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 accepted certification of a state law question submitted by the United States Court of Appeals for the Ninth Circuit and answered that the holding in Galbreath v. Golden Sunlight Mines, Inc., 890 P.2d 382 (Mont. 1995), has not been superseded by the 1999 statutory amendments to Mont. Code Ann. 39-2-801.At issue was whether, in an action for wrongful discharge pursuant to Mont. Code Ann. 39-2-904, an employer may defend an employee's termination solely for reasons given in a discharge letter, as held in Galbreath, or whether the 1999 statutory amendments, which allowed employers to use reasons other than the reason provided in the discharge letter to defend against a wrongful discharge action, superseded the Galbreath Rule. The Supreme Court answered in the negative, holding that the Galbreath Rule was not superseded by the 1999 statutory amendments. View "Smith v. Charter Communications, Inc." on Justia Law

The Supreme Court reversed the order of the Workers' Compensation Court (WCC) granting in part and denying in part Petitioner's motion for summary judgment, holding that the WCC erred in part.At issue on appeal was whether the WCC erred when it ruled that the aggregate wages of Petitioner, a disabled worker, calculated at the time of injury, are used to determine Petitioner's permanent partial disability (PPD) benefit rate regardless of Petitioner's actual wage loss at maximum healing. The Supreme Court reversed, holding that the WCC erred by ruling that Petitioner's PPD indemnity benefit rate was aggregated from both of her time-of-injury employments when she was only precluded from one employment upon reaching maximum medical improvement. View "Barnhart v. Mont. State Fund" on Justia Law

The Supreme Court affirmed in part and reversed in part the orders entered by the district court on review of the Human Rights Commission's (HRC) final agency decision regarding Plaintiff's sexual discrimination claims against Defendant, her former employer, holding that the district court erred in part.The hearing officer found discrimination and awarded Plaintiff $415,786. The HRC affirmed the finding of discrimination and slightly altered the hearing officer's damages calculations, resulting in an increase in the overall award. The district court upheld the finding of discrimination but concluded that the HRC's use of a four-year cap for front pay damages was arbitrary and capricious, thus increasing Plaintiff's front-pay damage award. The Supreme Court reversed in part, holding that the district court (1) did not err in affirming the determination that Plaintiff was exposed to a hostile and abusive work environment and was subjected to sexual harassment and retaliation; (2) erred in reversing the HRC's front-pay damage award; and (3) did not abuse its discretion in its determination of Plaintiff's attorney fee award. View "Norval Electric Cooperative, Inc. v. Lawson" on Justia Law

The Supreme Court affirmed the judgment of the district court rejecting Plaintiff's appeal of the Montana Human Rights Commission's rejection of his claims grounded in political discrimination, holding that while the district court erred in ruling that Appellant had to pursue his 42 U.S.C. 1983 claim under the exclusive remedy of the Montana Human Rights Act (MHRA), claim preclusion now barred him from relitigating that claim.Plaintiff, the undersheriff of Missoula County, was reassigned to the position of senior deputy when his opponent in an election race won the office of Missoula County Sheriff. Plaintiff brought a human rights complaint alleging, inter alia, retaliation, discrimination, and constructive discharge based on his demotion. The Commission denied the complaint. Thereafter, Plaintiff brought this complaint alleging wrongful discharge, intentional infliction of emotion distress, unlawful political discrimination, and unlawful retaliation. The district court dismissed the complaint, holding that the MHRA was Plaintiff's exclusive remedy. The Supreme Court affirmed, holding (1) the district court improperly dismissed Plaintiff's section 1983 claim; and (2) because the underlying facts in Plaintiff's amended complaint were the same as his human rights complaint, the claims were precluded by the final judgment of the administrative proceedings. View "Clark v. McDermott" on Justia Law

