Justia Montana Supreme Court Opinion Summaries

Steve Sangwin, a State employee, was a qualified subscriber and beneficiary of the State of Montana Employee Benefits Plan (Plan), which was administered by Blue Cross and Blue Shield of Montana (BCBS). Steve's daughter, McKinley, was also a beneficiary under the Plan. This case arose after BCBS denied a preauthorization request for a medical procedure for McKinley on the grounds that the procedure was "experimental for research." Steve and his wife (collectively, the Sangwins) initiated this action by filing an amended complaint setting forth five counts, including a request for certification of a class action. The Sangwins defined class members as other beneficiaries of the Plan who had their employee benefits denied by the State based on the experimental exclusion for research in the past eight years. The district court granted the Sangwins' motion for class certification. The State appealed. The Supreme Court (1) affirmed the district court's order defining the class; but (2) reversed and remanded with respect to the question certified for class treatment, holding that the district court abused its discretion in specifying for class treatment the question of whether the State breached its contract of insurance with the plaintiffs. View "Sangwin v. State" on Justia Law

The Montana Association of Counties Joint Powers Insurance Authority (MACo/JPIA) obtained catastrophic property insurance from Allianz Global Risks US Insurance Company to cover damages over $100,000. The Lincoln County Port Authority (Port) insured a building in its industrial facility through the MACo/JPIA self-insured risk pool. After the building's roof collapsed, MACo/JPIA informed the Port that it would no longer insure the building. The building was subsequently destroyed by a fire, and MACo/JPIA and Allianz refused to cover the loss. The Port filed this suit against Allianz. The district court concluded that the Allianz policy insured the Port and awarded $6,060,980 based on the findings of an appraisal panel. The Supreme Court (1) affirmed the district court's determination that Allianz's policy provided coverage for the building; (2) affirmed the district court's refusal to reform the Allianz policy; (3) reversed the district court's award of "replacement cost" for those portions of the building that the Port had slated for demolition; and (4) remanded to allow the district court to calculate post-judgment interest owed to the Port for the damages owed under the policy. View "Lincoln County Port Auth. v. Allianz Global Risks US Ins. Co." on Justia Law

In 1997, the district court granted Adriana Lockhead a temporary order of protection against Brian Lockhead. In 1999, the court made the order permanent and served Brian with a permanent order of protection. Brian did not appeal the order. In 2012, Brian filed a motion to vacate the permanent order of protection. The trial court denied the motion. Brian appealed, raising multiple issues. The trial court affirmed, holding (1) all but one of Brian's issues on appeal were barred from appellate review because Brian filed to timely appeal and failed to raise the issues with the district court; and (2) the district court did not abuse its discretion in denying Brian's motion to vacate the permanent order of protection, as Brian failed to prove the district court acted without conscientious judgment or in a way that exceeded the bounds of reason. View "In re Marriage of Lockhead" on Justia Law

Mother and Father were the parents of twins born in 2009. In 2011, the district court entered orders adjudicating the twins as youths in need of care. In 2012, the district court approved the Department of Public Health and Human Services' (DPHHS) permanency plan seeking termination of Mother's parental rights. Father subsequently relinquished his parental rights. After a hearing, the district court entered orders terminating Mother's parent-child relationship with the twins and awarded permanent legal custody of the children to DPHHS. The Supreme Court affirmed in part and remanded in part, holding (1) the district court did not err in denying Mother's request to terminate the services of Mother's court-appointed counsel; (2) because Mother's affidavit of relinquishment was silent as to the issue of whether Mother received relinquishment counseling, the cause is remanded for a determination of whether Mother received the required counseling or whether good cause existed to waive the requirement; and (3) the district court did not err in denying Mother's request to modify the treatment plan and stay the termination hearing. View "In re B.J.T.H." on Justia Law

Before he resigned, Plaintiff worked as the education director for Defendant, a farm organization. Plaintiff filed this action, claiming (1) Defendant failed to pay him for overtime, for vacation, and for his work handling the duties formerly assigned to the executive director; (2) Defendant's president (President) interfered with his employment relationship with Defendant; and (3) Defendant constructively discharged him because he refused to violate the law regarding payment of wages and overtime. The jury returned a special verdict form in all respects favorable to Plaintiff and awarded $232,439 in compensatory damages and $300,000 in punitive damages. The Supreme Court reversed and remanded in part and affirmed in part, holding (1) the district court erred in denying summary judgment on Plaintiff's wage claims; (2) the district court erred in denying judgment as a matter of law on Plaintiff's claim against President individually; (3) Defendant was not entitled to a new trial on Plaintiff's constructive discharge claim; and (4) the punitive damages claim properly went to the jury, but the trial court should have limited the award to three percent of Defendant's net worth as required by Mont. Code Ann. 27-1-220(3). View "Harrell v. Farmers Educ. Coop. Union of Am., Mont. Div." on Justia Law

