Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the rulings of the Workers' Compensation Court (WCC) determining that Johnny Lee Sheldon's claim was compensable, that Contessa Bryer, Sheldon's guardian and conservator, was entitled to her attorney fees, and that a statutory penalty should be imposed against Accident Fund General Insurance Company, holding that the WCC did not err.Sheldon was rendered incapacitated and mentally incompetent after a workplace accident. Because Accident Fund General Insurance Company refused to accept liability for Sheldon's workers' compensation claim Bryer, Sheldon's guardian and conservator, petitioned the WCC for a hearing. The WCC ruled that Accident Fund was liable for Sheldon's injuries and that Bryer was entitled to attorney fees and a statutory penalty. The Supreme Court affirmed, holding that the WCC did not err when it (1) ruled that the statute of limitations was tolled during the time that Sheldon had no appointed guardian; (2) found that substantial credible evidence supported the WCC's finding that Sheldon was working with argon when the pressure relief valve burst; and (3) awarded attorney fees under Mont. Code Ann. 39-71-611 and by imposing a penalty against Accident Fund under Mont. Code Ann. 39-71-2907. View "Bryer v. Accident Fund General Insurance Co." on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment for United Fire and Casualty Company and concluding that Clifford Christian and/or his Estate were not owed a defense or indemnification for claims made against Christian in litigation brought by Linda and Albert Parisian, holding that there was no error.Christian contracted with a general contractor on his project to construct four townhomes, one of which was pre-sold to the Parisians. A subcontractor later sued the general contractor and Parisians to obtain payment for his work to landscape the homesites. Christian was named as a third-party defendant and sought defense and indemnification from United Fire, which had insured the general contractor with a liability policy for the period at issue. After United Fire denied Christian's request Christian's Estate initiated this action. The district court granted summary judgment to United Fire. The Supreme Court affirmed, holding that the complaint did not allege facts that if proven, would trigger policy coverage. View "Christian v. United Fire & Casualty Co." on Justia Law

In this insurance dispute, the Supreme Court reversed the order of the district court granting Homeowners' cross-motion for partial summary judgment and denying Employer's Mutual Casualty Company's (EMC) motion for summary judgment, holding that the district court erred in concluding that a certain exclusion in the relevant policy precluded coverage for Homeowners' potential liability in the underlying lawsuits.EMC, who was defending Insureds in the underlying lawsuits, filed a declaratory judgment action seeking a declaration that, pursuant to the policy's "Earth Movement Exclusion," there was no coverage for Homeowners' claims against Insured. Homeowners then initiated a declaratory judgment action seeking a ruling that EMC was obligated to indemnify Insureds for Homeowners' claims under the applicable policy limits. The district court concluded that EMC had a duty to provide coverage for Homeowners' claims. The Supreme Court reversed, holding that the district court erred in concluding that coverage existed under the policy. View "Loendorf v. Employers Mutual Casualty Co." on Justia Law

The Supreme Court answered in the affirmative a certified question issued by the United States Court of Appeals for the Ninth Circuit in this insurance dispute.At issue was Mont. Code Ann. 33-15-334(2), which provides that Mont. Code Ann. 33-15-337(2) is "not intended to increase the risk assumed under policies subject to" its requirements. Specifically in question was whether, when an insurance policy does not adhere to the technical requirements of Mont. Code Ann. 33-15-337(2), the insurer may nonetheless rely on unambiguous exclusions or limitations to the policy's coverage. The Supreme Court answered the question in the affirmative, concluding that, notwithstanding a failure to follow the provisions of section 33-15-337(2), an insurer may rely on unambiguous exclusions or limitations to the policy's coverage when invalidating such a provision would result in an increase of the risk assumed. View "High Country Paving, Inc. v. United Fire & Casualty Co." on Justia Law