The Supreme Court reversed the judgment of the district court granting summary judgment to Defendant, Plaintiff's former employer, on her wrongful discharge claims brought under the Montana Wrongful Discharge From Employment Act (WDEA), Mont. Code Ann. 39-2-905(1), holding that genuine issues of material fact remained.After Plaintiff was discharged from her employment she brought this action alleging that Defendant discharged her without good cause, as defined by Mont. Code Ann. 39-2-903(5), and in violation of Defendant's own personnel policy. The district court granted summary judgment to Defendant on the wrongful discharge claims on the ground that the damages elements of those claims failed as a matter of law because Plaintiff failed reasonably to mitigate her claimed damages by seeking comparable full-time employment after her discharge. The Supreme Court reversed, holding that the district court erred in granting summary judgment on the causation of damages element of Plaintiff's asserted wrongful discharge claims. View "Timpano v. Central Mont. District Six Human Resources Development Council, Inc." on Justia Law

The Supreme Court affirmed the orders of the district court (1) resolving the parties' summary judgment motions, ruling in favor of Defendant, Plaintiff's former employer, in Plaintiff's wrongful discharge lawsuit; and (2) denying Plaintiff leave to amend his complaint in that case to add an age discrimination claim, holding that there was no error.Specifically, the Supreme Court held that the district court (1) did not err in holding that Defendant's failure to exhaust internal grievance procedures precluded his wrongful discharge case as a matter of law; and (2) did not abuse its discretion in finding Defendant's age discrimination claim futile and therefore denying his motion for leave to amend the complaint. View "Hathaway v. Zoot Enterprises, Inc." on Justia Law

The Supreme Court affirmed the order of the district court dismissing Plaintiff's complaint for failure to state a claim, holding that the district court did not err in granting Defendants' motion to dismiss.Plaintiff was employed with Defendant for seven years until he was terminated for testing positive for THC in a random drug and alcohol urine analysis test. Plaintiff had been prescribed medical marijuana as treatment for his diagnosed PTSD and challenged his termination, alleging wrongful discharge from employment and employment discrimination and seeking a declaratory judgment that Mont. Code Ann. 50-46-320(4)(b) and (5)(b) were unconstitutional as applied to his case. The district court dismissed the claims, concluding that Plaintiff had failed to notify his supervisor that he had been using medical marijuana, as required the company's policy. The Supreme Court affirmed, holding that the failure to follow Defendants' policy constituted good cause for termination. View "Barthel v. Barretts" on Justia Law

The Supreme Court affirmed the order of the district court granting summary judgment in favor of Western Montana Community Health Center (WMMHC) and dismissing Plaintiff's claim brought under the Wrongful Discharge from Employment Act (WDEA), Mont. Code Ann. 39-2-901 - 915, holding that the district court's grant of summary judgment was not an abuse of discretion.Specifically, the Supreme Court held (1) WMMHC satisfied its burden to demonstrate that it had legitimate business reasons constituting good cause for terminating Plaintiff as program manager; (2) Plaintiff failed to meet her burden of demonstrating that the reason for the termination was false or arbitrary; and (3) WMMHC met its burden of demonstrating that it did not violate the express provisions of its written personnel policies. View "Buckley v. Western Community Mental Health Center" on Justia Law

The Supreme Court affirmed the judgment of the district court denying BNSF Railway Company summary judgment and entering final judgment in favor of Robert Dannels, holding that the Federal Employers' Liability Act (FELA) does not preempt an injured railroad employee's state law bad faith claims.Dannels was employed by BNSF when he suffered a disabling back and spine injury. Dannels sued BNSF under FELA to recover damages, and the jury returned a verdict in Dannels' favor. Dannels subsequently filed claims for bad faith and punitive damages against BNSF. The district court entered final judgment against BNSF. The Supreme Court affirmed, holding that the district court properly determined that the FELA does not preempt a railroad worker's right to seek redress for all bad faith conduct in the adjustment of a claim. View "Dannels v. BNSF" on Justia Law