Justia Labor & Employment Law Opinion Summaries

Plaintiff suffered an injury in the course and scope of her employment with Employer. Employer's insurer (Insurer) accepted liability for Plaintiff's injury and paid wage loss and medical benefits. Plaintiff was later informed that Insurer would no longer approve or cover the expense of the pain patches she had been using for several years. Plaintiff filed a petition for expedited declaratory relief to reinstate medical benefits, seeking reinstatement of medical benefits for the pain patches as well as attorneys' fees and penalties. The Workers Compensation Court (WCC) determined that Plaintiff was entitled to continued payment of benefits for the pain patches but denied Plaintiff's request for attorneys' fees and for payment of the statutory penalty. The Supreme Court affirmed, holding that the WCC did not err (1) in determining Plaintiff was entitled to continued payment for the pain patches; (2) in determining Plaintiff was not entitled to reimbursement for her attorneys' fees; and (3) when it failed to impose the statutory penalty on Insurer. View "Stewart v. Liberty Northwest Ins. Corp." on Justia Law

After Employee failed to ask a shopper for a loyalty card per Employer's policy, Employee was fired. Employee brought a wrongful discharge claim against Employer under Montana's Wrongful Discharge From Employment Act (WDEA). Employee accepted Employer's offer to arbitrate the dispute because she said Mont. Code Ann. 39-915 would force her to pay Employer's attorney fees if she declined the offer and later lost at trial. Employee then successfully moved to amend her complaint to add destruction of evidence and declaratory judgment claims, alleging, inter alia, that section 39-2-915 was unconstitutional. The district court subsequently dismissed Employee's amended complaint, concluding that it had lost jurisdiction over Employee's claim once she accepted the offer to arbitrate. The court also ruled that 39-2-915 was constitutional. The Supreme Court (1) affirmed the dismissal of Employee's amended complaint, as the court lost its ability to consider Employee's claim once she agreed to arbitration; and (2) set aside the district court's determination of Employee's constitutional claim, as the court lost its authority to act further once Employee agreed to arbitrate. View "Ensey v. Mini Mart, Inc." on Justia Law

Plaintiffs were employed as by the Town of West Yellowstone. Plaintiff contended that the Town's on-call policy for police officers prior to 2009 was so restrictive that they could not engage in personal activities between shifts, and therefore, they should have been compensated for all their time spent on call, and not just for call outs, under the Fair Labor Standards Act (FLSA). After a jury trial, the trial court entered judgment in favor of the Town. The Supreme Court affirmed, holding that there was sufficient evidence to support the jury's verdict in favor of the Town, and Plaintiffs failed to show that the jury's verdict was either inherently impossible to believe or that there was a complete absence of evidence in support of the verdict. View "Stubblefield v. Town of W. Yellowstone" on Justia Law

Plaintiff worked as the manager of Defendant's automotive services and repair facility for more than one year. During his tenure, Plaintiff worked 819 hours in overtime but did not receive overtime pay under his employment contract. After Plaintiff resigned his employment, he filed a claim for overtime pay with the Department of Labor and Industry. The Department denied the claim. The district court affirmed. The Supreme Court affirmed, holding that the district court (1) did not err by concluding that Defendant did not waive its argument that Plaintiff was exempt from overtime pay as a "salesman" under 29 U.S.C. 213(b)(10); and (2) did not err by concluding that Plaintiff was not entitled to overtime pay under the Fair Labor Standards Act and the Montana Wage Protection Act. View "Thompson v. J.C. Billion, Inc." on Justia Law

Plaintiff was employed by the Department of Corrections (DOC) as a correctional officer at the Montana State Prison. After a taser training was held at the DOC Center, Plaintiff filed a complaint against the State, the DOC, and several fictitious defendants (collectively, Defendants), alleging that he suffered an intentional infliction of personal injury by his fellow employee when he was tased at the training. Plaintiff also raised a spoliation of evidence claim for the alleged loss or destruction of the DOC's video recording of the training session. The district court granted Defendants' motion for summary judgment. The Supreme Court affirmed, holding that the district court did not err in determining (1) the Workers' Compensation Act was the exclusive remedy for Defendant's injuries; and (2) there was no independent cause of action for Defendant's spoliation of evidence claim. View "Harris v. State" on Justia Law

