Justia Montana Supreme Court Opinion Summaries

Articles Posted in Contracts
by
Defendants in this suit included the St. Labre Indian Education Association, Inc. and the St. Labre Home for Indian Children and Youth (collectively, St. Labre). After St. Labre experienced a decrease in government funding, St. Labor began a fundraising campaign that NCT asserted resulted in millions of dollars donated to St. Labre through efforts that marketed the plight and need of NCT. NCT filed suit against Defendants alleging (1) St. Labre's fundraising system created a constructive trust on behalf of NCT and St. Labre wrongfully converted those funds to its own use, thus unjustly enriching itself; (2) contract and fraud type issues; and (3) St. Labre unconstitutionally committed cultural genocide against NCT. The district court dismissed all of NCT's motions. The Supreme Court (1) reversed the district court's grant of summary judgment on NCT's claim for unjust enrichment and the imposition of a constructive trust that may arise from St. Labre's fundraising activities after 2002; (2) reversed the district court's grant of summary judgment regarding St. Labre's fundraising activities before 2002; and (3) affirmed the court's grant of summary judgment on all of NCT's remaining claims. View "N. Cheyenne Tribe v. Roman Catholic Church" on Justia Law

by
Brent Anderson purchased life insurance from Insurer and named three beneficiaries under the policy: (1) his then-wife, Lucia, (2) his parents, and (3) his sister. Brent and Lucia subsequently divorced. Later that year, Mont. Code Ann. 72-2-814 became effective. The statute provides that a divorce revokes "any revocable disposition or appointment of property made by a divorced individual to the individual's former spouse in a governing instrument." Brent died several years later without having changed his designation of Lucia as primary beneficiary under the life insurance policy. Insurer filed an interpleader action to determine the rightful beneficiary under Brent's policy. The district court ruled in favor of Lucia based in part on the fact that section 72-2-814 became effective after Brent and Lucia's divorce. The Supreme Court accepted a certified question from the U.S. court of appeals and answered that section 72-2-814 applies to a divorce that pre-dates the statute's enactment. View "Thrivent Fin. for Lutherans v. Andronescu" on Justia Law

by
This appeal stemmed from a construction contract dispute between Total Industrial Plant Services, Inc. (TIPS) and Turner Industries Group, LLC (Turner). Fidelity and Deposit Company of Maryland (Fidelity) was the surety for Turner's substitution bond filed in lieu of TIPS's construction lien. TIPS filed a complaint against Turner and Fidelity, alleging various causes of action. The trial court granted TIPS's motion for partial summary judgment and ordered Turner to return the retainage it had withheld. After a trial, the district court found in favor of Defendants and dismissed TIPS's remaining claims. The Supreme Court affirmed in part and reversed in part, holding that the district court did not err by (1) denying TIPS's claim for additional compensation under a theory of either quantum meruit or breach of contract; (2) failing to find that TIPS was the prevailing party and awarding costs and fees to Turner; (3) finding TIPS's construction lien was barred by the ninety-day statute of limitations; (4) granting partial summary judgment to TIPS and ordering Turner to return the retainage; and (5) dismissing Turner's bill of costs for being untimely. The Court, however, found the district court erred by denying TIPS prejudgment interest on the retainage. Remanded. View "Total Indust. Plant Servs. v. Turner Indust. Group, LLC" on Justia Law

by
MCR, LLC filed an action for condemnation of a compressor station site on property owned by Appellees. Appellees counterclaimed against MCR for damage to their property and claimed punitive damages. Appellees sought restoration costs as the measure of damages for their contract, trespass, and nuisance claims. The parties stipulated to the substitution of MCR Transmission, LLC (MCR-T) for MCR on the condemnation claim. The district court dismissed MCR-T's condemnation claim and granted Appellees' summary judgment motion allowing Appellees to seek restoration costs. The jury awarded restoration costs and punitive damages to Appellees. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court (1) erred in dismissing MCR-T's motion to condemn Appellees' property for a compressor station, as genuine issues of material fact existed as to whether Appellees' property was necessary for the compressor station; (2) properly determined that Appellees were entitled to seek restoration costs as the measure of their damages; and (3) properly admitted evidence at trial that MCR had jumped Appellees' bid on state trust land leases. View "McEwen v. MCR, LLC" on Justia Law

by
Plaintiffs commenced a lawsuit against several power companies alleging that the Colstrip power facility, which bordered land owned by Plaintiffs, contaminated groundwater under their property. The parties proceeded with mediation after three years of litigation. The mediation ended with the transmission of a memorandum of understanding (MOU) to the parties' counsel. After some of Plaintiffs expressed reservations about accepting the settlement, the power companies filed a motion to enforce the settlement agreement, arguing that the MOU was a written and signed settlement agreement. After a hearing, the district court granted the motion to enforce the settlement agreement, finding that the MOU was a binding, enforceable settlement agreement. The Supreme Court affirmed, holding that the district court (1) did not err by finding the MOU was an enforceable settlement agreement; (2) did not err by allowing parol evidence to change an option to purchase into a right of first refusal; and (3) erred in admitting evidence protected by the mediation confidentiality statute, but the error was harmless. View "Kluver v. PPL Mont., LLC" on Justia Law

