Justia Montana Supreme Court Opinion Summaries

Wife sustained injuries as a result of Husband's negligent driving. Wife and Husband (Plaintiffs) sought coverage from Insurer, which denied coverage due to a family member exclusion in the umbrella police Husband held with Insurer. The district court concluded that the exclusion was unconscionable and entered summary judgment for Plaintiffs. The Supreme Court reversed and remanded for entry of summary judgment in favor of Insurer, holding (1) Plaintiffs failed to establish that the family member exclusion unconscionably favored State Farm, and the district court erred in so concluding; (2) the exclusion did not contravene and express statute, undermine the made-whole doctrine, or violate public policy in any other way; and (3) the policy unambiguously excluded Wife's claim from coverage, and the family member exclusion did not violate Plaintiffs' reasonable expectations. View "Fisher v. State Farm Mut. Auto. Ins. Co." on Justia Law

Plaintiffs Dorothy Harris and Tedeen Holbert were injured in separate automobile accidents caused by third-party tortfeasors. Plaintiffs were treated at Billings Clinic and St. Vincent Healthcare (Providers) for their injuries. Both Harris and Holbert were members of health plans administered by Blue Cross Blue Shield (BCBS), which entered into a preferred provider agreement (PPA) with the Providers pursuant to which Providers accepted payment from BCBS at a discounted reimbursement rate for certain medical services for BCBS insureds. Plaintiffs subsequently filed a complaint against Billings Clinic, asserting breach of contract and constructive fraud claims and requesting compensatory damages equal to the difference between the amount the third-party insurers paid to the Providers and the reduced reimbursement rates under the PPA with BCBS. Harris also filed similar claims against St. Vincent Healthcare. The district courts dismissed the claims for failure to state a claim upon which relief can be granted. The Supreme Court affirmed, holding that the district court did not err in determining that the Providers were entitled to collect from third-party insurers payment for the full amount of the billed charges for the medical treatment provided to Plaintiffs. View "Harris v. St Vincent Healthcare" on Justia Law

The Leonards entered into contracts with Centennial for the sale of a log home kit and construction of a custom log home. The Leonards later released Centennial from any claims for damages for defective construction or warranty arising out of the home's construction. Greg and Elvira Johnston held a thirty-six percent interest in the property at the time the release was signed. Eventually, all interest in the property was transferred to the Elvira Johnston Trust. A few years later, because of a number of construction defects affecting the structural integrity of the house, the Johnstons decided to demolish the house. The Johnstons sued Centennnial for negligent construction, breach of statutory and implied warranties, and other causes of action. The district court granted summary judgment for Centennial, finding that the Johnstons' claims were time-barred and were waived by the Leonards' release. The Supreme Court (1) reversed the court's ruling that the Johnstons' claims were time-barred and directed that the decision on remand apply only to the interest owned by the Johnstons at the time the release was executed; and (2) affirmed the district court's conclusion that the release was binding on the Leonards' sixty-four percent interest, later transferred to the Trust. View "Johnston v. Centennial Log Homes & Furnishings, Inc." on Justia Law

This case involved a dispute between Johnny Hughes and his parents, Jack and Shirley Hughes, regarding borrowed money, the partition of jointly owned real property and accompanying water rights, and a contested pasture lease. The district court ruled in favor of Johnny on all of the issues except for the water rights. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the jury's determination that Johnny paid interest on a promissory note executed in favor of Jack and Shirley in 1989 restarted the statute of limitations on the note, and therefore, the matter was remanded to consider the amount of principal and interest Johnny owed on the note; (2) the partition agreement between the parties dissolved whatever right Jack and Shirley may have possessed in a life estate on a house on the land Johnny received pursuant to the agreement or to insurance proceeds Johnny received after the house was destroyed by fire; (3) Jack was entitled to an easement for stock water across Johnny's property; and (4) the arbitrator who arbitrated the pasture lease did not exceed his authority or miscalculate damages. View "Hughes v. Hughes" on Justia Law

Bruce Nelson subdivided property in the 1970s. Appellant claimed he purchased tract eighteen from Nelson ten days after Nelson filed the plat. Appellant claimed that at the time of the conveyance, Nelson guaranteed that it would not sell adjoining tracts sixteen and seventeen. Appellee filed a notarized declaration four years later. In 2005, however, Nelson sold tracts sixteen and seventeen. Appellee purchased tracts sixteen and seventeen in 2008. Appellee filed a quiet title action to clear her title of any cloud that may have arisen as a result of Appellant's declaration. The district court granted summary judgment for Appellee, concluding that Appellant's declaration did not create a restriction on development and that there was no restriction on the property prohibiting the sale of the disputed tracts. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment to Appellee. View "Pennington v. Flaherty" on Justia Law

