Justia Montana Supreme Court Opinion Summaries

The Supreme Court reversed the district court’s judgments ruling that the Montana Public Employees’ Association (MPEA) breached its duty of fair representation (DFR) to Jeffrey Folsom and engaged in common law fraud, awarding Folsom attorney fees as an element of compensatory damages on his DFR claim and awarding $50,000 in punitive damages on his common law fraud claim. The Supreme Court held (1) Folsom’s separately pled common law fraud claim is necessarily subsumed in his DFR claim and is thus not independently cognizable in this case; (2) the district court did not err in denying Folsom’s claim for compensatory lost wages and benefits on his DFR claim; (3) the district court erred in awarding fees to Folsom as an element of compensatory damages on his DFR claim; (4) the district court erred in awarding punitive damages without a compensatory damages predicate; and (5) the district court abused its discretion in refusing to grant MPEA’s motions for postjudgment relief from its summary judgment. View "Folsom v. Montana Public Employees’ Ass’n" on Justia Law

After Plaintiff’s employment was terminated, he filed suit against Defendant alleging wrongful discharge, negligent infliction of emotional distress, and defamation. The district court granted Defendant’s motion to dismiss for lack of subject-matter jurisdiction, concluding that Ohio law governed or, alternatively, that Ohio was the appropriate forum to exercise jurisdiction. The Supreme Court vacated the district court’s dismissal, holding that Montana courts had subject-matter jurisdiction over Plaintiff’s claim, and remanded for further proceedings to consider whether dismissal under the doctrine of forum non conveniens was appropriate. On remand, the district court denied Plaintiff’s motion to amend the complaint and granted Defendant’s motion to dismiss under forum non conveniens. The Supreme Court affirmed, holding that the district court (1) did not act arbitrarily or exceed the bounds of reason in concluding that Plaintiff’s amendment would prejudice Defendant and that the amendment would run counter to the Supreme Court’s remand instructions in Harrington I; and (2) did not abuse its discretion by determining that resolution of Plaintiff’s claims in Ohio would promote the convenience of witnesses and the ends of justice. View "Harrington v. Energy West Inc." on Justia Law

While employed by a company now known as Asurion Services, LLC, Christy Harris filed industrial injury claims for two different incidents. Lumbermens Mutual Casualty Company adjusted Harris’s workers’ compensation claims until it was declared insolvent. Montana Insurance Guaranty Association (MIGA) subsequently assumed the handling of Harris’s claims. Thereafter, MIGA notified Asurion that it would seek reimbursement for the benefits it paid to Harris pursuant to Mont. Code Ann. 33-10-114(2). Asurion filed a declaratory judgment action against MIGA. The district court granted motion for Asurion based on the exclusivity provision of the Montana Workers’ Compensation Act (Act), concluding that because Asurion met its obligation to obtain workers’ compensation insurance, it had no payment obligations to Harris, and therefore, Mont. Code Ann. 33-10-114(2) did not afford MIGA relief. The Supreme Court affirmed, holding that because Asurion provided workers’ compensation coverage in accordance with the Act, Asurion was not required to reimburse MIGA for benefits paid to Harris. View "Asurion Services, LLC v. Montana Insurance Guaranty Ass’n" on Justia Law

Charlene Berdahl, a court reporter, filed a sexual harassment complaint against Judge George Huss, a district judge, with the Montana Human Rights Bureau (HRB). Huss’s attorney requested that the State agree to defend and indemnify Huss regarding Berdahl's HRB claims. Berdahl and Huss subsequently entered into a stipulated judgment resulting from the State’s refusal to defend and indemnify. The State filed this action seeking declarations that the State had no duty to defend or indemnify Huss against the claims and that Huss had entered a settlement without the consent of the State, which was unenforceable against the State. Berdahl counterclaimed seeking declarations that the State was responsible for the stipulated judgment entered by Berdahl and Huss and that the State was liable under the principle of respondent superior. The district court rejected Berdahl’s request for a declaration and held that the State owed no duty to defend or indemnify Huss. The court further reasoned that Berdahl’s exclusive remedy regarding her respondent superior claim was under the Montana Human Rights Act. The Supreme Court affirmed, holding that the district court did not err in concluding that the State bore no obligation to pay the stipulated settlement between Huss and Berdahl. View "State v. Berdahl" on Justia Law

