Justia Montana Supreme Court Opinion Summaries

JEM Contracting, Inc. (JEM) and Ohio Farmers Insurance Company (OFIC) executed two indemnity agreements so that JEM could obtain bonding from OFIC for construction projects. Thereafter, OFIC executed and delivered two surety bonds on behalf of JEM for two construction projects. JEM hired a subcontractor, Hollow Contracting (Hollow), to furnish labor and equipment for both projects. After a dispute arose between JEM and Hollow regarding payment for the work performed, Hollow filed a complaint against JEM and OFIC. The lawsuit was resolved, and the district court dismissed the litigation. Thereafter, OFIC filed a complaint seeking indemnification from JEM for attorney fees and costs incurred in the underlying litigation. In its answer, JEM alleged that the fees and costs OFIC incurred in the litigation were not covered under the indemnity agreements. The district court granted partial summary judgment on the pleadings in favor of OFIC, concluding that JEM was required to indemnify OFIC for “appropriate expenses.” The Supreme Court affirmed, holding that the district court did not err in granting partial summary judgment on the pleadings to OFIC on the limited issue of whether OFIC may seek indemnification from JEF pursuant to the indemnification agreements. View "Ohio Farmers Insurance Co. v. JEM Contracting, Inc." 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

Child was adjudicated a youth in need of care. Temporary legal custody was granted to the Department of Public Health and Human Services, Child and Family Services Division, and Child was placed with Jared and Cindy Watson. Patrick and Corinne Gilbert, who had custody of two of Child’s biological half-siblings, intervened in the case. The district court subsequently terminated Mother’s and any and all putative fathers’ parental rights and granted permanent legal custody to the Department. After a placement hearing, the district court concluded that it was in Child’s best interests to remain in her current placement with the Watsons for adoption. The Gilberts appealed. The Supreme Court affirmed, holding that the district court did not err approving the Department’s placement of Child with the Watsons. View "In re B.W.S." 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

The parties in this case disagreed over the ownership and operation of an irrigation system on a ranch. Plaintiff filed a complaint against Defendants, arguing that Defendants had converted his property by exercising unauthorized dominion or control over the irrigation system, that Defendants had been unjustly enriched through their possession of the irrigation system, and that Defendants had caused him damages. Defendants filed counterclaims against Welu, alleging trespass and breach of contract. The district court entered judgment in favor of Defendants. The Supreme Court affirmed, holding that the district court did not err in (1) determining that the entire pivot irrigation system constituted a fixture; (2) concluding that Defendants did not breach the parties’ agreement concerning the pivot irrigation system; and (3) did not err in determining that Defendants were not unjustly enriched. View "Welu v. Twin Hearts Smiling Horses, Inc." on Justia Law

At issue in this case was two oral contracts entered into between Ryffel Family Partnership, Ltd. (Ryffel Partnership) and Alpine Construction (Alpine). The first agreement was entered into in January 2007, and the second agreement was entered into in September 2007. Ryffel Partnership filed suit against Alpine. The jury found that Ryffel Partnership had breached both oral contracts but that Alpine should be awarded no damages for either breach. The jury further found that Ryffel Partnerhsip had been unjustly enriched by Alpine’s labor and awarded Alpine $50,348 in damages. The jury also found that Ryffel Partnership had breached the implied covenant of good faith and fair dealing and awarded $25,000 to Alpine. The district court amended the judgment to assign the jury’s damages award for unjust enrichment to its finding that Ryffel Partnership breached its contract. The court also struck the jury’s award for breach of the covenant of good faith and fair dealing. The Supreme Court affirmed, holding (1) the jury’s verdict was supported by substantial evidence; (2) the district court did not err in denying Ryffel Partnership’s motion for a new trial based on an inconsistent or illegal jury verdict; and (3) the district court did not err in denying Alpine’s motion for prejudgment interest. View "Ryffel Family Partnership Ltd. v. Alpine Country Construction, Inc." on Justia Law

Appellants attempted to execute judgments obtained against Robert Fitte in their respective underlying lawsuits by attaching the proceeds of a commercial liability policy issued to Fitte by joined party Mountain West Farm Bureau Mutual Insurance Company (Mountain West). In a separate declaratory proceeding, a federal court determined that the commercial policy covered Fitte’s actions. Thereafter, Mountain West filed a motion to deposit the proceeds of the commercial policy into an existing interpleader action. The underlying proceedings filed by Appellants were consolidated. The district court granted summary judgment to Fitte and Mountain West, concluding that Appellants were not entitled to execute judgments secured outside the pending interpleader action and attach the proceeds of the commercial policy. The Supreme Court affirmed, holding (1) the district court did not err in concluding that the proceeds from the commercial policy must be distributed through the interpleader; and (2) deposit of the commercial policy proceeds was not required at the time of the interpleader proceeding to establish the interpleader court’s jurisdiction. View "Associated Dermatology & Skin Cancer Clinic of Helena, P.C. Profit Sharing & Trust Benefit of Stephen D. Behlmer, M.D. v. Fitte" on Justia Law

In Montana’s ongoing water rights claims adjudication proceedings, the Bureau of Land Management (BLM) filed six water right claims related to one natural pothole and five reservoirs. The water sources were located wholly or partially on federal land. The BLM claimed the right to use each source for stock watering by its grazing permittees and for wildlife. Certain objectors (Objectors) raised objections to each claim, arguing that the BLM did not perfect any water rights. The Water Master recommended summary judgment in favor of the BLM on each claim. The Water Court granted partial summary judgment to the BLM and remanded a portion of the pothole claim to the Master for further proceedings. The Supreme Court affirmed, holding (1) the Water Court correctly found that the BLM properly perfected state law water rights in the reservoirs; and (2) The Water Court did not err in granting partial summary judgment on the pothole claim. View "Bureau of Land Management - Barthelmess" on Justia Law

623 Partners, LLC obtained a judgment against R. Larry Hunter and Larry Hunter Development Co. (collectively Larry). In its effort to satisfy the judgment, 623 Partners alleged that properly originally owned by Hunter Development was fraudulently transferred to Larry Todd Hunter, Larry’s son. The district court concluded that the properly was fraudulently transferred in order to avoid subjecting the property to 623 Partners’ writ of attachment and that Todd was liable to 623 Partners for the proceeds he received from the sale of a parcel of the property. The Supreme Court affirmed. On remand, Todd argued that he was entitled to an offset from the judgment amount based on the value of the improvements that he made to the property and that the property was exempt from execution or forced sale because he had claimed it as his homestead. The district court rejected Todd’s assertions. The Supreme Court affirmed, holding that the district court did not err in determining that Todd was not entitled to an offset and correctly concluded that Todd did not qualify for a homestead exemption. View "623 Partners, LLC v. Hunter" on Justia Law

Defendant was charged with his fifth Partner Family Member Assault (PFMA) felony for conduct occurring in 2014. The State filed a notice to classify Defendant as a persistent felony offender (PFO) based on two previous PFMA convictions. Pursuant to a plea agreement, Defendant pleaded guilty to a PFMA, a felony, and the State withdrew the PFO notice. Defendant subsequently filed a brief challenging his prior convictions and the constitutionality of Montana’s PFMA statute. The Supreme Court affirmed, holding that Defendant waived his right to appeal the constitutionality of the prior PFMA statute. View "State v. Watts" on Justia Law