally enforceable obligation during contract negotiations with NorthWestern Energy for the sale and purchase of electric energy generated by a proposed wind facility. The district court reversed, determining that NorthWestern’s refusal to negotiate created a legally enforceable obligation entitling Whitehall to a long-term avoided cost rate. The Supreme Court reversed the district court’s decision and order and remanded for reinstatement of the Commission’s order, holding that the Commission did not exceed its statutory authority in concluding that evidence of a utility’s refusal to negotiate, without more, is insufficient to establish that a qualifying facility has committed itself to the proposed project. View "Whitehall Wind, LLC v. Mont. Pub. Serv. Comm’n" on Justia Law

After Karrie Lynn Serrania went to Discovery Dental Group, PLLC (DDG) for a toothache, DDG referred her account to LPH, Inc., a debt collection agency. Serrania later sued LPH and DDC, alleging, among other claims, that LPH violated the Fair Debt Collection Practices Act (FDCPA). LPH and DDG counterclaimed for breach of contract. The district court (1) sanctioned Serrania’s attorney for failing to attend a pretrial conference, (2) entered summary judgment against Serrania on the contract and FDCPA claims, and (3) sanctioned Serrania and her attorney for their conduct in the course of litigation. After the district court entered judgment, Serrania underwent bankruptcy, and her dental debts and the district court’s orders were discharged. The Supreme Court affirmed in part and vacated and remanded in part, holding (1) some of Serrania’s arguments on appeal are moot, but her appeal of the district court’s summary judgment order on her FDPCA claim is live, and her attorney has an interest in overturning the sanctions entered against him; (2) the district court correctly entered judgment to LPH on the FDCPA claim; and (3) the district court erred in ordering Serrania and her attorney jointly to pay $24,797 to DDG and $41,113 to LPH as sanctions. View "Serrania v. LPH, Inc." on Justia Law

During a highway paving project a storm caused recently applied primer to emulsify in rainwater. The oil splashed onto passing vehicles, causing damage. The vehicle owners brought claims against the State, which the State paid. A.M. Welles, Inc. (Welles), the general contractor on the job, reimbursed the State for what it paid to the vehicle owners. The State then sued Liberty Mutual Fire Insurance Co. (Liberty), the insurer for the job, seeking indemnification for the costs that Welles did not cover. Welles, in turn, sued the subcontractors for the project, Montana Materials, Inc., RSJ, Inc., and GLJ, Inc. (collectively, “Jensen”), seeking indemnification under the subcontract. The district court granted summary judgment for Jensen on Welles’s indemnification claim and dismissed the State’s action against Liberty for failure to prosecute. The Supreme Court vacated and remanded, holding that the district court (1) erred in denying Welles’s motion for summary judgment, as Welles was entitled to indemnification under the subcontract; and (2) abused its discretion by dismissing the State’s action against Liberty for failure to prosecute. Remanded. View "A.M. Welles, Inc. v. Mont. Materials, Inc." on Justia Law

The Milky Whey, Inc., a dairy broker based in Montana, bought products from Dairy Partners, LLC, a dairy supply company located in Minnesota. This appeal concerned Milky Whey’s purchase of a product from Dairy Partners that Dairy Partners shipped to Utah. When Milky Whey picked up the product, it had become moldy and unusable. Milky Whey filed suit, alleging breach of contract, breach of warranty, unjust enrichment, and breach of an obligation to pay. Dairy Partners moved to dismiss the complaint for lack of personal jurisdiction. The district court dismissed the action, concluding that Dairy Partners did not come within Montana’s long-arm jurisdiction statute. The Supreme Court affirmed, holding that the district court did not err in determining that it could not exercise personal jurisdiction over Dairy Partners. View "Milky Whey, Inc. v. Dairy Partners, LLC" on Justia Law

In 2006, Robert and Teresa James brought a lot in a rural subdivision. At the time of the purchase, Chicago Title Insurance Company issued a title insurance policy that insured against loss or damage by reason of “lack of right of access to and from the land.” In 2013, the Jameses sued Chicago Title, contending that the title insurance policy required Chicago Title to provide them “legal” access to their lot. The district court granted summary judgment to Chicago Title, concluding that the Jameses failed to establish that the title insurance policy entitled them to “legal access” to their lot. The Supreme Court affirmed, holding that the district court properly granted judgment to Chicago Title on the Jameses’ claim, under the title insurance policy, that they lacked a right of access to their real property, as the language of the policy insured against loss from not having “a right” of access, and the Jameses clearly had a right of access when they bought the lot. View "James v. Chicago Title Ins. Co." on Justia Law

