Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the district court’s decision upholding the decision of the hearing officer with the Montana Human Rights Bureau (HRB) in favor of All Star Painting on Plaintiff’s complaint alleging that the company’s owner had sexually harassed her at work. The Court held (1) the district court erred in dismissing Plaintiff’s petition for judicial review because the hearing officer’s decision either ignored the testimony of four individuals, all of whom corroborated Plaintiff’s testimony, or misapprehended the effect of that evidence; and (2) the district court properly dismissed All Star Painting’s owner as a party to the action because he was never properly added as a party under Mont. R. Civ. P. 20. View "Jones v. All Star Painting Inc." on Justia Law

The Supreme Court reversed the judgment of the district court granting summary judgment to the Wolf Point School District Board of Trustees (Board) on Plaintiff’s claim that the Board unlawfully terminated her employment in violation of the open meeting law, Mont. Code Ann. 2-3-203, and Mont. Const. art. II, 9.Plaintiff appeared before the Board for a hearing regarding the termination of her employment. The Board closed the meeting to the public and then re-opened the meeting to the public, at which time a trustee made a motion, seconded by another, for the Board to terminate Plaintiff’s employment. The meeting was then closed again to everyone except the Board and the superintendent to allow the Board to discuss unspecified litigation strategy at an “executive session” with the Board’s lawyer. When Plaintiff was allowed back into the room the Board voted to terminate Plaintiff’s contract. The Supreme Court reversed the district court's grant of summary judgment to the Board, holding that the district court (1) erred in granting summary judgment that the Board lawfully closed the hearing portion of the meeting based on third-party privacy rights; and (2) erred in granting summary judgment that the Board lawfully excluded Plaintiff from its “executive session” under the litigation strategy exception of section 2-3-203(4). View "Raap v. Board of Trustees, Wolf Point School District" on Justia Law

The Workers’ Compensation Court (WCC) erred by ruling that a chiropractor may not make a medical determination regarding the claimant’s 1991 work-related injury in this case.In 1991, Claimant suffered injuries while working for Employer. Based on Chiropractor’s opinion, Claimant presented claims to Employer’s successor (Employer) for permanent partial disability and vocational rehabilitation benefits. Employer denied the claim on the ground that it was premised upon the medical determination of a chiropractor, rather than a physician, as required by the 1991 workers’ compensation statutes. Claimant filed a petition in the WCC. The WCC granted summary judgment to Employer, concluding that the 1991 statutes rendered Chiropractor’s opinion inadmissible. The Supreme Court reversed, holding (1) EBI/Orion Group v. Blythe, 931 P.2d 38 (Mont. 1997), controlled the outcome here; and (2) reversal was required because the WCC determined it was bound to follow Fleming v. International Paper Co., 194 P.3d 77 (Mont. 2008), as this Court’s most recent holding on the issue, but this Court’s overboard analysis in Fleming was in error. View "Murphy v. Westrock" on Justia Law

The Supreme Court affirmed the order of the district court awarding summary judgment to the Missoula County Detention Facility and the Missoula County Sheriff’s Office (collectively, the County) on Plaintiff’s claim that the County had illegally discriminated against him based on his disability. Plaintiff initially filed a complaint with the Human Rights Bureau (HRB), which found no reasonable cause to believe that the County had discriminated against Plaintiff. The district court agreed. The Supreme Court Supreme Court affirmed, holding (1) the district court did not err in declining to consider evidence arising after Plaintiff filed his HRB complaint; and (2) the district court correctly granted summary judgment for the County. View "Borges v. Missoula County Sheriff’s Office" on Justia Law

The Supreme Court affirmed the order of the district court awarding summary judgment to the Missoula County Detention Facility and the Missoula County Sheriff’s Office (collectively, the County) on Plaintiff’s claim that the County had illegally discriminated against him based on his disability. Plaintiff initially filed a complaint with the Human Rights Bureau (HRB), which found no reasonable cause to believe that the County had discriminated against Plaintiff. The district court agreed. The Supreme Court Supreme Court affirmed, holding (1) the district court did not err in declining to consider evidence arising after Plaintiff filed his HRB complaint; and (2) the district court correctly granted summary judgment for the County. View "Borges v. Missoula County Sheriff’s Office" on Justia Law

