Justia Labor & Employment Law Opinion Summaries

Articles Posted in Montana Supreme Court
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The Supreme Court affirmed the order of the district court dismissing Plaintiff's complaint for failure to state a claim, holding that the district court did not err in granting Defendants' motion to dismiss.Plaintiff was employed with Defendant for seven years until he was terminated for testing positive for THC in a random drug and alcohol urine analysis test. Plaintiff had been prescribed medical marijuana as treatment for his diagnosed PTSD and challenged his termination, alleging wrongful discharge from employment and employment discrimination and seeking a declaratory judgment that Mont. Code Ann. 50-46-320(4)(b) and (5)(b) were unconstitutional as applied to his case. The district court dismissed the claims, concluding that Plaintiff had failed to notify his supervisor that he had been using medical marijuana, as required the company's policy. The Supreme Court affirmed, holding that the failure to follow Defendants' policy constituted good cause for termination. View "Barthel v. Barretts" on Justia Law

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The Supreme Court affirmed the order of the district court granting summary judgment in favor of Western Montana Community Health Center (WMMHC) and dismissing Plaintiff's claim brought under the Wrongful Discharge from Employment Act (WDEA), Mont. Code Ann. 39-2-901 - 915, holding that the district court's grant of summary judgment was not an abuse of discretion.Specifically, the Supreme Court held (1) WMMHC satisfied its burden to demonstrate that it had legitimate business reasons constituting good cause for terminating Plaintiff as program manager; (2) Plaintiff failed to meet her burden of demonstrating that the reason for the termination was false or arbitrary; and (3) WMMHC met its burden of demonstrating that it did not violate the express provisions of its written personnel policies. View "Buckley v. Western Community Mental Health Center" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying BNSF Railway Company summary judgment and entering final judgment in favor of Robert Dannels, holding that the Federal Employers' Liability Act (FELA) does not preempt an injured railroad employee's state law bad faith claims.Dannels was employed by BNSF when he suffered a disabling back and spine injury. Dannels sued BNSF under FELA to recover damages, and the jury returned a verdict in Dannels' favor. Dannels subsequently filed claims for bad faith and punitive damages against BNSF. The district court entered final judgment against BNSF. The Supreme Court affirmed, holding that the district court properly determined that the FELA does not preempt a railroad worker's right to seek redress for all bad faith conduct in the adjustment of a claim. View "Dannels v. BNSF" on Justia Law

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The Supreme Court reversed the order of the district court dismissing Plaintiff's claim brought under the Wrongful Discharge from Employment Act (WDEA) as time-barred, holding that the district court erred by granting summary judgment in favor of the Department of Corrections (DOC).In granting summary judgment for the DOC, the district court held that since Plaintiff's grievance procedures took longer than 120 days from the date of her termination her claim was untimely. The Supreme Court reversed, holding (1) the limitation period on Plaintiff's WDEA claim was tolled from the time she commenced her grievance until the grievance procedures were exhausted; and (2) excluding the period during which the limitation period was tolled, Plaintiff timely filed her claim within the one-year statute of limitations. View "Shepherd v. State" on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the district court upholding a hearing officer's conclusion that Montana State University-North (MSU-N) retaliated against Dr. Randy Bachmeier for reporting and pursuing a claim of sexual harassment against his supervisor, holding that the district court erred in reinstating the hearing officer's first decision as the final agency decision in this matter.The hearing officer's original order concluded that Bachmeier failed to demonstrate that his supervisor sexually harassed him but that MSU-N retaliated against Bachmeier. The HRC rejected the hearing officer's conclusion that Bachmeier was discriminated against, upheld the hearing officer's retaliation conclusion, and remanded the case. The hearing officer issued a second decision concluding that Bachmeier had been sexually harassed. The Montana Human Rights Commission (HRC) then issued a final agency decision reducing the damages award for sexual harassment but leaving untouched the retaliation award. The district court voided the hearing officer's second decision and remanded with instructions to reinstate the hearing officer's first decision as the final agency decision. The Supreme Court reversed in part, holding that the district court (1) abused its discretion by concluding that the HRC did not have the authority to modify the hearing officer's first decision; and (2) correctly upheld the hearing officer's retaliation conclusion. View "Montana State University-Northern v. Bachmeier" on Justia Law

