Justia Montana Supreme Court Opinion Summaries

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

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

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

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

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

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

Johnson Farms, Inc. and Floyd Johnson filed a complaint against Ethel Halland alleging (1) in her capacity as secretary of Johnson Farms, Inc., Ethel breached her fiduciary duties by diverting corporate funds to herself and others; and (2) Ethel conferred gifts to herself and other family members in contravention of a written trust agreement. The district court granted Ethel's motion for summary judgment, finding that the complaint was barred by the statute of limitations and that equitable estoppel did not toll the statute of limitations. The district court also awarded Ethel attorneys' fees and costs. The Supreme Court affirmed, holding (1) Johnson's claims were barred by the statute of limitations; and (2) the district court did not err in awarding Ethel attorneys' fees and costs. View "Johnson Farms, Inc. v. Halland" on Justia Law

James Turner and Julie Viers opened a line of credit with Wells Fargo Bank and granted Wells Fargo a deed of trust on property they owned as security for the line of credit. Later, John Turner, Christina Turner, and Sandy Couch (the John Turners) purchased the property. Julie and James paid off the entire outstanding balance under the credit line agreement using the proceeds from the sale of the property to the John Turners, but Julie subsequently borrowed $169,090 under the credit line agreement secured by the property. Thereafter, Wells Fargo refused to release the deed of trust. The John Turners then filed a complaint to quiet title to the property. The district court granted Wells Fargo's motion for summary judgment, concluding that the John Turners could not enforce the terms of the credit line agreement because they were not intended beneficiaries of the agreement. The Supreme Court affirmed, holding that the district court correctly concluded (1) the John Turners were not entitled to judgment requiring Wells Fargo to release the deed of trust the bank held on the property; and (2) the John Turners failed to establish prima facie claims of promissory or equitable estoppel. View "Turner v. Wells Fargo Bank, N.A." 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

Mountain West Bank obtained a summary judgment against Helena Christian School and several individual defendants (HCS) following HCS’s default on loans from Mountain West. HCS appealed the decision of the Montana First Judicial District Court. The issues on appeal were: (1) whether the District Court erred by granting Mountain West’s motion for summary judgment without complying with the requirements of 71-1-222, MCA; and (2) whether the District Court erred by entering a judgment that did not comply with 25-9-203, MCA. Upon review, the Supreme Court reversed and remanded, giving the lower court the mandate to compute and state the exact judgment amount, including interest, pertaining to the unsecured loan; for the secured loan, the court must comply with the provisions of 71-1-222, MCA. Upon receipt of notice of the proceeds received in the sheriff’s sale, in the event of a deficiency, the court must determine the appropriate rate of interest vis-a-vis the deficiency, and enter an order of judgment computing and stating the amount owed by Defendants. View "Mtn. West Bank, NA v. Helena Christian School, Inc." on Justia Law