Articles Posted in Montana Supreme Court

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The Supreme Court affirmed the order of the district court awarding summary judgment to the Missoula County Detention Facility and the Missoula County Sheriff’s Office (collectively, the County) on Plaintiff’s claim that the County had illegally discriminated against him based on his disability. Plaintiff initially filed a complaint with the Human Rights Bureau (HRB), which found no reasonable cause to believe that the County had discriminated against Plaintiff. The district court agreed. The Supreme Court Supreme Court affirmed, holding (1) the district court did not err in declining to consider evidence arising after Plaintiff filed his HRB complaint; and (2) the district court correctly granted summary judgment for the County. View "Borges v. Missoula County Sheriff’s Office" on Justia Law

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The Supreme Court affirmed the order of the district court awarding summary judgment to the Missoula County Detention Facility and the Missoula County Sheriff’s Office (collectively, the County) on Plaintiff’s claim that the County had illegally discriminated against him based on his disability. Plaintiff initially filed a complaint with the Human Rights Bureau (HRB), which found no reasonable cause to believe that the County had discriminated against Plaintiff. The district court agreed. The Supreme Court Supreme Court affirmed, holding (1) the district court did not err in declining to consider evidence arising after Plaintiff filed his HRB complaint; and (2) the district court correctly granted summary judgment for the County. View "Borges v. Missoula County Sheriff’s Office" on Justia Law

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Christita Moreau appealed a Workers’ Compensation Court (WCC) order denying her motion for summary judgment and granting summary judgment to Transportation Insurance Company. Moreau’s husband Edwin worked at the W.R. Grace mine near Libby. In 2009, he died from asbestos-related lung cancer. In 2010 Moreau, as personal representative of Edwin’s estate, filed a workers’ compensation claim for occupational disease benefits. Transportation Insurance Company (Transportation) was W.R. Grace’s workers’ compensation insurer, and it denied liability for the claim. Edwin’s employer, W.R. Grace, established and funded the Libby Medical Plan (LMP) to pay the medical expenses of its employees who were injured by exposure to asbestos. LMP paid approximately $95,000 of Edwin’s medical expenses. In 2012, as part of Grace’s bankruptcy, “certain rights and duties of the LMP” were transferred to the Libby Medical Plan Trust. Grace remained responsible for LMP’s “ongoing payment obligations” incurred before that time. In 2013, Transportation accepted liability for the workers’ compensation claim and entered a settlement with Moreau. Transportation agreed to reimburse Medicaid, other providers, and Moreau personally for medical expenses each had paid for Edwin’s care. The parties stipulated that Transportation paid all of Edwin’s medical bills or reimbursed the other persons or entities that had paid them. Transportation did not reimburse the LMP for the $95,846 of Edwin’s medical bills it had previously paid because the LMP refused to accept it. After the LMP refused to accept reimbursement from Transportation, Moreau demanded that Transportation pay the $95,000 either to Edwin’s Estate, to the LMP or its successor, or to a charity selected by the Estate. Transportation refused and Moreau filed a second petition with the WCC to resolve the issue. The WCC determined that all of Edwin’s medical care costs had been paid; that Edwin had no liability to any health care provider; and that he had no right to claim any further payment from Transportation. The WCC determined that if the Estate were to receive the $95,000 from Transportation it would represent a double recovery because Edwin had already received the medical benefits themselves. The Court concluded that Moreau therefore lacked standing to proceed Moreau’s petition. The WCC also found that Moreau’s attorneys also represented the LMP Trust “for purposes of recovering the disputed $95,846” for the LMP Trust. At the time of the WCC order, the LMP Trust was not a party to this action and had not advanced a claim in the WCC for reimbursement of the amount paid by its predecessor LMP. The WCC therefore granted summary judgment to Transportation. Finding no reversible error in that WCC decision, the Montana Supreme Court affirmed. View "Moreau v. Transportation Ins." on Justia Law

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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