The Supreme Court affirmed the order of the district court denying Appellant's motion for summary judgment and granting summary judgment in favor of United Services Automobile Association (USAA) in this insurance dispute, holding that the district court did not err.Appellants filed a complaint alleging that USAA violated its duty to defend Shawn Conrad, one of USAA's insured policy-holders against whom Appellants had obtained a judgment. The district court granted summary judgment for USAA, concluding that USAA had no duty to defend Conrad because his conduct against Appellants did not fall within the scope of the policy's coverage. The Supreme Court affirmed, holding (1) Appellants' claims against Conrad were beyond the scope of coverage in USAA's policy; and (2) therefore, USAA did not have a duty to defend Conrad. View "R.S. v. United Services Automobile Ass'n" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of Depositors Insurance Company in its declaratory judgment action to determine any obligation it had relative to Patrick Sandidge pursuant to Ridley v. Guaranty National Insurance Co., 951 P.2d 987 (Mont. 1997), holding that the district court did not err.Specifically, the Supreme Court held that the district court (1) did not err by holding a hearing on the parties' cross-motions for summary judgment; (2) did not err by holding that Depositors had standing to bring a declaratory action pursuant to Ridley; (3) did not err by granting Depositors' motion for summary judgment; and (4) did not abuse its discretion by denying Sandidge attorney fees and costs. View "Depositors Insurance Co. v. Sandidge" on Justia Law

In this insurance dispute, the Supreme Court reversed in part and affirmed in part the judgment of the district court granting the cross-motion for partial summary judgment in favor of Plaintiffs and New West Health Services and denying Allied World Assurance Company's motion for partial summary judgment, holding that the district court erred in part.Dana Rolan, who serious injuries in an automobile accident, had health insurance through New West. New West denied coverage because the tortfeasor's liability insurance paid $100,000 of Rolan's medical expenses. Rolan filed a class action complaint alleging that New West violated its made-whole obligations. New West tendered the defense to its insurer, Allied. The district court certified the class and held New West liable for monetary losses. Plaintiffs and New West subsequently entered into a settlement. Allied opposed the district court's ensuing motion for final judgment, arguing that the proposed settlement amount was not covered by Allied. The district court approved the settlement between New West and Plaintiffs. The Supreme Court held that the district court (1) erred in holding that Allied was estopped from asserting a $1 million "each Claim" limit of liability under the policy; and (2) correctly concluded that Allied's "Loss" provision did not preclude Allied's indemnity obligation of the class's damages. View "Rolan v. New West Health Services" on Justia Law

The Supreme Court affirmed the rulings of the district court that the State was covered by an insurance policy it had with National Indemnity Company (National) for claims made against the State for injury and death resulting from asbestos exposure but reversed the district court's rulings regarding qualifying "occurrences" under the policy, holding that remand was required for further consideration of these issues.This insurance dispute followed litigation between the State and claimants who alleged that they were harmed by the State's failure to warn them of the hazards of asbestos exposure over years of mining and milling operations in Libby, Montana. National insured the State against general liability from 1973-1975. National filed this action seeking determinations that it had no obligation to defend the State or to cover the claims. The State concluded that National breached its duty to defend the State but disagreed with the district court's determination of the number of "occurrences" eligible for coverage under the policy, holding that remand was required for further factual findings. View "National Indemnity Co. v. State" on Justia Law

The Supreme Court reversed in part and affirmed in part the judgment of the district court concluding that Appellant was not entitled to underinsured motorist (UIM) and medical payment (MP) coverages under his automobile policy with USAA Casualty Insurance Company, holding that the court erred in part.The district court granted summary judgment for USAA on both coverages. The Supreme Court reversed in part, holding (1) as to the UIM coverage, the district court erred by interpreting the contract and determining its terms were not contrary to public policy; and (2) as to the MP coverage, the district court properly granted summary judgment in favor of USAA. View "Goss v. USAA Casualty Insurance Co." on Justia Law

The Supreme Court reversed the order of the district court dismissing as moot Appellant's claim for declaratory judgment that The Hartford Underwriters Insurance Company had a duty as an insurer to provide its insured's policy to a third-party claimant when the insured's liability was reasonably clear, holding that the district court improperly dismissed The Hartford from the action.The district court dismissed the case as moot after the insureds provided the policy at issue to Appellant. On appeal, Appellant argued that the district court erred in dismissing the case because The Hartford failed to meet its burden of demonstrating the inapplicability of the voluntary cessation exception to mootness. The Supreme Court agreed, holding that the district court erred by failing to apply the voluntary cessation exception to the mootness doctrine and dismissing the claims against The Hartford. View "Wilkie v. Hartford" on Justia Law