Justia Montana Supreme Court Opinion Summaries

Employee was fired by employer after allegations that Employee had a sexual relationship with a co-worker. Employee was found eligible to receive unemployment benefits. The Board of Labor Appeals affirmed. Employee subsequently filed this suit, alleging that Employer discharged him in violation of the Wrongful Discharge From Employment Act. After a trial, the jury found Employer did not wrongfully terminate Employee. The Supreme Court affirmed, holding that the district court did not err in (1) failing to grant summary judgment to Employee on liability and allowing Employer to proceed to trial on the question of whether it had good cause to discharge Employee; (2) failing to sanction Employer for discovery abuse and destruction of evidence; (3) denying Employee's motion to amend the pleadings to add a claim for punitive damages; (4) allowing Employer's expert witness to testify, as she did not testify as to ultimate issues of fact and law; and (5) allowing witnesses to testify to rumors heard at the workplace about Employee. View "Cartwright v. Scheels All Sports, Inc." on Justia Law

Defendant was charged with felony DUI and two misdemeanors. Defendant filed a motion to dismiss the charges on speedy trial grounds. The district court denied the motion. Defendant subsequently pleaded guilty to DUI pursuant to a plea agreement with the State in which the State agreed to drop the misdemeanor charges. Thereafter, Defendant appealed the district court's denial of his motion to dismiss. The Supreme Court affirmed, holding that the district court correctly found the State did not violate Defendant's right to a speedy trial where (1) Defendant's delay exceeded the 200-day trigger for a speedy trial analysis; but (2) the State's institutional delay did not prejudice Defendant. View "State v. Steigelman" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to felony DUI. Defendant appealed, arguing that the district court erred in denying his motion to dismiss the charge based on an alleged violation of his speedy trial rights. The Supreme Court affirmed the conviction, holding (1) Defendant suffered substantial pretrial delay largely attributed to the State's institutional delay in bringing him to trial, but Defendant failed to demonstrate that the delay caused undue prolonged disruption of his life or aggravated his anxiety beyond the expected level; and (2) Defendant failed to demonstrate that this delay substantially prejudiced his ability to defend against the charges. View "State v. Steigelman" on Justia Law

A trust (Trust) purchased lots in an RV park. The purchase agreement for the lots granted Trust an easement for access to a lake over and across lakefront property. At the time of the purchase, the lake property was encumbered by a deed of trust issued by Bank. After the owners of the lake property became delinquent on their loan obligations, Bank attempted to foreclose on the lake property by way of a trustee's sale, at which it purchased the property. Because Bank failed to provide Trust with notice of the sale, Bank subsequently noticed a second trustee's sale of the lake property, this time providing notice to Trust. Trust filed a complaint against Bank, claiming the Bank was precluded from holding the second sale and that it therefore could not extinguish its easement via the second sale. Bank subsequently purchased the property at the second trustees sale. The district court concluded (1) the first trustee's sale was invalid, but the second trustee's sale was valid; and (2) Trust's easement claims were therefore subordinate to Bank's interests in the lake property. The Supreme Court affirmed, holding that the district court correctly concluded that Bank effectively foreclosed on Trust's easement through the second trustee's sale. View "Terry L. Bell Generations Trust v. Flathead Bank of Bigfork" on Justia Law

Plaintiff purchased property from Defendants in 1993. The warranty deed for the property contained no express mention of water rights, ditch easements, or appurtenances. Plaintiff nevertheless believed that a water right came with the property and that a ditch easement existed to transport the water to his property. Defendants later purchased real property which historically contained a ditch. It was subsequently discovered the property did have a ditch that traversed from a creek, across Defendants' property, to a 20-acre "place of use" on the properly now owned by Plaintiff. Plaintiff subsequently attempted to reopen use of the ditch and filed an action against Defendants seeking a declaration that he had a ditch easement across Defendants' property. The district court ruled in favor of Defendants. The Supreme Court affirmed, holding that the district court properly determined that Plaintiff had no ditch easement across property owned by Defendants. View "Roland v. Davis" on Justia Law

