Justia Montana Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the district court partially denying Appellant's motion for attorney fees, holding that the district court did not abuse its discretion in its determination of whether attorney fees awarded to class counsel were reasonable.Appellant filed individual and class action claims against Montana University System (MUS). The parties reached a partial settlement. The district court approved the settlement and appointed Appellant the class representative and her attorneys as class counsel. The court's order provided that class counsel were entitled to attorneys' fees and costs, but the parties were unable to agree to a total attorney fees and costs award. The district court declined to award class counsel their requested fees under a percentage-based calculation and, instead, calculated the fee award by multiplying the hours worked on the case by hourly rates of $275 and $375, respectively. The Supreme Court affirmed but remanded the case for a determination of the interest to which Appellant was entitled, holding (1) the district court did not abuse its discretion in determining whether the attorney fees awarded to class counsel were reasonable; and (2) Appellant was entitled to interest in accordance with Mont. Code Ann. 25-9-205. View "Gendron v. Montana University System" on Justia Law

The Supreme Court reversed the order of the district court declining to dismiss Plaintiff's wrongful discharge claim, holding that Plaintiff failed timely to file his complaint in the district court within the applicable statute of limitations.Plaintiff filed a claim against the City of Dillon and the Dillon Mayor (collectively, Defendants) alleging violation of the Wrongful Discharge of Employment Act (WDEA), Mont. Code Ann. 39-2-905. The City moved to dismiss the complaint on the grounds that Plaintiff's claims were barred by the statute of limitations. The district court denied the claim. The City then sought dismissal of the action as time barred by a way of summary judgment, which the district court denied. The jury ultimately found that Plaintiff was discharged without good cause and awarded damages of $75,612. The Supreme Court reversed, holding that Plaintiff failed to timely file his complaint within the one-year limitation period, as required by the WDEA. View "Turner v. City of Dillon" on Justia Law

The Supreme Court affirmed in part and reversed in part the findings of the Water Court in adjudicating two of Twin Creeks's water rights claims, holding that the Water court did not err in finding that Twin Creeks abandoned one claim by nonuse but misapprehended the effect of testimony regarding the second claim's historical use.Five Twin Creeks claims were at issue before the Water Court. After a hearing, the Water Court issued a closing order ordering changes to four of the claims and removing the issue remarks. At issue on appeal were the statements of claim 40B109102-00 (the 102 claim) and 40B109104-00 (the 104 claim). The Supreme Court held (1) the Water Court did not err in finding that the 102 claim was abandoned by nonuse because the intent to abandon occurred concurrently with the nonuse; and (2) the Water Court erred finding that Petrolia Irrigation District did not overcome the presumption that the 104 claim was correct as filed. View "Twin Creeks Farm & Ranch v. Petrolia Irrigation District" on Justia Law

The Supreme Court affirmed the judgment of the district court finding Defendant guilty of one count of partner or family member assault and one count of deliberate homicide, holding that the court erred in admitting some of the deceased victim's out-of-court statements, but the error was harmless.Specifically, the Supreme Court held (1) the district court did not abuse its discretion in denying Defendant's motion to sever the counts; (2) the district court did not abuse its discretion when it excluded evidence of the victim's drug use and denied Defendant's motion for a new trial; (3) the district court abused its discretion in admitting the victim's out-of-court statements as evidence of her state of mind, but the error was harmless; and (4) there were no grounds to apply the doctrine of cumulative error in this case. View "State v. Gomez" on Justia Law

The Supreme Court reversed the judgment of the district court granting summary judgment to the City of Billing on Appellant's claims that the City was vicariously liable for the tortious acts of former City employee Michael Glancy, holding that the district court erred in concluding as a matter of law that Glancy was not acting within the scope of his employment.After Appellant brought his lawsuit the City filed a motion for summary judgment on the asserted ground that Glancy engaged in the alleged tortious conduct outside the scope of his employment. The district court granted summary judgment for the City. The Supreme Court reversed, holding that genuine issues of material fact precluded summary judgment as to whether Glancy's conduct were incidental to implicitly authorized conduct and thus within the scope of his employment. View "Brenden v. City of Billings" on Justia Law

