Justia Montana Supreme Court Opinion Summaries

Patterson Enterprises hired Archie Johnson Contracting (AJC) to perform blasting on a road construction project. During the project, an entire section of rock above one of Patterson's excavators collapsed, crushing it. Patterson filed suit against AJC, asserting various claims, including negligence and strict liability. AJC asserted various affirmative defenses, including contributory negligence and assumption of the risk. AJC also filed a counterclaim, asserting breach of contract. The jury (1) returned a verdict finding that AJC's blasting caused the damages sustained by Patterson and that Patterson and its employees assumed the risk of harm; (2) allocated fifty-one percent of the fault to AJC and forty-nine percent to Patterson, and awarded damages to Patterson in the amount of $50,000; and (3) returned a verdict in favor of AJC on its breach of contract claim, awarding damages to AJC in the amount of $19,255. The Supreme Court affirmed, holding that the district court did not err (1) when it permitted the defense of assumption of the risk to go to the jury; and (2) in failing to instruct the jury regarding the subjective knowledge requirement set forth in Lutz v. National Crane Corp. View "Patterson Enters., Inc. v. Johnson" on Justia Law

Lila Clavin (Lila) and Robert Gilbert founded Pastimes and executed an operating agreement (Agreement) that provided that Pastimes would terminate upon the death of a member unless at least two members remained who agreed to continue the business. After Lila died in 2000, Gilbert and Tim Clavin, Lila's son, could not agree on the value of Lila's share of Pastimes at the time of her death. This disagreement led Tim and Gilbert to conclude that Gilbert should continue to operate Pastimes. Gilbert filed a complaint for declaratory relief on behalf of Pastimes in 2005, requesting a date-of-death valuation for Lila's interest in 2005. The district court valued the Estate's interest at the date of trial rather than at the time of Lila's death. The Supreme Court affirmed in relevant part, holding that the district court properly valued the Estate's interest at the date of trial rather than at the time of Lila's death because Gilbert's and Tim's agreement and Gilbert's continued operation of Pastimes constituted a fully executed oral agreement that modified the dissolution provision of the Agreement. View "Pastimes v. Clavin" on Justia Law

Carl Murphy was injured while shopping at Home Depot. Murphy subsequently sued Home Depot. Counsel for both parties then began negotiating a settlement offer, but no settlement documents were executed. Home Depot moved to enforce the settlement agreement, arguing that Murphy's counsel agreed to a "global settlement" via his correspondence with Home Depot's counsel. The district court granted Home Depot's motion, determining that the parties formed a binding settlement agreement. The Supreme Court reversed, holding that there was no mutual consent between Murphy and Home Depot because there was no agreement on the essential terms of the settlement agreement, and therefore, no settlement agreement was ever reached between the parties. Remanded. View "Murphy v. Home Depot" on Justia Law

The City of Dillon entered an agreement with the McNeills allowing them to connect to a water main for their domestic water supply. Later, the City granted permission to the McNeills to activate an existing water service to their property. The Conners bought the McNeills' subdivided lot, and the City billed and collected for the water that was furnished to the Conners. The water main subsequently froze solid, leaving the Conners without water service for weeks. The Conners sued the City for breach of contract and negligence. The district court entered summary judgment for the City, concluding (1) there was no implied contract between the Conners and the City, and therefore, the Conners' water use was unlawful; and (2) the negligence claim was barred by City Ordinance 13.04.150, which provides that the City is not liable for claims from interruption of water service resulting from shutting off the water in its mains. The Supreme Court reversed, holding (1) the City had a legal obligation to provide water to the Conners under an implied contract; and (2) section 13.04.150 did not bar the Conners' claims because the City did not decide to shut off the water service. View "Conner v. City of Dillon" on Justia Law

Appellants and Bank entered a loan agreement in which Bank agreed to lend Appellants $5 million. After Bank refused to disburse further funds under the loan, Appellants sued Bank. Bank was represented by the Crowley Fleck law firm (Crowley). During the ensuing litigation, an attorney that was working with the law firm representing Appellants (Lawyer) joined Crowley as an attorney. Appellants subsequently filed motions to disqualify Crowley from representing Bank in the case and to permanently enjoin Crowley from proceeding in the litigation. The trial court denied Appellants' motion. The Supreme Court reversed, holding that the district court erred in denying Appellants' motions where (1) Lawyer, who was engaged in concrete discussions of future employment with the adversary's law firm, did not promptly inform Appellant, terminate all further discussions concerning the employment, or withdraw from representing Appellant; (2) the conflict was concurrent and thus imputed to Crowley; and (3) the measures Crowley took were inadequate to preserve Appellants' confidences. View "Krutzfeldt Ranch, LLC v. Pinnacle Bank" on Justia Law