Three individuals (collectively, "Pallister") were unnamed members in a class action suit against insurers Blue Cross and Blue Shield of Montana, Inc. (BCBSMT) and Montana Comprehensive Health Association (MCHA). The suit generally sought damages from the insurers for the companies' delayed payments of benefits and for benefits improperly withheld. BCBSMT, MCHA, and the named class members subsequently entered into a proposed settlement. Pallister objected to the settlement agreement and filed a motion to conduct discovery into the fairness of the proposed settlement. The district court denied the motion. The Supreme Court reversed and vacated the district court's approval of the settlement agreement. The Court remanded to the district court with instructions to allow discovery into the settlement negotiations. Pallister then filed a motion for substitution of the district court judge. The judge denied the motion. The Supreme Court affirmed, holding (1) Pallister was not a party for purposes of substitution; and (2) Mont. Code Ann. 1-804(12) did not provide for substitution on remand in this case. View "Pallister v. Blue Cross & Blue Shield of Mont., Inc." on Justia Law

After Sarah West was involved in a motor vehicle accident, West made a claim against her insurer, State Farm, for underinsured motorist benefits of $75,000. State Farm paid only $20,000 in benefits. Attorney Tracey Morin subsequently filed a complaint against State Farm on behalf of Sarah and her parents, Ausra and James West, for breach of contract, violation of the Montana Unfair Trade Practices Act, and breach of the implied covenant of good faith and fair dealing. At the conclusion of the action, the district court imposed sanctions on Morin individually under Mont. R. Civ. P. 11. Morin appealed, contending that the depth and breadth of the sanctions constituted an abuse of discretion. The Supreme Court affirmed, holding that the district court did not abuse its discretion in imposing the level of sanctions imposed in this case. View "Morin v. State Farm Mut. Auto. Ins. Co." on Justia Law

In 2012, Plaintiff sought and obtained a temporary order of protection against Defendant in a civil action. Subsequently, Plaintiff obtained a no contact order against Defendant in a criminal action. Defendant moved to have the civil action dismissed with prejudice as a discovery sanction. Plaintiff moved to have the civil action dismissed without prejudice in the event she needed a future civil order of protection. The district court granted Plaintiff's motion and dismissed the civil action without prejudice. The Supreme Court affirmed, holding (1) under the circumstances, it made sense to dismiss the action without prejudice so that, if necessary, Plaintiff could resurrect her action quickly; and (2) Defendant failed to establish that Plaintiff should be sanctioned with a dismissal of her proceeding with prejudice for her failure to appear for a deposition. View "Lear v. Jamrogowicz" on Justia Law

By decree of the district court, the marriage of Husband and Wife was dissolved. The decree also divided the marital estate. Husband appealed, challenging various aspects of the property division. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court (1) did not err in valuing the estate as of 2009 instead of 2002, when the parties separated; (2) did not err in its valuation of businesses owned or partly owned by Husband; (3) erred by failing to award Husband an offset credit for thousands of dollars paid to Wife between 2002 and 2009; and (4) erred by ordering that Husband pay $1.259 million equalization payment to Wife without providing a method of payment. Remanded for adoption of a reasonable payment plan for payment of the large equalization payment. View "Schwartz v. Harris" on Justia Law

After a jury trial, Defendant was found guilty of one count of deliberate homicide and one count of aggravated assault. The Supreme Court affirmed, holding (1) the district court did not err by excluding evidence of justifiable use of force as a defense to the charge of deliberate homicide; and (2) the Court declined to exercise plain error review of Defendant's claims that the district court erred by excluding evidence of the victim's prior mental health history, suicide attempts, and cutting behavior, and that this exclusion violated Defendant's Sixth Amendment right to compulsory process and confrontation and Fourteenth Amendment right to due process. View "State v. King" on Justia Law