Darleen Anderson died after a scab from a graft ruptured and Anderson pled to death. The graft was placed in Anderson's arm by Defendant, a board certified surgeon. Plaintiffs, as personal representatives of Anderson's estate, filed this malpractice action against Defendant. During trial, Plaintiffs sought an instruction that Defendant should be held to the standard of care of a board certified vascular surgeon, rather than a general surgeon. The district court refused Plaintiffs' instruction and gave the instruction proposed by Defendant. The Supreme Court affirmed the district court's decision regarding the jury instructions, holding that the district court did not err by refusing to give Plaintiffs' proposed jury instruction regarding the standard of care applicable to Defendant and instead giving Defendant's proposed instruction. View "Anderson v. Harper" on Justia Law

NorthWestern Energy (NWE) disconnected electric service to Plaintiff's residence based on an outstanding balance on Plaintiff's utility bill. Plaintiff filed an action alleging property damage due to NWE's negligence and negligence per se, claiming that the termination of his electric service caused his furnace to fail, which led to water pipes freezing and bursting. NWE filed a motion to dismiss based on lack of subject-matter jurisdiction for Plaintiff's failure to exhaust administrative remedies before the Public Service Commission (PSC). The district court granted NWE's motion and dismissed the action. The Supreme Court reversed, holding that the PSC had no authority to adjudicate Plaintiff's damage claim, and a negligence action seeking damages could be maintained against the power company in district court. View "Schuster v. NorthWestern Energy Co." on Justia Law

Plaintiff, a former high school instructor, was terminated from her employment for insubordination. Plaintiff appealed her termination to binding arbitration pursuant to the terms of a collective bargaining agreement. The arbitrator denied Plaintiff's grievance. The district court upheld the arbitration award, concluding that the arbitrator had not exceeded his powers and that Plaintiff had failed to meet her burden of proving that a ground for vacating, correcting, or modifying the award existed. The Supreme Court affirmed, holding that the district court did not abuse its discretion in refusing to vacate, modify, or correct the arbitration award. View "Roberts v. Lame Deer Sch. Dist. No. 6" on Justia Law

Plaintiff, a Delaware LLC operating in Montana, purchased a cable television network infrastructure in Montana in 2003. In 2010, Plaintiff filed a declaratory judgment action in response to certain actions taken by the State of Montana Department of Revenue. Specifically, Plaintiff sought (1) to prevent the Department from issuing revised assessments of Plaintiff for tax years 2007 through 2009 and to prevent the Department from issuing any other revised assessments, and (2) a declaration that the Department had illegally assessed all of Plaintiff's property as class thirteen property. The district court granted summary judgment for Plaintiff on the Department's ability to issue retroactive assessments and directed the Department to refund with interest the payments that Plaintiff had made under protest. The Supreme Court reversed, holding that the district court erred in concluding (1) Plaintiff owned exclusively class eight property because, under Montana law, Plaintiff was subject to assessment under class thirteen; and (2) the Department lacked authority to issue revised assessments for Plaintiff's property for tax years 2007 through 2009 where the Department's discovery and subsequent reclassification arose from the audit's revelation of inaccuracies in Plaintiff's self-classification. View "Bresnan Commc'ns, LLC v. Mont. Dep't of Revenue" on Justia Law

After a jury trial, Defendant was convicted of vehicular homicide while under the influence, failure to stop immediately at the scene of an accident involving an injured person, and driving without a valid driver's license. The Supreme Court affirmed, holding (1) the district court did not err by limiting Defendant's cross-examination of the State's informant; (2) the district court erred when it prevented Defendant's expert forensic pathologist from testifying about matters not disclosed through discovery, but the error was harmless; and (3) the district court's decision to permit an undisclosed expert witness to testify for the State did not constitute reversible error. View "State v. Garding" on Justia Law