The Supreme Court affirmed the order of the district court involuntarily committing Appellant to the Montana State Hospital (MSH) for a period not to exceed ninety days, holding that there was sufficient evidence to support the court's finding that Appellant was substantially unable to provide for her own basic needs.After a hearing, the district court issued its findings that Appellant suffered from a serious mental illness requiring commitment because she represented a danger to herself and because she was unable to care for her own basic needs. The court concluded that commitment to MSH was the least restrictive alternative necessary to protect Appellant and to effectively treat her mental disorder. The Supreme Court affirmed, holding that sufficient facts supported the district court's finding that Appellant required commitment to MSH. View "In re Mental Health of W.K." on Justia Law

The Supreme Court affirmed the judgment of the district court determining that Defendant, a chiropractor, was not negligent in his care of Plaintiff, holding that the district court did not abuse its discretion in any of the rulings challenged by Plaintiff.Plaintiff brought this action alleging that Defendant herniated her cervical disc, did not treat her consistent with the standard of care required by a chiropractor in Montana, and was negligent in his examination and treatment of her. After denying both parties' motions for partial summary judgment a trial was held. The jury returned a special verdict finding Defendant was not negligent in his care of Plaintiff. The Supreme Court affirmed, holding (1) the district court did not err in determining that there was disputed issues of material fact as to the chiropractic standard of care and whether Defendant departed from that standard of care; (2) the court did not abuse its discretion in admitting evidence of Defendant's habits and routine practices when treating patients; (3) the district court did not err in admitting Defendant's perpetuated expert testimony; and (4) any error in admitting alternative cause evidence or allowing Plaintiff to be impeached with her attorney's application to the Montana Chiropractic Legal Panel was harmless. View "Howlett v. Chiropractic Center, P.C." on Justia Law

The Supreme Court allowed hundreds of former employees of W.R. Grace & Company's Zonolite Division in Libby (Grace) to continue their asbestos-related personal injury claims against Maryland Casualty Company (MCC), Grace's former workers' compensation insurance provider, holding that MCC owed Grace workers a direct common law duty under Restatement (Second) of Torts 324A(b)-(c) to use reasonable care under the circumstances to warn them of the known risk of exposure to airborne asbestos in certain Grace workplaces.The Supreme Court assumed supervisory control over proceedings pending before the Montana Asbestos Claims Court. Here the Court addressed on extraordinary review MCC's assertion that the district court erred in concluding that MCC owed a duty of care to warn third-party employees of Grace of a known risk of airborne asbestos exposure in or about Grace facilities in and about Libby, Montana between 1963 and 1970. The Supreme Court held that, based on MCC's affirmative assumption of employee-specific medical monitoring and Grace's reliance on MCC to perform that function, MCC owed Grace workers a legal duty to use reasonable care to warn them of the risk of airborne asbestos. View "Maryland Casualty Co. v. Asbestos Claims Court" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the district court denying Appellant's application for temporary restraining order and preliminary injunction, ruling that holding individuals pursuant to a federal civil immigration detainer request is an arrest under Montana law and that a detainer request is not an arrest warrant and does not compel the re-arrest of a person otherwise entitled to release.Plaintiff was arrested and booked into county jail. When Plaintiff attempted to post his bond, the U.S. Customs and Border Protection (Border Patrol) sent the jail a civil immigration detainer request under the Immigration and Nationality Act and informed the bond company that the sheriff would continue to detain Plaintiff. Consequently, Plaintiff's bondsman declined to post his bond, and Plaintiff was not released. Plaintiff filed a complaint alleging that the sheriff violated Montana law in honoring the Border Patrol's request. The district court ruled against Plaintiff. The Supreme Court reversed in part, holding that Plaintiff's continued detention for a new purpose when he was otherwise entitled to release was an arrest under Montana law, and the sheriff lacked state arrest authority to detain Plaintiff on the basis of his potential removal under federal immigration law. View "Ramon v. Short" on Justia Law

The Supreme Court affirmed the order of the district court terminating Mother's parental rights to her son, holding that the district court did not err in terminating Mother's parental rights.In terminating Mother's parental rights, the district court concluded that Mother's conduct was unlikely to change within a reasonable time and found that termination of Mother's parental rights, rather than a guardianship, was in the best interests of the child. The Supreme Court affirmed, holding that the district court (1) did not err when it determine that Mother's condition or conduct rendering her unfit to parent was unlikely to change within a reasonable time; and (2) did not abuse its discretion when it determined that termination was in the child's best interests and that Mother did not overcome the presumption in favor of termination. View "In re A.B." on Justia Law