Plaintiff The Big Sky Colony, Inc., a signatory to the Hutterian Brethren Church Constitution, organized itself as a religious corporation under Montana law. Plaintiff Daniel Wipf was the Colony's first minister and corporate president. Plaintiffs brought suit against the Montana Department of Labor and Industry, claiming that the requirement to provide workers' compensation coverage for the Colony's members engaged in certain commercial activities contained in HB 119 violated the Colony's rights under the Free Exercise Clause and the Establishment Clause and also violated the Colony's right to equal protection. The district court found in favor of the Colony. The Supreme Court reversed, holding that the provisions of HB 119 that incorporated the Colony into the definition of "employer" and the Colony's members into the definition of "employee" under the Workers' Compensation Act did not violate the Free Exercise Clause, the Establishment Clause, or the Colony's right to equal protection of the laws. View "Big Sky Colony, Inc. v. Dep't of Labor & Indus." on Justia Law

Blue Cross and Blue Shield of Montana (BCBS) signed an employment agreement with Plaintiff containing a clause to compel arbitration for any disputes regarding the employment agreement. After Plaintiff's employment was terminated, Plaintiff brought an action against BCBS claiming that BCBS violated the Wrongful Discharge from Employment Act (WDEA). Plaintiff, however, could bring a WDEA claim only if she did not have a written contract of employment for a specific term. The district court compelled arbitration to allow the arbitrator to determine in the first instance whether Plaintiff had a term employment contract. The Supreme Court affirmed the district court's order to compel arbitration, holding that because the instant dispute implicated the terms or provisions of the employment agreement, the district court correctly determined that an arbitrator should decide, in the first instance, whether Plaintiff was an at-will employee or whether she had a term contract. View "Marsden v. Blue Cross & Blue Shield of Mont., Inc." on Justia Law

Plaintiff gave birth to Child at Hospital. Complications arose prior to and after Child's delivery, leading to problems with Child's brain development. Plaintiff, individually and on behalf of Child, later sued the doctor who delivered Child and Hospital. Plaintiff subsequently settled her claims with the doctor. The district court granted summary judgment to Hospital on all of Plaintiff's claims. This appeal arose out of pre-trial rulings made by the district court in Plaintiff's litigation with Hospital. The Supreme Court affirmed, holding that the district court did not err in (1) extending discovery deadlines; (2) granting summary judgment to Hospital on Plaintiff's agency claims; (3) granting summary judgment to Hospital on Plaintiff's Consumer Protection Act Claim; (4) granting summary judgment to Hospital on Plaintiff's joint venture claim; and (5) granting summary judgment to Hospital on Plaintiff's negligent credentialing claim. View "Brookins v. Mote" on Justia Law

Employee was injured while working for Employer. Because Employer failed to retain current worker's compensation insurance, Employee filed a claim with the Uninsured Employer's Fund, which the Fund accepted. The Fund sought indemnity from Employer for Employee's damages, and the parties agreed to an interim payment plan. However, the Fund ultimately turned Employer over to collection. Employer responded by suing the Fund for breach of contract. The district court granted Employer's summary judgment motion on the issue of whether the Fund had breached the repayment agreement. The district court then awarded damages to Employer in the amount of $198,749. The damages awarded largely centered on the court's implicit conclusion that the Fund's actions had interfered with Employer's ability to obtain financing, which, in turn, hurt Employer's sales. The Supreme Court affirmed, holding that the district court properly (1) determined Employer was entitled to summary judgment on the question of whether the Fund had breached the payment plan agreement; (2) determined Employer could receive consequential damages for the Fund's breach of contract; (3) denied the Fund's motion for post-trial relief; (3) calculated damages; and (4) denied Employer's damage claim for ten years of lost profits. View "Elk Mountain Motor Sports, Inc. v. Dep't of Labor & Indus." on Justia Law

Plaintiffs were employees of Defendant Kalispell Regional Medical Center (KRMC). Defendant Northwest Healthcare Corporation (NWHC) was the parent corporation of the remaining defendant entities. This case arose out of a dispute over the discontinuation of a sick leave buy-back program. Defendants appealed the order of the district court granting Plaintiffs' motion for class certification. The Supreme Court affirmed, holding (1) the district court properly determined that the named Plaintiffs had standing to bring claims against defendants they did not directly work for because the juridically linked Defendants were operating under a common scheme; and (2) the district court did not abuse its discretion in certifying the class under Mont. R. Civ. P. 23(a) and (b). View "Chipman v. Nw. Healthcare Corp." on Justia Law