Justia Montana Supreme Court Opinion Summaries

Plaintiff filed a petition for a hearing in the Montana Workers’ Compensation Court (WCC) asking the court to order Teck American, Inc. to continue to provide medical benefits for a knee injury he sustained while working for Teck. The WCC found that Plaintiff was entitled to medical benefits, that Plaintiff’s claim was not barred due to a superseding intervening cause, that Teck was equitably estopped from denying medical benefits on Plaintiff’s claim under Mont. Code Ann. 39-71-704(1)(d), and that Teck’s statute of limitations and statute of repose defenses were moot. The Supreme Court affirmed, holding (1) Plaintiff and Teck formed an enforceable contract when both parties agreed to close several of Plaintiff’s claims in exchange for a lump sum payment and lifetime health benefits for his knee and back injuries; and (2) the WCC did not err in concluding that Teck cannot deny medical benefits to Plaintiff on the basis of section 39-71-704(1)(d). View "Newlon v. Teck American, Inc." on Justia Law

After Jon Cruson resigned from his position with Missoula Electric Cooperative, Inc., he filed a claim for unemployment benefits with the Montana Department of Labor and Industry’s Unemployment Insurance Division (Department). The Department ultimately granted Cruson unemployment insurance benefits beginning on the date of his resignation. The Hearings Bureau reversed, concluding that Cruson was disqualified from receiving benefits because the reason he offered for quitting did not constitute good cause attributable to his employment. The Board of Labor Appeals affirmed. The district court denied Cruson’s appeal, determining that the Board correctly applied the law to the facts when it determined that Cruson did not voluntarily leave his employment with good cause attributable to his employer. The Supreme Court affirmed, holding that the Board’s factual findings were supported by substantial evidence, and its legal conclusion that “good cause attributable to the employer” had not been shown was correct. View "Cruson v. Missoula Elec. Coop." on Justia Law

After five years of employment with Employer, Employee was terminated. Employee brought this action against Employer alleging wrongful discharge and seeking damages. After a hearing, the district court granted summary judgment in favor of Employer, concluding that substantial undisputed evidence supported Employer’s claim of good cause for termination. The Supreme Court affirmed, holding that the district court did not err in ruling as a matter of law that good cause existed for Employee’s discharge from employment under Mont. Code Ann. 39-2-904(1)(b) and that summary judgment in favor of Employer was appropriate. View "Davis v. Dep’t of Pub. Health & Human Servs." on Justia Law

Appellant, an employee of BNSF Railway, sued BNSF under the Federal Employers’ Liability Act, alleging that BNSF negligently assigned him to work that caused cumulative trauma injuries to his musculoskeletal system, particularly his lower back. The jury returned a verdict finding that Appellant’s cumulative trauma claim was barred by the statute of limitations. Appellant filed a motion for a new trial, arguing that BNSF’s prejudicial questions and arguments deprived him of a fair trial. The district court denied the motion. The Supreme Court reversed, holding that cumulative prejudice from BNSF’s unlawful appeal to the passions and prejudices of the jury denied Appellant a fair trial. View "Anderson v. BNSF Railway" on Justia Law

Plaintiff sued Defendant, a corporation, alleging wrongful discharge, negligent infliction of emotional distress, and defamation after his employment was terminated. The district court granted Defendant’s motion to dismiss for lack of subject-matter jurisdiction, determining that Ohio law governed Plaintiff’s claims. The Supreme Court vacated the district court’s dismissal and remanded for consideration of whether dismissal under the doctrine of forum non conveniens was appropriate, holding (1) the district court did not err in considering evidence outside the pleadings in disposing of Defendant’s motion to dismiss; but (2) the district court was incorrect to conclude that the application of Ohio law to Plaintiff’s claims requires dismissal for lack of subject-matter jurisdiction. View "Harrington v. Energy West, Inc." on Justia Law