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The Supreme Court affirmed the ruling of the Workers' Compensation Court that Mont. Code Ann. 39-71-703(2) did not violate Appellant's right to equal protection by denying an impairment award to a worker with a Class 1 impairment who has suffered no wage loss, holding that the statute passes rational basis muster under the Equal Protection Clause of the Montana Constitution.Section 39-71-703(2) allows impairment awards for claimants without actual wage loss only if they have a Class 2 or higher impairment rating. Appellant, who was designated as Class 1 and was denied an impairment award, challenged the statute, arguing that it violated her constitutional right to equal protection because other workers with different injuries but the same whole-person impairment percentage would receive the award. The WCC denied the challenge. The Supreme Court affirmed, holding that the WCC did not err in its determination that section 39-71-703(2) did not violate the Equal Protection Clause. View "Hensley v. Montana State Fund" on Justia Law

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The Supreme Court affirmed the order of the district court denying Griz One Firefighting, LLC's petition for judicial review of a default order and determination by the Department of Labor and Industry Wage and Hour Division (DLI) and awarding Matthew Sean West $11,241 in back wages, penalties, costs, and attorney fees, holding that the district court did not err.Specifically, the Supreme Court held (1) the district court did not clearly err when it concluded that DLI notified Griz One of West's wage claim; (2) Griz One was not entitled to relief on its due process and jurisdictional arguments; (3) the district court was correct in concluding that Mont. R. Evid. 605 does not apply to a DLI compliance specialist; and (4) the district court's award of attorney fees and costs to West was reasonable and based on competent evidence. The Supreme Court remanded the matter to the district court for a determination of West's costs and fees on appeal. View "Griz One Firefighting v. State Department of Labor & Industry" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the district court awarding $2,353,463 in damages to Junkermier, Clark, Campanella, Stevens, P.C. (JCCS), a Montana accounting firm, after a bench trial on remand, holding that the district court did not err by awarding prejudgment interest but erred with regards to the date interest began accruing.Appellants, five of six shareholders in JCCS' Bozeman office, were employed under the terms of an Employment Agreement that contained a covenant restricting competition (Covenant). Appellants later began working at a newly formed accounting firm and solicited clients from JCCS' Bozeman client list. JCCS filed a complaint against Appellants to declare the Covenant enforceable and to recover damages. On remand, the district court determined that the Covenant was reasonable, Appellants were jointly and severally liable for damages arising out of the Covenant's breach, and JCCS was entitled to prejudgment interest. The Supreme Court largely affirmed, holding that the district court did not err by (1) concluding that Appellants were jointly and severally liable for JCCS' damages; (2) concluding that the Covenant was reasonable; (3) awarding prejudgment interest but erred with regards to the date interest began accruing; and (4) by denying Appellants' motion for discovery sanctions. View "Junkermier, Clark, Campanella, Stevens, P.C. v. Alborn" on Justia Law

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The Supreme Court held that service is not required when the Montana Department of Labor and Industry, Employment Relations Division (DLI) files an application for enforcement of judgment when it seeks enforcement of a final agency decision in a wage claim action.DLI applied to the district court for enforcement of judgment against a Billings restaurant on behalf of Jordan Carillo for unpaid wages pursuant to Mont. Code Ann. 39-3-212(1). DLI did not serve the restaurant under Mont. R. Civ. P. 4. The district court concluded that the filing of an application for enforcement of judgment initiates as lawsuit that that due process requires service of process. DLI petitioned the Supreme Court for a writ of supervisory control. After considering DLI's petition as one of a declaratory judgment, the Supreme Court held (1) DLI need not follow Mont. R. Civ. P. 4 service of process requirements when applying for enforcement of judgment in Montana's district courts in wage claim matters pursuant to section 39-3-212(1); but (2) the statutes do not exempt DLI from compliance with Mont. R. Civ. P. 5. View "Montana Department of Labor & Industry v. Montana Thirteenth Judicial District Court" on Justia Law

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The Supreme Court affirmed the judgment of the district court dismissing Appellant's petition for judicial review for failure to exhaust Department of Fish, Wildlife and Parks (FWP) employee grievance remedies, holding that Appellant failed to exhaust administrative remedies.After Appellant, who worked for FWP, was reassigned to a different position, Appellant petitioned for judicial review. The district judge dismissed the petition with prejudice, determining that Appellant had not exhausted all available administrative remedies by filing a grievance regarding his reassignment. Appellant then filed a grievance, which was denied as untimely. Appellant did not file exceptions. Instead, Appellant filed a second petition for judicial review in the district court. The district court granted FWP's motion to dismiss, determining that it lacked subject matter jurisdiction over Appellant's petition based on his failure to exhaust administrative remedies. The Supreme Court affirmed, holding that the district court did not err in concluding that Appellant's failure to file exceptions barred his petition for judicial review. View "Flowers v. Board of Personnel Appeals, Montana Department of Fish, Wildlife & Parks" on Justia Law