Articles Posted in Montana Supreme Court

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The Supreme Court reversed the order of the district court granting Burlington Northern and Santa Fe Railway Company’s (BNSF) motion for summary judgment on Kelly Watson’s asbestos-related disease claim, brought under the Federal Employers’ Liability Act, holding that the bankruptcy court’s order enjoining claims against W.R. Grace and other “affiliated entities,” including BNSF, tolled the statute of limitations on Watson’s claim. Thus, the district court erred in concluding that the bankruptcy court’s order expanding a previous injunction barring the commencement or filing of new claims to include BNSF as a nondebtor affiliate did not bar the commencement of new actions against BNSF. View "Watson v. BNSF Railway Co." on Justia Law

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The Supreme Court affirmed the district court’s grant of summary judgment dismissing Plaintiff’s claims for wrongful discharge under the Montana Wrongful Discharge from Employment Act (WDEA). Plaintiff sued Defendant, his former employer, for damages for wrongful discharge under WDEA, asserting that Defendant lacked good cause to terminate his employment, failed to follow its written personnel policies, and terminated him for refusing to violate public policy or for reporting violations of public policy. The district court granted Defendant’s motion for summary judgment on all claims, concluding that Plaintiff did not have a wrongful discharge claim because he was a probationary employee who could be terminated for any reason as provided in Mont. Code Ann. 39-2-904(2). The Supreme Court affirmed, holding (1) the district court correctly found that Plaintiff was still on probation when Defendant terminated his employment; and (2) the district court properly granted summary judgment to Defendant on the whistleblower issue because Plaintiff failed to produce any evidence to support his contention. View "Dundas v. Winter Sports, Inc." on Justia Law

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The Supreme Court affirmed the district court’s decision affirming the decision by the Unemployment Insurance Appeals Board denying Joyce Crouse’s claim for unemployment benefits. The district court affirmed the Board’s conclusion that Crouse did not qualify for unemployment benefits because her voluntary termination did not constitute “good cause” pursuant to Mont. Code Ann. 39-51-2302. The Supreme Court agreed with the lower court, holding (1) the findings of the Board were supported by substantial evidence; and (2) the district court correctly affirmed the Board’s decision to deny Crouse’s claim for benefits because she voluntarily resigned her position. View "Crouse v. State, Department of Labor" on Justia Law

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The City appealed the district court's order and judgment holding that the City incorrectly paid "longevity" wage benefits under successfully negotiated collective bargaining agreements (CBAs) and awarding damages to Officers. The Montana Supreme Court held that the district court erred by concluding as a matter of law that the longevity provisions of the subject CBAs were unambiguous. In this case, the differing language of the successive CBAs were reasonably subject to more than one interpretation, and the blanket exclusion of all extrinsic evidence offered by the City—while selectively relying on other extrinsic evidence—was likewise erroneous. Accordingly, the court reversed and remanded for further proceedings. View "Watters v. Billings" on Justia Law

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The Supreme Court reversed the district court’s judgments ruling that the Montana Public Employees’ Association (MPEA) breached its duty of fair representation (DFR) to Jeffrey Folsom and engaged in common law fraud, awarding Folsom attorney fees as an element of compensatory damages on his DFR claim and awarding $50,000 in punitive damages on his common law fraud claim. The Supreme Court held (1) Folsom’s separately pled common law fraud claim is necessarily subsumed in his DFR claim and is thus not independently cognizable in this case; (2) the district court did not err in denying Folsom’s claim for compensatory lost wages and benefits on his DFR claim; (3) the district court erred in awarding fees to Folsom as an element of compensatory damages on his DFR claim; (4) the district court erred in awarding punitive damages without a compensatory damages predicate; and (5) the district court abused its discretion in refusing to grant MPEA’s motions for postjudgment relief from its summary judgment. View "Folsom v. Montana Public Employees’ Ass’n" on Justia Law

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After Plaintiff’s employment was terminated, he filed suit against Defendant alleging wrongful discharge, negligent infliction of emotional distress, and defamation. The district court granted Defendant’s motion to dismiss for lack of subject-matter jurisdiction, concluding that Ohio law governed or, alternatively, that Ohio was the appropriate forum to exercise jurisdiction. The Supreme Court vacated the district court’s dismissal, holding that Montana courts had subject-matter jurisdiction over Plaintiff’s claim, and remanded for further proceedings to consider whether dismissal under the doctrine of forum non conveniens was appropriate. On remand, the district court denied Plaintiff’s motion to amend the complaint and granted Defendant’s motion to dismiss under forum non conveniens. The Supreme Court affirmed, holding that the district court (1) did not act arbitrarily or exceed the bounds of reason in concluding that Plaintiff’s amendment would prejudice Defendant and that the amendment would run counter to the Supreme Court’s remand instructions in Harrington I; and (2) did not abuse its discretion by determining that resolution of Plaintiff’s claims in Ohio would promote the convenience of witnesses and the ends of justice. View "Harrington v. Energy West Inc." on Justia Law

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While employed by a company now known as Asurion Services, LLC, Christy Harris filed industrial injury claims for two different incidents. Lumbermens Mutual Casualty Company adjusted Harris’s workers’ compensation claims until it was declared insolvent. Montana Insurance Guaranty Association (MIGA) subsequently assumed the handling of Harris’s claims. Thereafter, MIGA notified Asurion that it would seek reimbursement for the benefits it paid to Harris pursuant to Mont. Code Ann. 33-10-114(2). Asurion filed a declaratory judgment action against MIGA. The district court granted motion for Asurion based on the exclusivity provision of the Montana Workers’ Compensation Act (Act), concluding that because Asurion met its obligation to obtain workers’ compensation insurance, it had no payment obligations to Harris, and therefore, Mont. Code Ann. 33-10-114(2) did not afford MIGA relief. The Supreme Court affirmed, holding that because Asurion provided workers’ compensation coverage in accordance with the Act, Asurion was not required to reimburse MIGA for benefits paid to Harris. View "Asurion Services, LLC v. Montana Insurance Guaranty Ass’n" on Justia Law

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Charlene Berdahl, a court reporter, filed a sexual harassment complaint against Judge George Huss, a district judge, with the Montana Human Rights Bureau (HRB). Huss’s attorney requested that the State agree to defend and indemnify Huss regarding Berdahl's HRB claims. Berdahl and Huss subsequently entered into a stipulated judgment resulting from the State’s refusal to defend and indemnify. The State filed this action seeking declarations that the State had no duty to defend or indemnify Huss against the claims and that Huss had entered a settlement without the consent of the State, which was unenforceable against the State. Berdahl counterclaimed seeking declarations that the State was responsible for the stipulated judgment entered by Berdahl and Huss and that the State was liable under the principle of respondent superior. The district court rejected Berdahl’s request for a declaration and held that the State owed no duty to defend or indemnify Huss. The court further reasoned that Berdahl’s exclusive remedy regarding her respondent superior claim was under the Montana Human Rights Act. The Supreme Court affirmed, holding that the district court did not err in concluding that the State bore no obligation to pay the stipulated settlement between Huss and Berdahl. View "State v. Berdahl" on Justia Law

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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

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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