Justia Montana Supreme Court Opinion Summaries

Edythe Rice, who was in her late eighties, owned a cattle ranch. Edythe's son, Clark Rice, assisted Edythe in performing ranch duties. In 2006, Clark was driving a tractor in "advanced twilight" without illuminated lights. Juanita Stands struck the tractor's left rear tire. The impact caused Juanita's vehicle to spin into the neighboring lane, where it collided with Vianna Stewart's vehicle. Juanita and Vianna sustained injuries from the accident. The tractor and automobiles were total losses. After five years in litigation, the district court (1) concluded that Clark was negligent per se for violating three traffic statutes; (2) determined Edythe was vicariously liable for the injuries; and (3) concluded that Clark and Edythe were jointly and severally liable for eighty percent of Juanita's claimed damages and one hundred percent of Vianna's claimed damages. The Supreme Court (1) reversed the district court's judgment against Edythe, holding that the district court erred by proceeding to trial without addressing Edythe's competency or ensuring the parties met statutory notice requirements; and (2) otherwise affirmed. Remanded the case for an evaluation of Edythe's need for a conservator and new trial as to Edythe's vicarious liability only. View "Stewart v. Rice" on Justia Law

Plaintiff and her minor daughter were injured when their vehicle was involved in a collision with a pickup truck driven by Michael Morris, Jr. (Son), a Glacier County resident. The pickup truck was owned by Michael Morris, Sr. (Father), a Teton County resident. The collision occurred in Teton County but Plaintiff's vehicle was propelled across the county line and came to rest in Cascade County. Plaintiff filed a complaint in Cascade County against both men, claiming Son was negligent in his operation of the vehicle and Father negligently entrusted Son with the pickup truck. Son moved to change the venue to either Glacier or Teton county. The district court granted the motion and moved the proceeding to Glacier County. The Supreme Court affirmed, holding that the district court did not err in finding that Cascade County was an improper place for trial, as the tort was not committed in Cascade County and Defendants lived in Teton and Glacier counties. View "Yeager v. Morris" on Justia Law

Peter Carter was driving a Ford Explorer rented from Overland West when Todd Durham's vehicle collided with Carter's vehicle. The impact caused the Explorer to roll five times, partially ejecting Carter and killing him. Carter's estate filed a wrongful death and survival claim against Ford, Overland, and Durham (collectively, Defendants) under strict products liability and negligence theories. After a jury trial, the district court concluded that Durham was liable in negligence and that Ford and Overland were not liable. The Supreme Court affirmed, holding that the district court did not err by (1) denying the estate's motion for default judgment on liability as a sanction against Ford for withholding evidence of other incidents; (2) excluding the estate's proffered evidence of other incidents; (3) excluding evidence related to Ford's actions in making a Safe Canopy System a standard feature in the United States in 2007 and some other countries in 2002, and by permitting Ford to present a "consumer-choice" defense; and (4) excluding an indemnity agreement between Ford and Overland and limiting questioning about the agreement and the parties' prior adversarial position. View "Stokes v. Ford Motor Co." on Justia Law

Plaintiff was driving her vehicle on a public highway when she was struck by a truck owned by Stockton Oil Company (Stockton) and driven by Ronald Gerber. Plaintiff filed a complaint against Stockton and Gerber seeking damages for the injuries she sustained as a result of the accident. Stockton was served but Gerber was not. Stockton did not respond to the complaint, and a default was subsequently entered against it in February 2011. A judgment for damages was entered in April 2011. In October 2011, Stockton moved to set aside the default judgment. Sixty-eight days later, the district court granted Stockton's motion. The Supreme Court reversed, holding that the district court (1) erred in granting Stockton's motion to set aside default judgment, as the court ignored the expiration of the sixty-day deadline in doing so; (2) thus, the motion was deemed denied by operation of law; and (3) the deemed denial did not constitute a slight abuse of discretion. Remanded for reinstatement of the default judgment. View "Green v. Gerber" on Justia Law

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

Tamara Lucas and her husband James brought a legal malpractice claim against attorney Mat Stevenson after they hired Stevenson to defend James against criminal charges and to represent them in a civil suit against the city police department, the city, and individual police officers that arrested James for disturbing the peace and felony assault on a peace officer. However, Stevenson later learned that the Lucases had previously filed for bankruptcy. The civil suit was determined to an asset of the bankruptcy estate, and Stevenson was reassigned to pursue the case on behalf of the bankruptcy estate. After a settlement agreement was reached, the Lucases brought this action against Stevenson. The district court granted summary judgment in favor of Stevenson. The Supreme Court affirmed, holding that the district court correctly determined (1) the Lucases' civil claims were properly determined to be an asset of the bankruptcy estate; and (2) Stevenson did not represent the Lucases at the time the claims were settled, and therefore, the Lucases had no standing to bring a legal malpractice claim against him. View "Lucas v. Stevenson" on Justia Law

Plaintiff was employed by the Department of Corrections (DOC) as a correctional officer at the Montana State Prison. After a taser training was held at the DOC Center, Plaintiff filed a complaint against the State, the DOC, and several fictitious defendants (collectively, Defendants), alleging that he suffered an intentional infliction of personal injury by his fellow employee when he was tased at the training. Plaintiff also raised a spoliation of evidence claim for the alleged loss or destruction of the DOC's video recording of the training session. The district court granted Defendants' motion for summary judgment. The Supreme Court affirmed, holding that the district court did not err in determining (1) the Workers' Compensation Act was the exclusive remedy for Defendant's injuries; and (2) there was no independent cause of action for Defendant's spoliation of evidence claim. View "Harris v. State" on Justia Law

Defendant owned a building and leased spaced in the building to Company. Plaintiff worked as an independent contractor for Company, providing cleaning services. After Plaintiff injured himself while working in Defendant's building, Plaintiff sued Defendant. The district court granted summary judgment to Defendant. The Supreme Court reversed, holding (1) the district court erred in applying construction industry liability standards to this case and in determining that Defendant owed no duty that Defendant as a property owner had a duty of care to Plaintiff because Plaintiff was an independent contractor working for Company; and (2) the court further erred in granting summary judgment to Defendant based upon the determination that "no reasonable jury" could find that Defendant had breached the duty of ordinary care under the facts of the case. View "Steichen v. Talcott Props., LLC " on Justia Law

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

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