Montana State University-Bozeman v. First Judicial District Court

The Supreme Court exercised supervisory control over pending proceedings in the underlying matter of Cepeda v. Montana State University and reversed an order sanctioning Montana State University-Bozeman (MSU), holding that the district court abused its discretion in imposing default judgment as an evidence spoliation sanction pursuant to Mont. R. Civ. P. 37(b)-(c) and (e).Plaintiff filed a claim alleging that MSU negligently hired or supervised a faculty member and that MSU’s negligence caused Plaintiff to suffer harm. Two and a half years after the district court heard oral argument on the parties’ cross-motions for summary judgment, discovery sanctions, and preliminary evidentiary rulings, the district court granted Plaintiff’s sanctions motion and summarily adjudicated liability against MSU as an evidence spoliation sanction. The Supreme Court held (1) exercise of supervisory control was necessary and proper because this case presented a significant question as to whether the district court was proceeding under a mistake of law which, if uncorrected, would likely cause significant injustice rendering ordinary appeal inadequate; and (2) the district court abused its discretion in imposing default judgment against MSU as a spoliation sanction under Rule 37(b)-(c) and (e). View "Montana State University-Bozeman v. First Judicial District Court" on Justia Law