Justia Montana Supreme Court Opinion Summaries

Plaintiff sued Defendant, a corporation, alleging wrongful discharge, negligent infliction of emotional distress, and defamation after his employment was terminated. The district court granted Defendant’s motion to dismiss for lack of subject-matter jurisdiction, determining that Ohio law governed Plaintiff’s claims. The Supreme Court vacated the district court’s dismissal and remanded for consideration of whether dismissal under the doctrine of forum non conveniens was appropriate, holding (1) the district court did not err in considering evidence outside the pleadings in disposing of Defendant’s motion to dismiss; but (2) the district court was incorrect to conclude that the application of Ohio law to Plaintiff’s claims requires dismissal for lack of subject-matter jurisdiction. View "Harrington v. Energy West, Inc." on Justia Law

Jim Hein hired John Sott and his companies (collectively, Sott) to construct a log home for him and then, later, an addition to the home. Hein eventually filed a complaint against Sott alleging negligence, negligent misrepresentation, and violation of the Montana Consumer Protection Act (CPA). The district court dismissed Hein’s claims related to the construction of the home as time-barred and then dismissed Hein’s remaining claims on the ground that Hein had not provided expert evidence that Sott’s work was either defective or caused Hein damage. The Supreme Court affirmed, holding that the district court (1) correctly determined that Hein’s negligence and negligent misrepresentation claims arising from water damage to his home were barred by the statute of repose; (2) did not err in determining that Hein’s CPA claims for damages arising two years before Hein filed his complaint were barred by the statute of limitations but erred in determining that Hein’s CPA claims based on alleged deceptive acts or practices in the performance of repairs occurring less than two years before Hein filed his complaint were barred by the statute of limitations; and (3) erred in determining that Hein was required to produce expert evidence for his CPA claim arising from Sott’s billing for work on the addition. View "Hein v. Sott" on Justia Law

While in the course and scope of his employment with Employer, Plaintiff suffered serious injuries. Plaintiff recovered workers’ compensation insurance benefits in the amount of $207,147. Plaintiff subsequently brought this action against Employer, alleging that Employer was an uninsured employer under the Workers’ Compensation Act at the time of the accident. The district court granted summary judgment in favor of Employer, concluding that Employer was an insured employer under the Act and was therefore entitled to tort immunity pursuant to Mont. Code Ann. 39-71-411. The Supreme Court affirmed, holding that the district court did not err in concluding that Employer was an insured employer under the Act and therefore was entitled to tort immunity. View "Stokes v. Golden Triangle, Inc." on Justia Law

The Butte Local Development Corporation (BLDC) filed a complaint against Masters Group International alleging that Masters had failed to pay its obligations under a loan agreement, as modified. Masters filed a third-party complaint against Comerica Bank, alleging, among other claims, that Comerica breached a Forbearance Agreement. A jury found Masters liable to BLDC for $275,251 and found Comerica liable to Masters for a total of $52,037,593, which included punitive damages. The Supreme Court reversed the judgment against Comerica, holding (1) the district court did not abuse its discretion by implicitly denying Comerica’s severance motion; (2) the district court erred in applying Montana law despite the existence of a contractual Michigan choice-of-law provision, and had the district court properly applied Michigan law, Masters’ tort claims would not have been permitted to go to the jury as stand-alone tort claims, and the jury’s award of $10.5 million in punitive damages must be vacated; (3) the law of both Montana and Michigan supports the district court’s decision to submit the companion questions of contract formation and waiver to the jury; and (4) the district court abused its discretion by allowing Troubled Asset Relief Program (TARP) evidence to be presented to the jury. Remanded for a new trial on the contract claims applying Michigan law. View "Masters Group Int’l v. Comerica Bank" on Justia Law

F.H. Stoltze Land & Lumber Company and Maxum Specialty Insurance Group (collectively, “Stoltze”) and Les Schlegel Enterprises (“Schlegel”) contracted for Schlegel to log Stoltze’s property. Schlegel obtained liability insurance from American States Insurance Company (ASI). Whitney Shanks, a worker for Schlegel, injured himself during logging operations on Stoltze’s property. Shanks filed a personal injury lawsuit against both Schlegel and Stoltze. Stoltze tendered defense and indemnity of Shanks’s suit to ASI. After ASI accepted the tender, the district court dismissed the case against Schlegel on the grounds that Schlegel was immune to suit under the Workers’ Compensation Act’s exclusive remedy provision. ASI subsequently withdrew its defense of Stoltze, asserting that the policy covered Stoltze only to the extent that Schlegel was liable. Stoltze then filed a complaint against ASI, seeking declaratory judgment that ASI was required to defend and indemnify Stoltze against Shanks’s suit. The district court entered summary judgment for ASI, concluding that because the court in the underlying action determined that Schlegel was immune and not liable, ASI had no duty to defend or indemnify Stoltze. The Supreme Court affirmed, holding that ASI’s insurance policy with Schlegel did not require ASI to defend and indemnify Stoltze in an action in which Schlegel could not be held liable. View "F.H. Stoltze Land & Lumber Co. v. Am. States Ins. Co." on Justia Law