Christita Moreau appealed a Workers’ Compensation Court (WCC) order denying her motion for summary judgment and granting summary judgment to Transportation Insurance Company. Moreau’s husband Edwin worked at the W.R. Grace mine near Libby. In 2009, he died from asbestos-related lung cancer. In 2010 Moreau, as personal representative of Edwin’s estate, filed a workers’ compensation claim for occupational disease benefits. Transportation Insurance Company (Transportation) was W.R. Grace’s workers’ compensation insurer, and it denied liability for the claim. Edwin’s employer, W.R. Grace, established and funded the Libby Medical Plan (LMP) to pay the medical expenses of its employees who were injured by exposure to asbestos. LMP paid approximately $95,000 of Edwin’s medical expenses. In 2012, as part of Grace’s bankruptcy, “certain rights and duties of the LMP” were transferred to the Libby Medical Plan Trust. Grace remained responsible for LMP’s “ongoing payment obligations” incurred before that time. In 2013, Transportation accepted liability for the workers’ compensation claim and entered a settlement with Moreau. Transportation agreed to reimburse Medicaid, other providers, and Moreau personally for medical expenses each had paid for Edwin’s care. The parties stipulated that Transportation paid all of Edwin’s medical bills or reimbursed the other persons or entities that had paid them. Transportation did not reimburse the LMP for the $95,846 of Edwin’s medical bills it had previously paid because the LMP refused to accept it. After the LMP refused to accept reimbursement from Transportation, Moreau demanded that Transportation pay the $95,000 either to Edwin’s Estate, to the LMP or its successor, or to a charity selected by the Estate. Transportation refused and Moreau filed a second petition with the WCC to resolve the issue. The WCC determined that all of Edwin’s medical care costs had been paid; that Edwin had no liability to any health care provider; and that he had no right to claim any further payment from Transportation. The WCC determined that if the Estate were to receive the $95,000 from Transportation it would represent a double recovery because Edwin had already received the medical benefits themselves. The Court concluded that Moreau therefore lacked standing to proceed Moreau’s petition. The WCC also found that Moreau’s attorneys also represented the LMP Trust “for purposes of recovering the disputed $95,846” for the LMP Trust. At the time of the WCC order, the LMP Trust was not a party to this action and had not advanced a claim in the WCC for reimbursement of the amount paid by its predecessor LMP. The WCC therefore granted summary judgment to Transportation. Finding no reversible error in that WCC decision, the Montana Supreme Court affirmed. View "Moreau v. Transportation Ins." on Justia Law

The Supreme Court reversed the order of the district court granting Burlington Northern and Santa Fe Railway Company’s (BNSF) motion for summary judgment on Kelly Watson’s asbestos-related disease claim, brought under the Federal Employers’ Liability Act, holding that the bankruptcy court’s order enjoining claims against W.R. Grace and other “affiliated entities,” including BNSF, tolled the statute of limitations on Watson’s claim. Thus, the district court erred in concluding that the bankruptcy court’s order expanding a previous injunction barring the commencement or filing of new claims to include BNSF as a nondebtor affiliate did not bar the commencement of new actions against BNSF. View "Watson v. BNSF Railway Co." on Justia Law

The Supreme Court affirmed the district court’s grant of summary judgment dismissing Plaintiff’s claims for wrongful discharge under the Montana Wrongful Discharge from Employment Act (WDEA).Plaintiff sued Defendant, his former employer, for damages for wrongful discharge under WDEA, asserting that Defendant lacked good cause to terminate his employment, failed to follow its written personnel policies, and terminated him for refusing to violate public policy or for reporting violations of public policy. The district court granted Defendant’s motion for summary judgment on all claims, concluding that Plaintiff did not have a wrongful discharge claim because he was a probationary employee who could be terminated for any reason as provided in Mont. Code Ann. 39-2-904(2). The Supreme Court affirmed, holding (1) the district court correctly found that Plaintiff was still on probation when Defendant terminated his employment; and (2) the district court properly granted summary judgment to Defendant on the whistleblower issue because Plaintiff failed to produce any evidence to support his contention. View "Dundas v. Winter Sports, Inc." on Justia Law

The Supreme Court affirmed the district court’s decision affirming the decision by the Unemployment Insurance Appeals Board denying Joyce Crouse’s claim for unemployment benefits. The district court affirmed the Board’s conclusion that Crouse did not qualify for unemployment benefits because her voluntary termination did not constitute “good cause” pursuant to Mont. Code Ann. 39-51-2302. The Supreme Court agreed with the lower court, holding (1) the findings of the Board were supported by substantial evidence; and (2) the district court correctly affirmed the Board’s decision to deny Crouse’s claim for benefits because she voluntarily resigned her position. View "Crouse v. State, Department of Labor" on Justia Law

The City appealed the district court's order and judgment holding that the City incorrectly paid "longevity" wage benefits under successfully negotiated collective bargaining agreements (CBAs) and awarding damages to Officers. The Montana Supreme Court held that the district court erred by concluding as a matter of law that the longevity provisions of the subject CBAs were unambiguous. In this case, the differing language of the successive CBAs were reasonably subject to more than one interpretation, and the blanket exclusion of all extrinsic evidence offered by the City—while selectively relying on other extrinsic evidence—was likewise erroneous. Accordingly, the court reversed and remanded for further proceedings. View "Watters v. Billings" on Justia Law