The City of Dillon filed a civil action against George Warner seeking to recover the costs of installation of a water meter. Judge Gregory Mohr ruled on several motions filed by the city and conducted a scheduling conference. Warner subsequently filed an affidavit of disqualification against Mohr. The judge that presided over the disqualification proceeding (1) found Warner's affidavit of disqualification was insufficient as a matter of law and was therefore void; and (2) ordered that Mohr would maintain jurisdiction. The district court dismissed Warner's appeal, finding that the city court order concerning Warner's attempt to disqualify Mohr was an interim order and was therefore not appealable. The Supreme Court affirmed, holding (1) the district court properly dismissed Warner's appeal, as it was from an interim order and not a final judgment; and (2) the district court's orders dismissing the appeal were interim orders and thus not appealable to the Court. View "City of Dillon v. Warner" on Justia Law

James Whealon was employed by the Anaconda School District pursuant to a series of employment contracts. Upon retirement, Whealon filed a formal grievance, asserting that, under the terms of his contract, he was entitled to payment of his health insurance premiums by the District until he reached the age of sixty-five. The District denied his claim. The County Superintendent granted summary judgment to the District, holding that the language of the contract was unambiguous and that Whealon was not entitled to the claimed benefits beyond the date of his retirement. The State Superintendent of Public Instruction reversed and remanded for an evidentiary hearing, holding that the language of the contract was ambiguous. The district court reversed and reinstated the County Superintendent's ruling. The Supreme Court affirmed the district court, holding (1) the district court did not err in holding that a county superintendent has authority to grant summary judgment; and (2) the district court did not err in reinstating summary judgment in favor of the district where the language of the agreement was unambiguous and the District was entitled to judgment. View "Anaconda Public Schools v. Whealon" on Justia Law

Campbell Farming Corporation had its shares controlled by three shareholders: Stephanie Gately controlled fifty-one percent of the shares, and H. Robert Warren and Joan Crocker controlled the remaining forty-nine percent. Stephanie awarded her son, Robert Gately, who was president of the company, a bonus after a vote by the shareholders. Warren and Crocker filed a derivative and direct action against the company and the Gatelys in federal district court seeking to void the bonus. The district court entered judgment in favor of Defendants. The Supreme Court accepted certification from the Tenth Circuit to answer several questions and held (1) the safe harbor provision of Mont. Code Ann. 35-1-462(2)(c) can be extended to cover a conflict-of-interest transaction involving a bonus that lacks consideration and would be void under Montana common law; (2) the business judgment rule does not apply to situations involving a director's conflict-of-interest transaction; and (3) the holding in Daniels v. Thomas, Dean & Hoskins does not apply to the claim challenging Stephanie's role in the director conflict of interest transaction, but the Daniels test does apply to the claim of breach of fiduciary duties alleged by the minority shareholders against Stephanie in her capacity as majority shareholder. View "Warren v. Campbell Farming Corp." on Justia Law

Gary Martin and Lewistown Miller Construction Company entered into a written contract for the construction of a dwelling on Martin's property. When construction was completed, Martin refused to pay additional amounts above the bid price, and LMCC filed a construction lien on the property. LMCC then filed suit, seeking damages for breach of contract, unjust enrichment, and foreclosure of the lien. Martin counterclaimed for declaratory relief that the lien was invalid and to quiet title, among other things. The district court (1) granted foreclosure of LMCC's construction lien and awarded damages to LMCC; and (2) denied LMCC's and Martin's request for attorney fees. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err in ordering foreclosure of the construction lien, and the award of damages was not clearly erroneous; but (2) the district court erred in failing to award statutorily mandated attorney fees to LMCC, as it established its lien. Remanded. View "Lewistown Miller Constr. v. Martin" on Justia Law

The Fronks (Fronks) purchased two pieces of property from the Collinses (Collins), and the parties entered into an oral agreement whereby Collins would acquire horses and Collins would be entitled to keep the first foal from each mare as payment for their services. Fronks later transferred $215,000 to Collins for the acquisition of the horses. Fronks later deeded the properties back to Collins with the understanding that Collins would reconvey the land back to Fronks within five years. The parties subsequently signed an agreement setting forth each party's obligations. When Collins did not comply with the agreement, Fronks brought an action for breach of contract, breach of implied covenant of good faith and fair dealing, and misrepresentation seeking, inter alia, to enforce the agreement and recover damages, obtain ownership of the real property, and recover attorney fees. The district court determined that the agreement was a valid, enforceable contract and granted summary judgment to Fronks. The Supreme Court affirmed, holding that the agreement was a valid contract and the agreement did not suffer from a lack of consent by virtue of duress or menace. View "Fronk v. Collins" on Justia Law