Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the order of the district court dismissing Plaintiff's claim brought under the Wrongful Discharge from Employment Act (WDEA) as time-barred, holding that the district court erred by granting summary judgment in favor of the Department of Corrections (DOC).In granting summary judgment for the DOC, the district court held that since Plaintiff's grievance procedures took longer than 120 days from the date of her termination her claim was untimely. The Supreme Court reversed, holding (1) the limitation period on Plaintiff's WDEA claim was tolled from the time she commenced her grievance until the grievance procedures were exhausted; and (2) excluding the period during which the limitation period was tolled, Plaintiff timely filed her claim within the one-year statute of limitations. View "Shepherd v. State" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the district court upholding a hearing officer's conclusion that Montana State University-North (MSU-N) retaliated against Dr. Randy Bachmeier for reporting and pursuing a claim of sexual harassment against his supervisor, holding that the district court erred in reinstating the hearing officer's first decision as the final agency decision in this matter.The hearing officer's original order concluded that Bachmeier failed to demonstrate that his supervisor sexually harassed him but that MSU-N retaliated against Bachmeier. The HRC rejected the hearing officer's conclusion that Bachmeier was discriminated against, upheld the hearing officer's retaliation conclusion, and remanded the case. The hearing officer issued a second decision concluding that Bachmeier had been sexually harassed. The Montana Human Rights Commission (HRC) then issued a final agency decision reducing the damages award for sexual harassment but leaving untouched the retaliation award. The district court voided the hearing officer's second decision and remanded with instructions to reinstate the hearing officer's first decision as the final agency decision. The Supreme Court reversed in part, holding that the district court (1) abused its discretion by concluding that the HRC did not have the authority to modify the hearing officer's first decision; and (2) correctly upheld the hearing officer's retaliation conclusion. View "Montana State University-Northern v. Bachmeier" on Justia Law

The Supreme Court affirmed the ruling of the Workers' Compensation Court that Mont. Code Ann. 39-71-703(2) did not violate Appellant's right to equal protection by denying an impairment award to a worker with a Class 1 impairment who has suffered no wage loss, holding that the statute passes rational basis muster under the Equal Protection Clause of the Montana Constitution.Section 39-71-703(2) allows impairment awards for claimants without actual wage loss only if they have a Class 2 or higher impairment rating. Appellant, who was designated as Class 1 and was denied an impairment award, challenged the statute, arguing that it violated her constitutional right to equal protection because other workers with different injuries but the same whole-person impairment percentage would receive the award. The WCC denied the challenge. The Supreme Court affirmed, holding that the WCC did not err in its determination that section 39-71-703(2) did not violate the Equal Protection Clause. View "Hensley v. Montana State Fund" on Justia Law

The Supreme Court affirmed the order of the district court denying Griz One Firefighting, LLC's petition for judicial review of a default order and determination by the Department of Labor and Industry Wage and Hour Division (DLI) and awarding Matthew Sean West $11,241 in back wages, penalties, costs, and attorney fees, holding that the district court did not err.Specifically, the Supreme Court held (1) the district court did not clearly err when it concluded that DLI notified Griz One of West's wage claim; (2) Griz One was not entitled to relief on its due process and jurisdictional arguments; (3) the district court was correct in concluding that Mont. R. Evid. 605 does not apply to a DLI compliance specialist; and (4) the district court's award of attorney fees and costs to West was reasonable and based on competent evidence. The Supreme Court remanded the matter to the district court for a determination of West's costs and fees on appeal. View "Griz One Firefighting v. State Department of Labor & Industry" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the district court awarding $2,353,463 in damages to Junkermier, Clark, Campanella, Stevens, P.C. (JCCS), a Montana accounting firm, after a bench trial on remand, holding that the district court did not err by awarding prejudgment interest but erred with regards to the date interest began accruing.Appellants, five of six shareholders in JCCS' Bozeman office, were employed under the terms of an Employment Agreement that contained a covenant restricting competition (Covenant). Appellants later began working at a newly formed accounting firm and solicited clients from JCCS' Bozeman client list. JCCS filed a complaint against Appellants to declare the Covenant enforceable and to recover damages. On remand, the district court determined that the Covenant was reasonable, Appellants were jointly and severally liable for damages arising out of the Covenant's breach, and JCCS was entitled to prejudgment interest. The Supreme Court largely affirmed, holding that the district court did not err by (1) concluding that Appellants were jointly and severally liable for JCCS' damages; (2) concluding that the Covenant was reasonable; (3) awarding prejudgment interest but erred with regards to the date interest began accruing; and (4) by denying Appellants' motion for discovery sanctions. View "Junkermier, Clark, Campanella, Stevens, P.C. v. Alborn" on Justia Law

