Justia Montana Supreme Court Opinion Summaries

Appellants, three individuals, alleged that Appellees, a newspaper and its editor, published defamatory statements about the group concerning an incident at a rest area near Conrad, Montana. The district court ruled that the statements did not constitute defamatory libel and granted summary judgment in favor of Appellees. The Supreme Court affirmed the grant of summary judgment as to Appellees, holding that, under the three-part analysis to determine whether the publication was defamatory, Appellees’ defamatory libel allegations failed because the public was not false within the meaning of court precedent regarding libel. View "Lee v. Traxler" on Justia Law

Robert Crawford was pulled over by Flathead Tribal Police Officer Casey Couture on the Flathead Reservation. Crawford was allowed to leave but was then informed that he was in violation of his parole because he did not have permission to be traveling in that area. Crawford was arrested upon a warrant issued for parole violations and then charged with criminal possession of dangerous drugs. A jury found him guilty. Thereafter, Crawford filed this action in state court against Couture, the Flathead Tribal Police Department, and the Confederated Salish Kootenai Tribal Government alleging numerous claims due to inappropriate conduct by Couture. The district court dismissed Crawford’s claims based on lack of subject matter jurisdiction and the sovereign immunity of the Tribe. The Supreme Court affirmed, holding that the district court properly dismissed Crawford’s claims based on lack of subject matter jurisdiction and sovereign immunity. View "Crawford v. Couture" on Justia Law

This case related to circumstances surrounding a data entry error that resulted in a significant sum of money being deposited into the wrong bank account. Grizzly Security Armored Express (Grizzly Security) filed suit against Bancard Services (Bancard) and B&B Lounge and Leland Ruzicka (collectively, Ruzicka). The district court concluded that the claim against Ruzicka was time-barred under the pertinent statute of limitations and that the claims against Bancard failed for various reasons. The court further awarded attorney’s fees to Bancard. The Supreme Court affirmed, holding that the district court (1) did not err in granting summary judgment in favor of Ruzicka; (2) did not err in granting summary judgment in favor of Bancard; and (3) did not err in awarding attorney’s fees to Bancard under the terms of a contract between the parties. View "Grizzly Security Armored Express, Inc. v. Bancard Services, Inc." on Justia Law

Peter Lee and three other passengers were injured in a single vehicle accident. The driver held an insurance policy issued by USAA Casualty Insurance Company and United States Automobile Association (collectively, USAA), and all of the passengers were covered by TRICARE. TRICARE paid medical benefits for the passengers and asserted medical payment liens for the passengers’ combined medical expenses. Lee made a settlement demand on USAA for Perez’s $100,000 policy limits. USAA offered to pay the policy limits provided that Lee first secure lien releases from TRICARE. TRICARE eventually waived its liens, and USAA issued a check for the policy limits of $100,000. Lee continued his suit against Perez after receiving the policy limits payment from USAA. Perez agreed to a consent judgment and assigned his claims against USAA to Lee. Elizabeth West, acting as guardian ad litem for Lee, filed suit asserting that USAA acted in bad faith by conditioning payment on resolving the TRICARE liens. The district court granted summary judgment for West, holding USAA liable to Lee for the consent judgment. The Supreme Court reversed, holding that USAA’s grounds for conditioning its payment of policy limits upon resolution of the TRICARE liens were reasonable under existing law, and therefore, USAA was entitled to judgment as a matter of law. View "West v. United Services Automobile Ass’n" on Justia Law

James Raulston started a fire while cutting scrap metal on Bernice McPhillips’ property. The fire spread, burning several structures and a variety of equipment on Gabriel Pearson’s property. Pearson filed a complaint against Raulston and McPhillips, alleging that Raulston was acting as an agent, servant, or employee of McPhillips when he started the fire. The district court granted summary judgment to McPhillips, concluding that McPhillips was not vicariously liable for Raulston’s actions. The Supreme Court affirmed, holding that the district court did not err (1) in finding that McPhillips and Raulston were not engaged in a joint venture, and (2) in finding that Raulston’s use of a cutting torch was not an inherently dangerous activity. View "Pearson v. McPhillips" on Justia Law