After Sarah West was involved in a motor vehicle accident, West made a claim against her insurer, State Farm, for underinsured motorist benefits of $75,000. State Farm paid only $20,000 in benefits. Attorney Tracey Morin subsequently filed a complaint against State Farm on behalf of Sarah and her parents, Ausra and James West, for breach of contract, violation of the Montana Unfair Trade Practices Act, and breach of the implied covenant of good faith and fair dealing. At the conclusion of the action, the district court imposed sanctions on Morin individually under Mont. R. Civ. P. 11. Morin appealed, contending that the depth and breadth of the sanctions constituted an abuse of discretion. The Supreme Court affirmed, holding that the district court did not abuse its discretion in imposing the level of sanctions imposed in this case. View "Morin v. State Farm Mut. Auto. Ins. Co." on Justia Law

Plaintiffs leased an apartment from Defendant for thirteen months. Before the lease term expired, a dispute arose between the parties. Plaintiffs subsequently filed a complaint against Defendant, alleging breach of the terms of the lease, negligence, and negligence per se. The justice court found in favor of Plaintiffs. Defendant appealed, seeing a trial de novo. After a bench trial, the district court ruled in Plaintiffs' favor on their breach of lease claim and awarded them damages, costs, and attorney's fees. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it allowed Plaintiffs to amend their complaint to add a claim that had not been pled during the justice court proceedings; (2) the district court did not abuse its discretion when it denied Defendant's motion in limine to prohibit any reference to the testimony and evidence presented during the justice court proceedings; and (3) because the district court's references to the prior proceedings did not suggest that the district court was unduly influenced by the justice court proceedings, Defendant was not denied her right to a trial de novo. View "McDunn v. Arnold" on Justia Law

Plaintiff law firm filed a complaint alleging that Defendants and Plaintiff had previously entered into a contract for legal services and that Defendants breached this contract by failing to fully pay for the legal services performed by Plaintiff. Defendants failed to file an answer or otherwise appear within the required time period, and the district court subsequently entered an order of default judgment against Defendants. Defendants filed a motion to vacate the entry of default some nine months later. The district court denied the motion as untimely. The Supreme Court affirmed, holding (1) the district court did not slightly abuse its discretion in denying Defendants' motion to vacate its entry of default judgment; (2) the district court did not err by awarding attorney fees and costs to Plaintiff; and (3) consideration of Defendants' appeal of the court's denial of Defendants' motions seeking to alter or set aside the court's earlier denial of Defendants' motion to vacate the entry of default judgment was barred. View "Wittich v. O'Connell " on Justia Law

This matter arose from the suicide of a sixteen-year-old girl, who was residing at the Spring Creek Lodge Academy at the time of her death. Following the girl's death, her mother, Plaintiff, brought an action against the owner of the school, its on-site directors, including Teen Help, and various related entities. Claims against Teen Help were settled before trial, and the settlement was later reduced to a judgment. While Newman I proceeded to trial, Newman filed this declaratory judgment and breach of contract action against Teen Help's two insurers to collect on the settlement and judgment, arguing that the insurers breached their obligation to defend and indemnify Teen Help in Newman I. The district court determined the insurers were severally liable for the underlying judgment and awarded attorney's fees and interest on the underlying judgment. The Supreme Court (1) affirmed the district court's judgment as it pertained to the insurers, its award of interest on the underlying judgment, and its application of Montana law; and (2) reversed the court's ruling on attorney's fees. Remanded for recalculation of reasonable attorney's fees. View "Newman v. Scottsdale Ins. Co." on Justia Law

In 2006, Plaintiffs sustained serious injuries in an automobile accident and incurred medical expenses in excess of $1,000,000. Plaintiffs subsequently learned that they had only $5,000 in medical payments coverage and did not have any underinsured motorist (UIM) coverage after a transfer of their Oregon State Farm policy to Montana by the Mark Olson State Farm Agency. The driver who caused the accident carried the statutory minimum automobile liability insurance limits. Plaintiffs sued State Farm and Mark Olson, requesting declaratory relief and a reformation of the contract and alleging negligence, breach of fiduciary duty, and conduct sufficient to support an award of punitive damages. The district court entered summary judgment in favor of Defendants. The Supreme Court reversed, holding that the district court erred in entered summary judgment in favor of State Farm and Olson on Plaintiffs' negligence claims. Remanded for trial. View "Bailey v. State Farm Auto. Ins. Co." on Justia Law