Plaintiff was injured while working as a switchman/brakeman for BNSF Railway Company. Plaintiff later brought this action against BNSF under the Federal Employers’ Liability Act (FELA) alleging negligence. The jury returned a verdict in BNSF’s favor on negligence and strict liability claims for violations of the Locomotive Inspection Act (LIA). The district court subsequently denied Plaintiff’s motion for judgment as a matter of law or, in the alternative, motion for a new trial. The Supreme Court affirmed in part, reversed in part, and remanded for a new trial, holding that the district court (1) did not err by allowing Plaintiff’s LIA claim to be considered by the jury; (2) did not abuse its discretion by excluding evidence of heated platforms at BNSF’s Whitefish and Essex depots; but (3) abused its discretion by admitting into evidence the specific amount of income Plaintiff made from his non-railroad employment. View "Martin v. BNSF Railway Co." on Justia Law

A licensed social worker informed the Department of Public Health and Human Services that Mother was psychologically abusing her two girls. After investigating the report, the Department removed the girls from Mother’s custody and placed them into foster care. The Department later returned the girls to Mother’s care. Mother sued the State, alleging that the Department failed adequately to investigate the social worker’s report before removing her children from her care, and as a result, she was wrongfully charged with and arrested for criminal contempt in Wisconsin, was denied custody and visitation with her children, and suffered emotional distress. The State moved for summary judgment, arguing that it was statutorily immune from suit. The district court denied the motion The district court later summary judgment for the State, concluding that the State qualified for statutory immunity. The Supreme Court reversed the district court’s earlier decision and order and affirmed the district court’s later judgment in favor of the State, holding that the State was entitled as a matter of law to statutory immunity from Mother’s claims because Mother failed to establish a genuine issue of material fact to support her claim that the State employees involved in the investigation were grossly negligent or knowingly provided false information. View "Weber v. State" on Justia Law

Fay Posnien, an exclusive agent for Allstate incorporated as Posnien Inc. sold the agency to Baird 7. Baird 7 subsequently executed an exclusive agency agreement with Allstate. The agency was successful following the transfer until Baird’s termination as an agent. Baird 7 chose to receive a termination payment from Allstate rather than transfer its economic interest to an approved buyer. Allstate withheld its disbursement of the funds and filed a complaint in interpleader to determine whose lien had priority to the termination payment. Posnien counterclaimed against Allstate, alleging conversion. At issue in this case was the scope of the security interest that Posnien was granted when it sold its economic interest in the agency book of business to Baird 7. The district court concluded that Posnien lacked rights in the collateral of the economic interest in the Allstate agency sold to Baird 7 and therefore could not sustain a claim for conversion against Allstate. The Supreme Court reversed the entry of judgment in favor of Allstate and remanded for entry of partial summary judgment on liability in favor of Posnien, holding that Posnien held an economic interest in the book of business, which satisfied the liability elements of conversion. View "Allstate v. Posnien" on Justia Law

Cody McDonald was injured while working on the construction of a building. RTK Construction, Inc. hired Ponderosa Enterprises Inc. to frame the building, and Ponderosa hired McDonald as an independent contractor to assist with the framing. McDonald brought suit against Ponderosa and RTK, alleging, inter alia, negligence and violation of the Montana Occupational Safety and Health Act (MOSHA). The district court granted partial summary judgment on the MOSHA claims, concluding that because McDonald was an independent contractor at the time of his injury, Ponderosa and RTK did not owe him any duties of safety under MOSHA. RTK was subsequently dismissed from the case, and a jury found that Ponderosa was not negligent. The Supreme Court affirmed, holding that MOSHA does not create a duty for employers to meet certain safety guidelines with respect to independent contractors. View "McDonald v. Ponderosa Enters., Inc." on Justia Law

Plaintiff, a machinist employed by the BNSF Railway Company (BNSF), brought this action against BNSF alleging negligence under the Federal Employers’ Liability Act (FELA). After his lawsuit was filed, Plaintiff requested the production of videos of the work area where the alleged injury occurred. BNSF refused to provide the video footage alleging that it had been overwritten. After a trial, the jury found in favor of BNSF. The Supreme Court reversed, holding that the district court abused its discretion when it (1) declined to impose a meaningful sanction on BNSF for its destruction of evidence; and (2) instructed the jury as to BNSF’s duty of care in a FELA action. View "Mark Spotted Horse v. BNSF Railway Co." on Justia Law