Robert and Tina George filed a complaint against Curtis and Jean Bowler arising from injuries Robert sustained on Defendants’ property. Robert was employed as a warehouse manager for Carpets Plus when he was injured. Robert filed suit against the Bowlers in their individual capacities as the property owners and general contractors of the warehouse alleging that the Bowlers failed to provide a safe place to work in violation of the Montana Occupational Safety and Health Act. The Bowlers pleaded the Workers’ Compensation Act’s (WCA’s) exclusivity provision as an affirmative defense, arguing that, as corporate directors, they were co-employees of Robert at Carpets Plus and were thus exempt from suit for Robert’s workplace injuries. The district court concluded that the Bowlers were immune from suit under the WCA’s exclusivity provision because they were acting in their capacities as corporate officers of Carpets Plus at the time they were alleged to have failed to provide a Carpets Plus employee with a safe place to work. The Supreme Court affirmed, holding that because the Bowlers were acting within the course and scope of their employment for Carpets Plus at all relevant times, they were protected from suit by the exclusivity provision of the WCA. View "George v. Bowler" on Justia Law

While in the course and scope of his employment with Employer, Plaintiff suffered serious injuries. Plaintiff recovered workers’ compensation insurance benefits in the amount of $207,147. Plaintiff subsequently brought this action against Employer, alleging that Employer was an uninsured employer under the Workers’ Compensation Act at the time of the accident. The district court granted summary judgment in favor of Employer, concluding that Employer was an insured employer under the Act and was therefore entitled to tort immunity pursuant to Mont. Code Ann. 39-71-411. The Supreme Court affirmed, holding that the district court did not err in concluding that Employer was an insured employer under the Act and therefore was entitled to tort immunity. View "Stokes v. Golden Triangle, Inc." on Justia Law

Plaintiffs were laborers who worked on the construction and rehabilitation of two multi-family housing projects. Plaintiffs filed this wage and hour action and moved for certification of a proposed class including all laborers, tradesmen, and craftsmen who worked for Monfric, Inc., the general contractor, or its subcontractors and who were not paid prevailing wages during the construction and rehabilitation of the housing projects. The district court denied Plaintiffs’ motion for class certification, concluding that Plaintiffs failed to demonstrate numerosity of the proposed class. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it concluded that Plaintiffs failed to establish that their proposed class was so numerous as to make joinder of its remaining members in a single action impracticable. View "Morrow v. Monfric" on Justia Law

F.H. Stoltze Land & Lumber Company and Maxum Specialty Insurance Group (collectively, “Stoltze”) and Les Schlegel Enterprises (“Schlegel”) contracted for Schlegel to log Stoltze’s property. Schlegel obtained liability insurance from American States Insurance Company (ASI). Whitney Shanks, a worker for Schlegel, injured himself during logging operations on Stoltze’s property. Shanks filed a personal injury lawsuit against both Schlegel and Stoltze. Stoltze tendered defense and indemnity of Shanks’s suit to ASI. After ASI accepted the tender, the district court dismissed the case against Schlegel on the grounds that Schlegel was immune to suit under the Workers’ Compensation Act’s exclusive remedy provision. ASI subsequently withdrew its defense of Stoltze, asserting that the policy covered Stoltze only to the extent that Schlegel was liable. Stoltze then filed a complaint against ASI, seeking declaratory judgment that ASI was required to defend and indemnify Stoltze against Shanks’s suit. The district court entered summary judgment for ASI, concluding that because the court in the underlying action determined that Schlegel was immune and not liable, ASI had no duty to defend or indemnify Stoltze. The Supreme Court affirmed, holding that ASI’s insurance policy with Schlegel did not require ASI to defend and indemnify Stoltze in an action in which Schlegel could not be held liable. View "F.H. Stoltze Land & Lumber Co. v. Am. States Ins. Co." on Justia Law

Plaintiff was injured while working as a switchman/brakeman for BNSF Railway Company. Plaintiff later brought this action against BNSF under the Federal Employers’ Liability Act (FELA) alleging negligence. The jury returned a verdict in BNSF’s favor on negligence and strict liability claims for violations of the Locomotive Inspection Act (LIA). The district court subsequently denied Plaintiff’s motion for judgment as a matter of law or, in the alternative, motion for a new trial. The Supreme Court affirmed in part, reversed in part, and remanded for a new trial, holding that the district court (1) did not err by allowing Plaintiff’s LIA claim to be considered by the jury; (2) did not abuse its discretion by excluding evidence of heated platforms at BNSF’s Whitefish and Essex depots; but (3) abused its discretion by admitting into evidence the specific amount of income Plaintiff made from his non-railroad employment. View "Martin v. BNSF Railway Co." on Justia Law