Jason Talbot was seriously injured in Montana when he was struck by a vehicle driven by an employee of WMK-Davis, LLC. At the time of the accident, Talbot was employed by Cudd Pressure Control, Inc. Talbot, who was a resident of Oklahoma, filed a workers’ compensation claim in Oklahoma. Talbot then filed a complaint in Yellowstone County against WMK-Davis’s employee. Cudd, in turn, successfully moved to intervene in order to assert a workers’ compensation subrogation lien against Talbot’s potential tort recovery. Such an action is allowable under Oklahoma law, but Oklahoma law directly conflicts with Montana’s rule that a party may not subrogate until the injured worker has been whole. The district court granted summary judgment in favor of Talbot, concluding that Montana applied and Cudd was prohibited from asserting a workers’ compensation subrogation lien in the underlying action. The Supreme Court affirmed, holding (1) the district court did not err in determining that Montana courts will not conduct a choice of law analysis when determining the validity of a workers’ compensation subrogation lien; and (2) because the Montana Constitution applies in this case, and Cudd stipulated that Talbot will not be made whole under Montana law, Talbot was entitled to summary judgment as a matter of law. View "Talbot v. Cudd" on Justia Law

In 1991, Appellant was convicted of two counts of deliberate homicide and sentenced to life imprisonment. Attorney James Goetz attempted to help Appellant with his parole eligibility claim. Displeased with Goetz's assistance, Appellant filed a complaint against Goetz. Appellant was assisted by attorneys Allan Baris and Todd Stubbs in this action. In 2010, Appellant filed a complaint against Goetz, Baris, and Stubbs, asserting claims related to the alleged withholding of discovery in Appellant’s previous action against Goetz. The district court granted Defendants’ motion for summary judgment without a hearing. The Supreme Court affirmed, holding that the district court did not abuse its discretion (1) by denying Appellant’s motion for a summary judgment hearing; and (2) by denying Appellant’s motion to stay judgment pending completion of discovery.View "Miller v. Goetz" on Justia Law

This controversy arose from cyber-blog exchanges between Plaintiff and Defendant. Plaintiff requested and was granted a temporary order of protection (TOP) against Defendant. The district court affirmed the municipal court’s order granting the TOP, extended the TOP, and sanctioned Defendant as a vexatious litigant through imposing a pre-filing order. The Supreme Court affirmed but struck one condition of the district court’s order, holding that the district court (1) not abuse its discretion in affirming the TOP and remanding to the municipal court for further proceedings; (2) did not err by permanently enjoining Defendant from filing any new pleadings without prior district court approval; but (3) abused its discretion in requiring Defendant to post a $50,000 bond in the event Defendant filed an action or proceeding against a judge or court employee.View "Boushie v. Windsor" on Justia Law

Plaintiff and Defendant entered into a buy-sell agreement for the purchase of Plaintiff’s home. As agreed upon, Defendant moved into Plaintiff’s home and began paying rent. Before the closing date, however, Defendant notified Plaintiff that he had decided not to purchase the property and had vacated the premises. Plaintiff sued Defendant, alleging constructive fraud, deceit, and negligence. The district court dismissed Plaintiff’s tort claims on the ground that they arose strictly out of a breach of contract. The Supreme Court affirmed in part and reversed in part, holding (1) summary judgment was appropriate on Plaintiff’s constructive fraud and deceit claims; but (2) the district court erred in dismissing Plaintiff’s negligence claim on the ground it arose solely out of duties imposed under the agreement. Remanded.View "Dewey v. Stringer" on Justia Law

In 2009, Plaintiff’s floral shop was destroyed by a fire. State Farm Casualty Insurance Company, with whom Plaintiff had an insurance policy for her business, paid Plaintiff the maximum amount available under her policy, which was approximately $21,105. Plaintiff filed suit against State Farm and insurance agent Shawn Ori, alleging that Ori, acting as State Farm’s agent, had a professional duty to ascertain or advise her of the adequate amount of coverage for her business and that his failure to do so constituted professional negligence. State Farm and Ori jointly moved for summary judgment on the ground that Plaintiff failed to name an expert witness to establish the standard of care applicable to an insurance agent. The district court granted summary judgment in favor of Defendants, concluding that expert testimony was required to establish the standard of care to which Ori was required to conform. The Supreme Court affirmed, holding that Plaintiff’s failure to obtain an expert witness resulted in an insufficiency of proof regarding duty and thus prevented Plaintiff from establishing a prima facie claim of negligence. View "Dulaney v. State Farm Fire & Cas. Ins. Co." on Justia Law