Charlotte Suzor injured her knees in a workplace accident in 1982 and settled her workers’ compensation claims in 1987 with her self-insured employer, reserving the right to seek future medical benefits for ongoing complications from her injury. In 2009, Suzor broke her hip after her knees gave out. Suzor’s physical filed a claim with Sedgwick Claims Management Services (Sedgwick), the third-party administrator for the workers’ compensation plan now funded by her employer’s successor in interest, International Paper Company (International). After Sedgwick denied the claim, Suzor sued International, Sedgwick, and two of Sedgwick’s employees (collectively, Defendants), alleging bad faith and breach of fiduciary duty. The district court entered judgment in favor of Defendants. The Supreme Court affirmed, holding (1) Defendants did not owe Suzor a fiduciary duty; (2) the district court did not abuse its discretion in denying Suzor’s jury instruction on causation; (3) the mistaken association of a wrong juror questionnaire with a juror was not a structural error necessitating a new trial; (4) the jury’s award of no damages was supported by sufficient evidence; and (5) the district court did not abuse its discretion in its award of attorney’s fees. View "Suzor v. International Paper Co." on Justia Law

After the Cascade County Board of Commissioners terminated Stacey Bird from her position as the County’s human resources director, Bird filed a wrongful discharge claim against the County and the Board. The district court granted summary judgment in favor of the County, concluding that the County had good cause to terminate Bird. The Supreme Court affirmed, holding that the district court did not err in granting summary judgment in favor of the County on Bird’s claim that the County terminated her employment without good cause, as the County met its initial burden of showing good cause for Bird’s termination, and Bird failed to raise a genuine issue of material fact as to whether the County had legitimate business reasons for discharging her. View "Bird v. Cascade County" on Justia Law

After she was demoted from her position with the Montana Department of Transportation, Sheila Cozzie filed a grievance. Following a contested case proceeding, the hearing examiner recommended that Cozzie’s grievance be denied. Cozzie appealed to the full Board of Personnel Appeals (BOPA). The BOPA voted to grant Cozzie’s grievance and issued a final decision reinstating Cozzie. On appeal, the district court ruled that BOPA acted outside the scope of review, concluding that the BOPA improperly struck findings of fact and incorrectly modified conclusions of law. The Supreme Court affirmed, holding that the district court (1) did not err by affirming the evidentiary ruling made by the hearing examiner; and (2) did not err by reversing the BOPA’s just cause decision. View "Department of Transportation v. Department of Labor" on Justia Law

The underlying claim in this case, which had been appealed on three previous occasions, concerned an exclusion in the State’s health benefit insurance plan, which allowed the State to coordinate benefits in violation of Montana’s made whole laws. Jeanette Diaz, Leah Hoffman-Bernhardt, and others similarly situated (collectively, Diaz) filed suit alleging that third-party administrators and the State (collectively, Defendants) had violated employees’ made whole rights under Montana law. During the various appeals, the Supreme Court concluded that the district court certified and defined a class and that the district court correctly denied the State’s motion for summary judgment. In this, the fourth appeal, Diaz appealed a district court order determining the manner in which prejudgment interest on payments due to class members was to be calculated. The Supreme Court affirmed the district court’s order declaring interest to begin thirty days following the Court’s decision in Blue Cross & Blue Shield of Montana v. Montana State Auditor. Remanded for the district court to correct the date to be applied for determining the calculation of prejudgment interest. View "Diaz v. State" on Justia Law

Appellee filed an action against Missoula Electric Cooperative (MEC), asserting age discrimination in the hiring process. A Human Rights Bureau Investigator granted summary judgment for MEC, concluding that, as a matter of law, Appellee could not prove a case against MEC. The Human Rights Commission overturned its Hearing Examiner’s decision. The district court affirmed, holding that the Commission properly reversed the Hearing examiner’s decision because genuine issue of material fact existed, thus precluding summary judgment. The Supreme Court affirmed, holding that the Commission did not err by determining that the Hearing Examiner improperly granted summary judgment to MEC. View "Missoula Electric Cooperative v. Jon Cruson Inc." on Justia Law

After Lisa Warrington accepted an offer of employment with Great Falls Clinic (the Clinic), she signed a written employment contract. On Warrington’s last day at her former job, the Clinic informed her it would not employ her after all. Warrington filed an action against the Clinic, asserting breach of contract, promissory estoppel, and breach of the covenant of good faith and fair dealing. The district court granted summary judgment on the breach of contract claim and found that the Wrongful Discharge From Employment Act (the Act) did not apply. The Clinic petitioned the Supreme Court for a writ of supervisory control, arguing that the district court made a mistake of law by concluding that the Act did not apply to the relationship between Warrington and the Clinic. The Supreme Court accepted the petition for supervisory control, affirmed the district court’s determination that the Act does not apply to the relationship between the parties, and affirmed the district court’s order granting summary judgment to Warrington on the breach of contract claim. View "Great Falls Clinic LLP v. Eighth Judicial Dist. Court" on Justia Law