Justia Montana Supreme Court Opinion Summaries

Plaintiff injured his shoulder while working for his employer, who was insured by the Montana State Fund. The State Fund paid for Plaintiff's two shoulder injuries and paid temporary total disability (TTD) benefits after informing Plaintiff that if he returned to gainful employment without the State Fund's knowledge and continued to receive benefits, he would be subject to legal action or criminal prosecution. After the State Fund discovered that Plaintiff had built and sold furniture and worked at a vacuum cleaner store while receiving TTD benefits, the assistant attorney general charged Plaintiff with theft, a felony. The State Fund subsequently terminated Plaintiff's TTD benefits. Plaintiff filed suit against the State fund and its private investigators, alleging that Defendants violated Montana's Insurance Code regarding unfair claim settlement practices and pleaded a variety of common law causes of action. The district court ruled in favor of Defendants. The Supreme Court affirmed the district court's entry of judgment in favor of the State Fund, holding that the district court did not err in (1) granting the State Fund's motion to dismiss Defendant's claims under the Insurance Code; and (2) granting the State Fund's motion for summary judgment regarding Plaintiff's common law claims. View "White v. State ex rel. Mont. State Fund" on Justia Law

Three individuals (collectively, "Pallister") were unnamed members in a class action suit against insurers Blue Cross and Blue Shield of Montana, Inc. (BCBSMT) and Montana Comprehensive Health Association (MCHA). The suit generally sought damages from the insurers for the companies' delayed payments of benefits and for benefits improperly withheld. BCBSMT, MCHA, and the named class members subsequently entered into a proposed settlement. Pallister objected to the settlement agreement and filed a motion to conduct discovery into the fairness of the proposed settlement. The district court denied the motion. The Supreme Court reversed and vacated the district court's approval of the settlement agreement. The Court remanded to the district court with instructions to allow discovery into the settlement negotiations. Pallister then filed a motion for substitution of the district court judge. The judge denied the motion. The Supreme Court affirmed, holding (1) Pallister was not a party for purposes of substitution; and (2) Mont. Code Ann. 1-804(12) did not provide for substitution on remand in this case. View "Pallister v. Blue Cross & Blue Shield of Mont., Inc." on Justia Law

This matter arose from the suicide of a sixteen-year-old girl, who was residing at the Spring Creek Lodge Academy at the time of her death. Following the girl's death, her mother, Plaintiff, brought an action against the owner of the school, its on-site directors, including Teen Help, and various related entities. Claims against Teen Help were settled before trial, and the settlement was later reduced to a judgment. While Newman I proceeded to trial, Newman filed this declaratory judgment and breach of contract action against Teen Help's two insurers to collect on the settlement and judgment, arguing that the insurers breached their obligation to defend and indemnify Teen Help in Newman I. The district court determined the insurers were severally liable for the underlying judgment and awarded attorney's fees and interest on the underlying judgment. The Supreme Court (1) affirmed the district court's judgment as it pertained to the insurers, its award of interest on the underlying judgment, and its application of Montana law; and (2) reversed the court's ruling on attorney's fees. Remanded for recalculation of reasonable attorney's fees. View "Newman v. Scottsdale Ins. Co." on Justia Law

In 2006, Plaintiffs sustained serious injuries in an automobile accident and incurred medical expenses in excess of $1,000,000. Plaintiffs subsequently learned that they had only $5,000 in medical payments coverage and did not have any underinsured motorist (UIM) coverage after a transfer of their Oregon State Farm policy to Montana by the Mark Olson State Farm Agency. The driver who caused the accident carried the statutory minimum automobile liability insurance limits. Plaintiffs sued State Farm and Mark Olson, requesting declaratory relief and a reformation of the contract and alleging negligence, breach of fiduciary duty, and conduct sufficient to support an award of punitive damages. The district court entered summary judgment in favor of Defendants. The Supreme Court reversed, holding that the district court erred in entered summary judgment in favor of State Farm and Olson on Plaintiffs' negligence claims. Remanded for trial. View "Bailey v. State Farm Auto. Ins. Co." on Justia Law

