Justia Montana Supreme Court Opinion Summaries

Donovan Donald (Don) was incapacitated in an accident and received several treatment in Kalispell Regional Medical Center (KRMC). Later, a dispute arose between Don's estate and KRMC over KRMC's acceptance or rejection of Medicaid's payments for Don's care. KRMC filed liens against the Estate. The Estate, in turn, sued KRMC and MASH, a company that had provided Medicaid application forms to the Estate, under several theories of liability. The district court granted Defendants' motions for summary judgment. The Supreme Court affirmed, holding the district court (1) did not err in granting summary judgment to KRMC and MASH; (2) correctly interpreted and applied the Montana Medicaid Act; (3) correctly awarded KRMC prejudgment interest but incorrectly included interest KRMC received from its interest-bearing account; and (4) did not abuse its discretion by awarding KRMC attorney fees and costs. Remanded with instructions to offset the prejudgment interest award by the amount of interest KRMC received from the interest-bearing account.

Harold Caldwell was injured when he fell at an airport where he worked as manager. The airport's insurer, MACo, paid Caldwell's medical and wage-loss benefits. MACo, however, denied Caldwell rehabilitation benefits based on Mont. Code Ann. 39-71-710. Caldwell challenged the constitutionality of the statute on the basis that its categorical termination of benefits based on a claimant's eligibility for social security violated equal protection principles. The Workers' Compensation Court (WCC) agreed, concluding that the statute creates two similarly situated classes and treats them disparately without being reasonably related to a legitimate government interest. MACo appealed. The Supreme Court affirmed, holding (1) the statute creates two similarly situated classes and treats them differently, and (2) the categorical elimination of rehabilitation benefits in the statute based solely on age-defined eligibility for social security does not rationally relate to any governmental interest. Therefore, the statute violates the Equal Protection clause insofar as it deems disabled workers ineligible to receive rehabilitation benefits based on their eligibility for social security benefits.

Gary Hoff filed a complaint alleging contract and negligence claims against Countrywide Home Loans, Inc. and Lake County Abstract & Title Company. Countrywide failed to appear or answer within the 20 days permitted by Mont. R. Civ. P. 12(a), after which Hoff moved for entry of default against Countrywide. Countrywide later attempted to reverse the default proceedings with a motion to set aside the default pursuant to Mont. R. Civ. P. 55(c) and then a Mont. R. Civ. P. 60(b) motion to set aside the entry of default for mistake or excusable neglect. The court denied the motions and entered a default judgment against Countrywide. Countrywide appealed and Hoff cross-appealed. The Supreme Court affirmed, holding (1) the district court did not err in its judgment against Countrywide because pursuant to Cribb v. Matlock Commc'n, Inc., good cause did not exist to set aside the entry of default, and (2) the district court did not err as Countrywide's 60(b) motion was procedurally defective. Lastly, the Court concluded the district court correctly denied Hoff's request for attorneys fees because the contract did not entitle either party to attorneys fees under the circumstances.

Michael Clark owns property on which he stores unused, abandoned, or broken vehicles. Joseph Doyle owns surrounding properties. After attempting for several years to get Clark to clean up the portion of Clark's property that was visible from Doyle's property, Doyle sued Clark and others, claiming that Clark breached a written and oral contract and created a public and private nuisance. A jury ruled in favor of Clark and the other defendants. Following the trial, the district court awarded costs to the defendants. Doyle appealed. The Supreme Court held that the district court did not abuse its discretion (1) in excluding certain exhibits and testimony, (2) in refusing to give Doye's jury instructions on breach of contract and negligence theories, and (3) by limiting Doyle's counsel's closing argument with threats of a mistrial. The Court, however, found the court abused its discretion by awarding Clark his costs. The Court affirmed the judgment of the district court but with instructions to vacate the award of costs to Clark.

Plaintiff sued defendant and others claiming, among other things, that defendant breached a written and oral contract and created a public and private nuisance when plaintiff tried unsuccessfully for several years to get defendant to clean up the portion of his property that was visible from plaintiff's property. At issue was whether the district court abused its discretion in excluding certain exhibits and testimony; in refusing to give plaintiff's proposed jury instructions on breach of contract and negligence theories; by limiting plaintiff's counsel's closing argument with threats of mistrial; and in awarding defendant his costs. The court held that the district court did not abuse its discretion by refusing to admit certain evidence and exhibits during the testimony of the Department of Environmental Quality's section chief, who summarized the legal obligations imposed under the applicable statutes, where the district court sustained the objections and noted that it was the "the province of the court to instruct this jury what the law is and what the definitional aspects of the law require." The court also held that the district court did not abuse its discretion in refusing to instruct the jury on contract law where no oral or written contract was created; the district court's jury instruction on promissory estoppel potentially benefited, rather than harmed, plaintiff; plaintiff's argument vis-a-vis negligence jury instructions was without merit; the district court refused to instruct the jury on negligence per se upon the conclusion that there was no private right of action under the applicable statutes; and in refusing plaintiff's original proposed instructions on negligence per se. The court declined to address the issue of counsel's closing arguments with threats of mistrial. The court further held that defendant waived his right to recover costs and the district court abused its discretion in awarding them.