Justia Montana Supreme Court Opinion Summaries

Leonard Landa was the sole managing member of a Montana limited liability corporation. Landa carried commercial general liability insurance through Assurance. After a former employee of Landa's filed a complaint alleging that Landa had committed various torts by inducing him to work for Landa under allegedly false pretenses, Landa tendered defense of the former employee's claim to Assurance. Assurance refused to defend Landa, stating that the complaint's allegations were not covered under Landa's policy. Landa filed a complaint seeking declaratory relief establishing that Assurance had a duty to defend and indemnify Landa and alleging violations of Montana's Unfair Trade Practices Act (UTPA), negligence, and other causes of action. The district court granted summary judgment for Assurance, finding that the complaint's allegations were not covered under Landa's policy and that Assurance was not liable under the UTPA because the denial of coverage was grounded on a legal conclusion. The Supreme Court affirmed, holding that Assurance correctly declined to provide a defense where the former employee's complaint did not allege an "occurrence" and, as a result, did not trigger a duty to defend under the policy. View "Landa v. Assurance Co. of Am." on Justia Law

Plaintiffs were insured through the State group insurance plan administered by Defendants. Both Plaintiffs were injured in automobile accidents caused by tortfeasors whose insurers accepted liability. The third-party insurers paid Plaintiffs' medical providers, but in both cases, the State and Defendants allegedly exercised their rights of subrogation without confirming that Plaintiffs under the State plan had been made whole. Plaintiffs filed a class complaint seeking a declaratory ruling that Defendants' practices violated the State's made-whole laws. On remand, the district court defined the class to include only those insureds who had timely filed claims for covered benefits, thus excluding from the class all non-filing insureds. The Supreme Court affirmed, holding that the incorporation of the filing limitation did not constitute an abuse of discretion. View "Diaz v. State" on Justia Law

Mont. Code Ann. 15-7-211 requires the Department of Revenue (Department) to reappraise all residential property in the state every six years. The Department assessed the value of Plaintiff's property in 2008 and used the 2008 appraisal to establish Plaintiff's tax liability for the six-year tax cycle ending in 2014. Plaintiff argued that section 15-7-111, as applied, violated its right to equal protection. The State Tax Appeal Board rejected the claim. The district court, however, concluded that section 15-7-111 violated Plaintiff's right to equal protection because the six-year tax cycle caused some taxpayers to pay a disproportionate share of taxes due to their over-assessed property value and other taxpayers to pay less than their fair share of taxes due to their under-assessed property value. The Supreme Court reversed, holding that similarly situated taxpayers, for a short time, may pay divergent taxes, and such a divergence in taxes does not violate equal protection privileges. View "Covenant Invs., Inc. v. Dep't of Revenue" on Justia Law

Plaintiff was a patron at the Crystal Bar when she was hit on the head by Jason Howard, a friend of the bouncer, causing him to fall and strike his head. Plaintiff filed a complaint against the Crystal Bar, alleging, among other claims, negligence and liquor shop liability, or a "dram shop" claim. The district court entered summary judgment for the Crystal Bar on Plaintiff's negligence and dram shop claim, holding (1) there was no interaction between Plaintiff and Howard that should have alerted Crystal Bar employees that Howard posed any danger to plaintiff, and (2) it was uncontested that Howard was not intoxicated and had not been served at the Crystal Bar. The Supreme Court (1) affirmed the district court's grant of summary judgment to the Crystal Bar on Plaintiff's dram shop claim, as there was no evidence Howard was served alcohol by the Crystal Bar prior to the altercation; but (2) reversed the district court's grant of summary judgment on Plaintiff's negligence claims, as genuine issues of material fact existed as to whether the Crystal Bar had knowledge of the conflict between Plaintiff and Howard and whether Crystal Bar satisfied its duty of reasonable care under the circumstances. Remanded. View "Harrington v. Crystal Bar, Inc." on Justia Law

