Justia Labor & Employment Law Opinion Summaries

Plaintiff filed a petition for a hearing in the Montana Workers’ Compensation Court (WCC) asking the court to order Teck American, Inc. to continue to provide medical benefits for a knee injury he sustained while working for Teck. The WCC found that Plaintiff was entitled to medical benefits, that Plaintiff’s claim was not barred due to a superseding intervening cause, that Teck was equitably estopped from denying medical benefits on Plaintiff’s claim under Mont. Code Ann. 39-71-704(1)(d), and that Teck’s statute of limitations and statute of repose defenses were moot. The Supreme Court affirmed, holding (1) Plaintiff and Teck formed an enforceable contract when both parties agreed to close several of Plaintiff’s claims in exchange for a lump sum payment and lifetime health benefits for his knee and back injuries; and (2) the WCC did not err in concluding that Teck cannot deny medical benefits to Plaintiff on the basis of section 39-71-704(1)(d). View "Newlon v. Teck American, Inc." on Justia Law

After Jon Cruson resigned from his position with Missoula Electric Cooperative, Inc., he filed a claim for unemployment benefits with the Montana Department of Labor and Industry’s Unemployment Insurance Division (Department). The Department ultimately granted Cruson unemployment insurance benefits beginning on the date of his resignation. The Hearings Bureau reversed, concluding that Cruson was disqualified from receiving benefits because the reason he offered for quitting did not constitute good cause attributable to his employment. The Board of Labor Appeals affirmed. The district court denied Cruson’s appeal, determining that the Board correctly applied the law to the facts when it determined that Cruson did not voluntarily leave his employment with good cause attributable to his employer. The Supreme Court affirmed, holding that the Board’s factual findings were supported by substantial evidence, and its legal conclusion that “good cause attributable to the employer” had not been shown was correct. View "Cruson v. Missoula Elec. Coop." on Justia Law

Appellant was an officer with the Glacier County Sheriff’s Office (GCSO) from 1995 to 2010 and occasionally investigated the deaths of people he knew. In 2010, Appellant pled guilty to two misdemeanors and resigned from the GCSO. In 2011, Appellant applied for disability retirement benefits from the Sheriffs’ Retirement Systems, alleging that he was permanently disabled due the post-traumatic stress disorder (PTSD) he developed while working at the GCSO. The Montana Public Employees’ Retirement Board (PERB) denied Appellant’s disability claim, concluding that Appellant’s PTSD was not permanently disabling. The district court affirmed PERB’s decision to deny benefits. The Supreme Court affirmed, holding that the district court did not misapprehend the effect of the evidence presented and properly determined that the findings of PERB were not clearly erroneous. View "Fauque v. Mont. Pub. Employees Ret. Bd." on Justia Law

In two separate cases, Appellants were injured in the course and scope of their employment. Montana State Fund (SMF) paid Appellants indemnity and medical benefits. Appellants were subsequently incarcerated for various crimes, after which MSF terminated or denied payment of permanent partial disability (PPD) benefits. Appellants each appealed their ineligibility to receive PPD benefits. The Workers’ Compensation Court (WCC) granted MSF’s motions for summary judgment as to both Appellants. The Supreme Court affirmed, holding (1) the WCC properly determined that Mont. Code Ann. 39-71-744 rendered incarcerated claimants ineligible for disability or rehabilitation compensation benefits; and (2) section 39-71-744 did not violate Appellants’ constitutional rights to equal protection, to substantive due process, to procedural due process, or to be from excessive fines. View "Goble v. Mont. State Fund" on Justia Law

Plaintiff filed a constructive discharge claim naming the Musselshell County Sheriff’s Office as the sole defendant. Defendant filed a motion to dismiss, arguing that it was not an independent legal entity subject to suit. Plaintiff subsequently moved for leave to amend the complaint to add Musselshell County as a defendant. The district court denied Plaintiff’s motion to amend and granted Defendant’s motion to dismiss. The Supreme Court reversed, holding (1) the district court’s order was appealable; and (2) under the circumstances, the district court’s refusal to allow Defendant to add the correct party constituted an abuse of discretion and resulted in substantial prejudice to Defendant. Remanded. View "Seamster v. Mussellshell County Sheriff's Office" on Justia Law