by
Boyne USA, Inc. filed an action for breach of contract against Blixseth Group, Inc. that covered a land sale for fifteen acres of property, seeking specific performance. Boyne joined Yellowstone Mountain Club, LLC (Yellowstone) as a party due to Yellowstone's acquisition of the contested property. Meanwhile, Yellowstone conveyed the property to Spanish Peaks Development, LLC (SPD). SPD, in turn, conveyed the property to Lone Mountain Holdings, LLC (LMH). Boyne joined SPD and LMH as parties. Boyne further alleged abuse of the legal process and deceit. The district court dismissed Blixeth Group and Yellowstone due to Yellowstone's bankruptcy. After a jury trial, (1) the jury awarded Boyne $300,000 from each SPD and LMH based on its determination that Defendants had deceived Boyne and had abused the legal process, (2) the district court awarded Boyne specific performance on the agreement; and (3) the court awarded attorney fees to Boyne. The Supreme Court affirmed subject to one minor modification, holding that the district court did not err in its judgment, and that Boyne was entitled to legal fees on appeal. View "Boyne USA, Inc. v. Spanish Peaks Dev., LLC" on Justia Law

by
Blue Cross and Blue Shield of Montana (BCBS) signed an employment agreement with Plaintiff containing a clause to compel arbitration for any disputes regarding the employment agreement. After Plaintiff's employment was terminated, Plaintiff brought an action against BCBS claiming that BCBS violated the Wrongful Discharge from Employment Act (WDEA). Plaintiff, however, could bring a WDEA claim only if she did not have a written contract of employment for a specific term. The district court compelled arbitration to allow the arbitrator to determine in the first instance whether Plaintiff had a term employment contract. The Supreme Court affirmed the district court's order to compel arbitration, holding that because the instant dispute implicated the terms or provisions of the employment agreement, the district court correctly determined that an arbitrator should decide, in the first instance, whether Plaintiff was an at-will employee or whether she had a term contract. View "Marsden v. Blue Cross & Blue Shield of Mont., Inc." on Justia Law

by
In this dispute over real property, Roslyn Shephard, in her capacity as personal representative of the estates of real property owners (Lessors), terminated the third lease of Lessees based on an alleged violation of the terms of the lease. Shephard then sued Lessees, seeking to invalidate Lessees' third lease due to the fact that she had not signed it on Lessors' behalf. Shephard alternatively sought an order declaring that Lessees had breached the terms of the lease. Lessees counterclaimed, alleging that Shephard had breached the terms of the lease by wrongfully terminating the lease and by failing to provide notice to them of the alleged breach. The district court found in favor of Lessees. The Supreme Court affirmed, holding (1) the district court correctly determined that the lease was valid without Shephard's signature; (2) substantial evidence supported the district court's finding that Lessees had not violated the lease; and (3) the district court correctly determined that the terms of the lease entitled Lessees to notice of their alleged breach and an opportunity to cure. View "Shephard v. Widhalm" on Justia Law

by
Plaintiff owned and operated a ranch with an 18,000 square-foot lodge. Defendant was a custom manufacturer of high-end wood flooring from whom Plaintiff brought wood flooring while building the lodge. After it was installed, the wood flooring began buckling and had to be replaced. Plaintiff sued Defendant for negligent misrepresentation, breach of an implied warranty of suitability for a particular purpose, and violation of the Montana Unfair Trade Practices and Consumer Protection Act (MCPA). The jury returned a verdict in Defendant's favor on all of Plaintiff's claims. The district court then granted Defendant attorney fees as the prevailing party under the MCPA. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion when it found good cause to amend the scheduling order to allow Defendant's late disclosure of an expert witness; and (2) did not err when it awarded Defendant attorney fees under the MCPA. View "B Bar J Ranch, LLC v. Carlisle Wide Plank Floors, Inc." on Justia Law

by
At issue on review in this case was whether the State Board of Land Commissioners properly issued leases to Ark Land Co., a subsidiary of Arch Coal, Inc., without first conducting environmental review under the Montana Environmental Policy Act (MEPA). The State Land Board did not conduct environmental review prior to entering the leases, relying on Mont. Code Ann. 77-1-121(2). The district court granted summary judgment to the State Land Board, Ark Land Co., and Arch Coal (Defendants), determining that the State retained sufficient ability to require adequate environmental protections sufficient to meet its constitutional and trust responsibilities. The Supreme Court affirmed, holding (1) because the leases did not allow for any degradation of the environment and specifically required full environmental review and full compliance with applicable State environmental laws, the act of issuing the leases did not impact or implicate the right to a clean and healthful environment in Mont. Const. art II, 3; and (2) therefore, section 77-1-121(2) was not subject to strict or "middle-tier" scrutiny. View "N. Plains Res. Council, Inc. v. Bd. of Land Comm'rs" on Justia Law