Beaverhead County selected Coleman Construction to complete a stream rehabilitation and bridge replacement project. Coleman was unable to finish the project on time or for the amount of money it had estimated. Coleman subsequently sued for damages, asserting ten claims for relief. The Montana Association of Counties Joint Powers Insurance Authority (MACo), which had issued an insurance policy to the County, denied coverage, finding that the claims against the County were excluded from coverage based upon two exclusions in the policy. The district court granted summary judgment for MACo, ruling that the two exclusions each provided sufficient independent bases for denying coverage. The Supreme Court affirmed, holding that the claims against the County were not covered by its insurance policy with MACo. View "Beaverhead County v. Mont. Ass’n of Counties Joint Powers Ins. Auth." on Justia Law

San Diego Gas & Electric Co. (“San Diego”) and several NaturEner wind-energy companies (“NaturEner”) entered into two contracts, a purchase agreement and a contribution agreement, under which San Diego agreed to purchase renewable energy credits and electricity from NaturEner. The credits and electricity are generated at a wind farm in Montana. The purchase agreement contained a forum selection clause stating that the parties consented to conduct all litigation in California. San Diego filed suit in a California court seeking a declaration that NaturEner had not satisfied the “Avian Conditions” of the agreements. NaturEner filed a nearly identical suit in a Montana court seeking a declaration that it had satisfied the conditions. San Diego filed a motion to dismiss or stay, which the district court denied. San Diego then petitioned the Supreme Court to exercise supervisory control, claiming that the district court erred by accepting jurisdiction over the parties’ dispute in light of the purchase agreement’s forum selection clause, as well as forum non conveniens. The Supreme Court granted the application for writ of supervisory control, holding (1) the forum selection clause contained in the purchase agreement was mandatory in nature; and (2) related issues regarding the contribution agreement would be appropriately and justly tried in California as well.View "San Diego Gas & Elec. Co. v. Ninth Judicial Dist. Court" on Justia Law

Meadow Brook owned land that it developed into lots with covenants, conditions, and restrictions. Meadow Brook then decided to develop an undeveloped tract as an independent subdivision. The existing homeowners, however, argued that the covenants granted them exclusive use of three roads that future homeowners would need to use to access the subdivision. A court concluded that the covenants did not reserve an easement over the three roads for use by future lot owners. First American Title Insurance Company and First American Title Company of Montana (collectively, First American), which had issued Meadow Brook a title insurance policy, subsequently denied Meadow Brook’s claim for coverage and refused to further defend against the homeowners’ counterclaims. Meadow Brook settled with the homeowners in the easement litigation and then sued First American for, inter alia, breach of contract and negligence. The district court granted summary judgment to Meadow Brook as to the breach of contract claim, concluding First American had insured under the policy that the three roads would be open to public access. The Supreme Court affirmed, holding that the district court did not err in granting Meadow Brook’s motion for partial summary judgment on the breach of contract claim. View "Meadow Brook, LLP v. First Am. Title Ins. Co." on Justia Law

Greg LeMond had an oral contract to purchase a five-acre lot (Lot 11) at the Yellowstone Mountain Club from the lot's owner, Yellowstone Development. Yellowstone Development allegedly breached its contract with LeMond by combining twenty-three acres of additional property with Lot 11 to create what became the Overlook Lots, comprising a total of twenty-eight acres. LeMond sued, claiming that Yellowstone Development breached its contract to convey Lot 11 and was under an equitable duty to convey the entirety of Overlook Lots to LeMond. In its final determination, the district court quieted title to the Overlook Lots in favor of LeMond. The Supreme Court reversed in part, holding that the district court did not provide adequate insight into the equitable considerations involved in granting LeMond title to the Overlook Lots, as Yellowstone Development was obligated to transfer Lot 11 to LeMond and was unjustly enriched by failing to do so, but LeMond was entitled to enforce a constructive trust worth only the equitable value of the parties’ bargain. View "LeMond v. Yellowstone Dev., LLC" on Justia Law