Wife sustained injuries as a result of Husband's negligent driving. Wife and Husband (Plaintiffs) sought coverage from Insurer, which denied coverage due to a family member exclusion in the umbrella police Husband held with Insurer. The district court concluded that the exclusion was unconscionable and entered summary judgment for Plaintiffs. The Supreme Court reversed and remanded for entry of summary judgment in favor of Insurer, holding (1) Plaintiffs failed to establish that the family member exclusion unconscionably favored State Farm, and the district court erred in so concluding; (2) the exclusion did not contravene and express statute, undermine the made-whole doctrine, or violate public policy in any other way; and (3) the policy unambiguously excluded Wife's claim from coverage, and the family member exclusion did not violate Plaintiffs' reasonable expectations. View "Fisher v. State Farm Mut. Auto. Ins. Co." on Justia Law

Employee contracted an occupational disease arising out of her employment with Employer. In 2006, Employee began seeking medical treatment. Employee received treatment periodically until 2011 when her doctor informed her that she had an occupational disease. Employee subsequently initiated a workers' compensation claim. Montana State Fund denied Employee's claim, asserting that the claim was not timely filed under the twelve-month statute of limitations. Employee appealed. The Workers' Compensation Court granted summary judgment for State Fund, concluding that the undisputed facts demonstrated that Employee knew or should have known that she was suffering from occupational disease as early as 2006. The Supreme Court reversed, holding that a material question of fact existed as to when Employee should have known she was suffering from an occupational disease. Remanded for a trial to determine when Employee knew or should have known she was suffering from an occupational disease. View "Dvorak v. State Fund" on Justia Law

Plaintiffs Dorothy Harris and Tedeen Holbert were injured in separate automobile accidents caused by third-party tortfeasors. Plaintiffs were treated at Billings Clinic and St. Vincent Healthcare (Providers) for their injuries. Both Harris and Holbert were members of health plans administered by Blue Cross Blue Shield (BCBS), which entered into a preferred provider agreement (PPA) with the Providers pursuant to which Providers accepted payment from BCBS at a discounted reimbursement rate for certain medical services for BCBS insureds. Plaintiffs subsequently filed a complaint against Billings Clinic, asserting breach of contract and constructive fraud claims and requesting compensatory damages equal to the difference between the amount the third-party insurers paid to the Providers and the reduced reimbursement rates under the PPA with BCBS. Harris also filed similar claims against St. Vincent Healthcare. The district courts dismissed the claims for failure to state a claim upon which relief can be granted. The Supreme Court affirmed, holding that the district court did not err in determining that the Providers were entitled to collect from third-party insurers payment for the full amount of the billed charges for the medical treatment provided to Plaintiffs. View "Harris v. St Vincent Healthcare" on Justia Law

Defendant pled guilty to felony DUI offenses and associated offenses, including two misdemeanor offenses. After Defendant began serving his period of probation, the State filed a petition to revoke Defendant's probation based upon his violation of certain conditions of probation. The district court issued a bench warrant for Defendant's arrest, but Defendant had absconded from supervision. Eight years later, the State petitioned the district court to quash the original arrest warrant and to issue a new warrant for Defendant's arrest. Defendant was subsequently arrested and sentenced. Defendant appealed, arguing that the eight-year delay between the initial arrest warrant and his actual arrest violated his right to due process. The Supreme Court remanded for resentencing, as the district court may have imposed a longer period of imprisonment than allowed. View "State v. Sullivant" on Justia Law

Defendant was charged with criminal possession of dangerous drugs with intent to distribute and was appointed counsel. A jury subsequently found Defendant guilty of criminal possession with intent to distribute. The Supreme Court affirmed, holding (1) the district court's pre-trial inquiry into Defendant's complaint about his counsel was adequate, and the court did not abuse its discretion by declining to further consider Defendant's complaints in a hearing; (2) the district court did not err in denying Defendant's motion for a new trial; and (3) the case was remanded so that the district court may conform the written judgment to the oral pronouncement of sentence, which conditioned any assessment of fees upon Defendant's future ability to obtain work if released on parole. View "State v. Hammer" on Justia Law

After a jury trial, Defendant was found guilty of felony DUI and driving without a valid driver's license. Defendant subsequently filed a motion to vacate his convictions primarily on the grounds that he had not received a probable cause hearing within forty-eight hours of his arrest. The district court denied Defendant's motion. The Supreme Court affirmed, holding that Defendant waived his right to complain that nineteen days was an unreasonable time for the State to initiate filing charges in the district court by failing to object or file a motion to dismiss before his trial. View "State v. Haller" on Justia Law