Plaintiff was injured in an automobile accident and received medical treatment at Benefis Health System, Inc. Plaintiff had healthcare coverage as a TRICARE beneficiary and also had medical payments coverage through his insurance carrier, Kemper. Plaintiff's medical treatment costs totaled $2,073. Benefis accepted $662 from TRICARE as payment in full satisfaction of the bill pursuant to a preferred provider agreement (PPA) between Blue Cross Blue Shield and Benefis. Benefis subsequently received $1,866 from Kemper, upon which Benefis reimbursed TRICARE's payment in full. Plaintiff filed an individual and class action complaint, claiming that he was entitled to the additional $1,204 that Benefis received from Kemper over and above the TRICARE reimbursement rate. Plaintiff filed a motion for judgment on the pleadings, asking the district court to find Benefis breached its contract with TRICARE and that Benefis was liable for Plaintiff's damages. The district court converted the motion into a motion for summary judgment and granted summary judgment to Plaintiff. The Supreme Court reversed the grant of summary judgment, holding (1) Plaintiff was not entitled to pocket the difference between the TRICARE reimbursement rate and the amount Benefis accepted from Kemper; and (2) Plaintiff failed to establish any damages that resulted from the alleged breach. View "Conway v. Benefis Health Sys., Inc." on Justia Law

Brent Anderson purchased life insurance from Insurer and named three beneficiaries under the policy: (1) his then-wife, Lucia, (2) his parents, and (3) his sister. Brent and Lucia subsequently divorced. Later that year, Mont. Code Ann. 72-2-814 became effective. The statute provides that a divorce revokes "any revocable disposition or appointment of property made by a divorced individual to the individual's former spouse in a governing instrument." Brent died several years later without having changed his designation of Lucia as primary beneficiary under the life insurance policy. Insurer filed an interpleader action to determine the rightful beneficiary under Brent's policy. The district court ruled in favor of Lucia based in part on the fact that section 72-2-814 became effective after Brent and Lucia's divorce. The Supreme Court accepted a certified question from the U.S. court of appeals and answered that section 72-2-814 applies to a divorce that pre-dates the statute's enactment. View "Thrivent Fin. for Lutherans v. Andronescu" on Justia Law

Employee was injured while working for Employer. Because Employer failed to retain current worker's compensation insurance, Employee filed a claim with the Uninsured Employer's Fund, which the Fund accepted. The Fund sought indemnity from Employer for Employee's damages, and the parties agreed to an interim payment plan. However, the Fund ultimately turned Employer over to collection. Employer responded by suing the Fund for breach of contract. The district court granted Employer's summary judgment motion on the issue of whether the Fund had breached the repayment agreement. The district court then awarded damages to Employer in the amount of $198,749. The damages awarded largely centered on the court's implicit conclusion that the Fund's actions had interfered with Employer's ability to obtain financing, which, in turn, hurt Employer's sales. The Supreme Court affirmed, holding that the district court properly (1) determined Employer was entitled to summary judgment on the question of whether the Fund had breached the payment plan agreement; (2) determined Employer could receive consequential damages for the Fund's breach of contract; (3) denied the Fund's motion for post-trial relief; (3) calculated damages; and (4) denied Employer's damage claim for ten years of lost profits. View "Elk Mountain Motor Sports, Inc. v. Dep't of Labor & Indus." on Justia Law

Employer terminated Employee's employment after receiving complaints regarding poor service and use of inappropriate language by Employee. The Department of Labor & Industry concluded Employee was not qualified for unemployment insurance benefits because she had been discharged for misconduct. A hearing officer awarded unemployment benefits to Employee, concluding that Employee had not been deliberately rude and thus had not engaged in misconduct. The Board of Labor Appeals affirmed. Employer petitioned for judicial review. The Department and Board filed a notice of non-participation indicating they would not participate in the proceeding but reserved the right to intervene if issues arose pertaining to them. The district court reversed, holding that Employee's conduct as established by the hearing officer's findings of fact constituted misconduct as a matter of law under the carelessness standard of Admin. R. M 24.11.460(1)(d). The Department appealed. The Supreme Court affirmed, holding (1) the Department did not preserve its evidentiary arguments for appeal; and (2) the district court did not err by determining that the evidence found by the Department constituted misconduct as a matter of law under the carelessness standard. View "Gary & Leo's Fresh Foods v. Dep't of Labor & Indus." 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

Candice Brilz filed an action in Montana state court purportedly asserting statutory and common law bad-faith claims against Metropolitan General Insurance Company (Metropolitan). Metropolitan removed the action to federal court and filed a motion for summary judgment, which the federal court granted. Thereafter, Brilz commenced this suit district court seeking a determination that she may pursue her common law bad-faith claim against Metropolitan. Because the statute of limitations on that claim had since expired, Brilz requested a ruling that she may pursue the claim pursuant to 27-2-407, MCA, or the Supreme Court's doctrine of equitable tolling. The District Court dismissed the action, and Brilz appealed. The Supreme Court concluded that principles of claim preclusion barred her from filing a second action against Metropolitan arising out of the same underlying facts. Accordingly the Court affirmed the District Court's judgment. View "Brilz v. Metropolitan General Ins." on Justia Law