The Supreme Court held that service is not required when the Montana Department of Labor and Industry, Employment Relations Division (DLI) files an application for enforcement of judgment when it seeks enforcement of a final agency decision in a wage claim action.DLI applied to the district court for enforcement of judgment against a Billings restaurant on behalf of Jordan Carillo for unpaid wages pursuant to Mont. Code Ann. 39-3-212(1). DLI did not serve the restaurant under Mont. R. Civ. P. 4. The district court concluded that the filing of an application for enforcement of judgment initiates as lawsuit that that due process requires service of process. DLI petitioned the Supreme Court for a writ of supervisory control. After considering DLI's petition as one of a declaratory judgment, the Supreme Court held (1) DLI need not follow Mont. R. Civ. P. 4 service of process requirements when applying for enforcement of judgment in Montana's district courts in wage claim matters pursuant to section 39-3-212(1); but (2) the statutes do not exempt DLI from compliance with Mont. R. Civ. P. 5. View "Montana Department of Labor & Industry v. Montana Thirteenth Judicial District Court" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Appellant's petition for judicial review for failure to exhaust Department of Fish, Wildlife and Parks (FWP) employee grievance remedies, holding that Appellant failed to exhaust administrative remedies.After Appellant, who worked for FWP, was reassigned to a different position, Appellant petitioned for judicial review. The district judge dismissed the petition with prejudice, determining that Appellant had not exhausted all available administrative remedies by filing a grievance regarding his reassignment. Appellant then filed a grievance, which was denied as untimely. Appellant did not file exceptions. Instead, Appellant filed a second petition for judicial review in the district court. The district court granted FWP's motion to dismiss, determining that it lacked subject matter jurisdiction over Appellant's petition based on his failure to exhaust administrative remedies. The Supreme Court affirmed, holding that the district court did not err in concluding that Appellant's failure to file exceptions barred his petition for judicial review. View "Flowers v. Board of Personnel Appeals, Montana Department of Fish, Wildlife & Parks" on Justia Law

The Supreme Court reversed the order of the district court declining to dismiss Plaintiff's wrongful discharge claim, holding that Plaintiff failed timely to file his complaint in the district court within the applicable statute of limitations.Plaintiff filed a claim against the City of Dillon and the Dillon Mayor (collectively, Defendants) alleging violation of the Wrongful Discharge of Employment Act (WDEA), Mont. Code Ann. 39-2-905. The City moved to dismiss the complaint on the grounds that Plaintiff's claims were barred by the statute of limitations. The district court denied the claim. The City then sought dismissal of the action as time barred by a way of summary judgment, which the district court denied. The jury ultimately found that Plaintiff was discharged without good cause and awarded damages of $75,612. The Supreme Court reversed, holding that Plaintiff failed to timely file his complaint within the one-year limitation period, as required by the WDEA. View "Turner v. City of Dillon" on Justia Law

The Supreme Court allowed hundreds of former employees of W.R. Grace & Company's Zonolite Division in Libby (Grace) to continue their asbestos-related personal injury claims against Maryland Casualty Company (MCC), Grace's former workers' compensation insurance provider, holding that MCC owed Grace workers a direct common law duty under Restatement (Second) of Torts 324A(b)-(c) to use reasonable care under the circumstances to warn them of the known risk of exposure to airborne asbestos in certain Grace workplaces.The Supreme Court assumed supervisory control over proceedings pending before the Montana Asbestos Claims Court. Here the Court addressed on extraordinary review MCC's assertion that the district court erred in concluding that MCC owed a duty of care to warn third-party employees of Grace of a known risk of airborne asbestos exposure in or about Grace facilities in and about Libby, Montana between 1963 and 1970. The Supreme Court held that, based on MCC's affirmative assumption of employee-specific medical monitoring and Grace's reliance on MCC to perform that function, MCC owed Grace workers a legal duty to use reasonable care to warn them of the risk of airborne asbestos. View "Maryland Casualty Co. v. Asbestos Claims Court" on Justia Law

The Supreme Court affirmed the decision of the district court granting summary judgment in favor of Central Montana Medical Center (CCMC) and dismissing Plaintiff's complaint alleging wrongful termination and violation of Mont. Code Ann. 39-2-904(1)(b) and (c) of the Wrongful Discharge from Employment Act, holding that the district court did not err.In granting summary judgment in favor of CCMC and denying Plaintiff's motion for summary judgment, the district court determined that CMMC terminated Plaintiff's employment for good cause and that CMMC did not violate its express written policies when it terminated Plaintiff. The Supreme Court affirmed, holding that there were no genuine issues of material fact in this case, and CMMC was entitled to judgment as a matter of law. View "Putnam v. Central Montana Medical Center" on Justia Law