From 2003 to 2011, Jasvinder Singh worked for America’s Best Contractors, Inc. (ABC) as a salesperson and estimator. After his employment with ABC ended, Singh filed a claim with the Montana Department of Labor and Industry (DOLI), alleging that he was owed unpaid commissions for the period of June 2010 to June 2011. The DOLI hearings bureau determined that ABC owed Singh unpaid commissions and a penalty totaling $60,575. The district court affirmed DOLI’s final agency decision. The Supreme Court affirmed, holding (1) the hearing officer did not adjudicate collateral matters beyond DOLI’s jurisdiction when he excluded certain payments; and (2) the hearing officer’s factual determinations that certain checks issued to Singh were payments on collateral obligations were supported by the evidence. View "America's Best Contractors, Inc. v. Singh" on Justia Law

In the 1990s, Defendants (Employers) created a sick-leave policy allowing employees to bank their sick leave in a continued illness bank (CIB). In 2002, Employers modified the terms of the CIB to create the CIB pay-out benefit, which allowed a capped amount of unused CIB hours to be paid to departing employees who completed twenty-five years or more of service. In 2008, Employers terminated the CIB pay-out benefit, and only employees who had reached twenty-five years of employment with Employers were entitled to their earned but unused CIB hours upon termination. Plaintiffs in this case represented employees who had not reached twenty-five years of service before the benefit ended. Plaintiffs brought a class action complaint against Employers. The district court granted summary judgment for Employers. The Supreme Court affirmed, holding that the district court did not err in determining that (1) Employers’ policies did not constitute a standardized group employment contract; (2) the CIB pay-out benefit was not deferred compensation or wages under the Montana Wage and Wage Protection Act; and (3) the covenant of good faith and fair dealing did not apply to Plaintiffs’ claims. View "Chipman v. Northwest Healthcare Corp." on Justia Law

In 2004, Petitioner was hired as a production supervisor for Holcim Inc.’s cement manufacturing plant. In 2008, Petitioner was diagnosed with angina. After Petitioner left Holcim, Petitioner filed a claim under the Montana Human Rights Acts for discrimination. The Montana Department of Labor and Industry dismissed Petitioner’s complaint, concluding that Holcim did not discriminate against Petitioner on the basis of disability. The Montana Human Rights Commission upheld the dismissal, and the district court affirmed. The Supreme Court affirmed, holding that the district court did not err in affirming the hearing officer’s determination that Petitioner did not prove that he belonged to a protected class, as Petitioner failed to establish that he was disabled within the meaning of the Human Rights Act. View "Estate of Welch v. Holcim, Inc." on Justia Law

Steve Sangwin, a State employee, was a qualified subscriber and beneficiary of the State of Montana Employee Benefits Plan (Plan), which was administered by Blue Cross and Blue Shield of Montana (BCBS). Steve's daughter, McKinley, was also a beneficiary under the Plan. This case arose after BCBS denied a preauthorization request for a medical procedure for McKinley on the grounds that the procedure was "experimental for research." Steve and his wife (collectively, the Sangwins) initiated this action by filing an amended complaint setting forth five counts, including a request for certification of a class action. The Sangwins defined class members as other beneficiaries of the Plan who had their employee benefits denied by the State based on the experimental exclusion for research in the past eight years. The district court granted the Sangwins' motion for class certification. The State appealed. The Supreme Court (1) affirmed the district court's order defining the class; but (2) reversed and remanded with respect to the question certified for class treatment, holding that the district court abused its discretion in specifying for class treatment the question of whether the State breached its contract of insurance with the plaintiffs. View "Sangwin v. State" on Justia Law

Before he resigned, Plaintiff worked as the education director for Defendant, a farm organization. Plaintiff filed this action, claiming (1) Defendant failed to pay him for overtime, for vacation, and for his work handling the duties formerly assigned to the executive director; (2) Defendant's president (President) interfered with his employment relationship with Defendant; and (3) Defendant constructively discharged him because he refused to violate the law regarding payment of wages and overtime. The jury returned a special verdict form in all respects favorable to Plaintiff and awarded $232,439 in compensatory damages and $300,000 in punitive damages. The Supreme Court reversed and remanded in part and affirmed in part, holding (1) the district court erred in denying summary judgment on Plaintiff's wage claims; (2) the district court erred in denying judgment as a matter of law on Plaintiff's claim against President individually; (3) Defendant was not entitled to a new trial on Plaintiff's constructive discharge claim; and (4) the punitive damages claim properly went to the jury, but the trial court should have limited the award to three percent of Defendant's net worth as required by Mont. Code Ann. 27-1-220(3). View "Harrell v. Farmers Educ. Coop. Union of Am., Mont. Div." on Justia Law