Justia Injury Law Opinion Summaries

Articles Posted in Montana Supreme Court
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The case involves Michael Goguen, an engineer and businessman, who was the subject of two civil suits alleging sexual and criminal misconduct. The New York Post published an article detailing these lawsuits, which Goguen claimed was defamatory. Goguen filed a defamation lawsuit against New York Post's parent company, NYP Holdings, and others. In response, NYP Holdings argued that their article was protected by New York’s fair report privilege, a law that protects media from defamation suits if they are reporting on official proceedings.However, the District Court in Montana, where Goguen resides, applied Montana law and denied NYP Holdings' motion to dismiss, finding that whether the article was privileged was a question of fact for the jury. On appeal, the Supreme Court of Montana determined that under Montana's choice of law rules, New York law should be applied to determine the fair report privilege. The Court found that all the contested statements in the article fairly and accurately reported the lawsuits against Goguen and were thus protected by New York's fair report privilege. Therefore, the Court held that NYP Holdings was entitled to dismissal of Goguen’s complaint.The Court also upheld the District Court's decision to dismiss Goguen's defamation claim against former police chief Bill Dial, ruling that Dial's statements in the article were protected opinions and not actionable. View "Goguen v. NYP Holdings" on Justia Law

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The Supreme Court of the State of Montana affirmed a lower court decision that granted Dr. Gregory S. Tierney's motion to dismiss a medical malpractice lawsuit filed by Janice M. Dodds for insufficient service of process. Dodds initially filed the suit against Dr. Tierney and Benefis Health System in 2013, alleging medical malpractice related to a knee replacement surgery. She failed to serve the defendants in time. Dr. Tierney later filed for bankruptcy, which invoked an automatic stay, halting the lawsuit. After his bankruptcy discharge, Dodds attempted to serve Dr. Tierney but failed to do so within the required 30-day timeframe following the discharge.Dodds further sought to join Dr. Tierney's malpractice insurance company as the real party in interest, but the court denied the motion. Upon review, the Supreme Court found that Dodds had not proven Dr. Tierney's liability, thus the insurer had no duty to indemnify him. The court also rejected Dodds' argument that Dr. Tierney lacked standing after his Chapter 7 discharge. The court held that Dr. Tierney maintained a personal stake in demonstrating he was not liable for medical malpractice and that his insurer would only have a duty to indemnify him once Dodds proved her malpractice claims. View "Dodds v. Tierney" on Justia Law

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This case was a negligence action brought by Dennis Vancos against the State of Montana, Department of Transportation, for injuries he sustained when struck by a car at an intersection. Vancos alleged that the traffic control device at the intersection was inadequately designed, installed, and maintained, leading to the accident. The Supreme Court of the State of Montana addressed three issues on appeal. The first was whether the District Court made an error in handling evidence of Vancos’s consumption of alcohol. The court found that the District Court did err by allowing evidence of Vancos's alcohol consumption but refusing to take judicial notice of his blood alcohol content (BAC), which was not deemed to be in evidence. The court held that a party need not introduce evidence of a fact judicially noticed, and therefore, the District Court's interpretation of the rule was incorrect, and it abused its discretion by refusing to take judicial notice of Vancos's BAC.The second issue was whether the District Court erred by not accepting Vancos’s proposed jury instruction on pedestrian rights-of-way. The court found that the District Court did not abuse its discretion when it rejected Vancos’s proposed instruction and instead chose to instruct the jury on the entirety of the law.The third issue, which was not addressed due to the requirement for a new trial determined by the first issue, was whether the District Court erred by not striking a prospective juror for cause. Due to the error in handling evidence of Vancos's alcohol consumption, the court reversed in part, affirmed in part, and remanded the case to the District Court for a new trial. View "Vancos v. Montana Department of Transportation" on Justia Law

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The Supreme Court of the State of Montana reversed a district court's decision in a case involving a plaintiff, John Breuer, who sued the State of Montana for injuries sustained in a motor vehicle accident. The accident was caused by a student-employee of the University of Montana. Breuer claimed that the accident resulted in a shoulder injury that caused him significant pain and suffering, and loss of established course of life. The State admitted liability for the accident, but disputed that the accident was the sole cause of Breuer's claimed disabilities and pain. The district court excluded evidence of Breuer's pre-accident back injury and related disabilities as alternate cause evidence. The Supreme Court held that this was an error and that the district court's exclusion of this evidence materially prejudiced the State's right to a fair trial. The case was remanded for a new trial. View "Breuer v. State" on Justia Law

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The Supreme Court affirmed in part and reversed in part the determination of the district court granting Hill County, Montana, and Blaine County, Montana summary judgment on the standalone claims brought by the Estate of A.J. Longsoldier, Jr. for negligence and denying its cross-motion for partial summary judgment on liability, holding that remand was required for further proceedings.Longsoldier died in 2009 while in Hill County's custody. In the first appeal, the Supreme Court affirmed the determination that neither Blaine County, where Longsoldier was arrested, nor Hill County discriminated against Longsoldier on the basis of race or disability. In the second appeal, the Supreme Court reversed the ruling that Hill County could be held vicariously liable for the negligence of the hospital where Longsoldier was treated during his detention. In this third appeal, the Supreme Court reversed in part and remanded the case, holding that the district court (1) erred in determining that the Estate's negligence claim against Hill County was barred by principles of issue preclusion; (2) erred in ruling that the Estate may not pursue a negligence claim against Blaine County; and (3) did not err in denying the Estate's motion for partial summary judgment on liability. View "Stricker v. Blaine County" on Justia Law

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The Supreme Court accepted supervisory control in the underlying action, holding that Montana had specific personal jurisdiction over Melissa Groo regarding Triple D Game Farm, Inc.'s intentional tort claims when the tortious activity allegedly accrued in Montana despite Groo interacting only with the forum via social media.At issue was Groo's purposeful and substantial use of social media to affect Triple D's business operations. Triple D brought this lawsuit alleging tortious interference with contractual relations and tortious interference with prospective economic advantage claims. Groo moved to dismiss the claims for lack of personal jurisdiction, arguing that her statements did not create the necessary minimum contacts with Montana as a forum. The district court denied the motion to dismiss, condoling that Groo had the requisite minimum contacts with the state and that the court's exercise of personal jurisdiction over her did not violate due process principles. The Supreme Court affirmed, holding that the district court was not proceeding under a mistake of law, and the court had personal jurisdiction to resolve this dispute. View "Groo v. Eleventh Judicial District Court" on Justia Law

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The Supreme Court reversed the judgment of the district court awarding Plaintiff $1,000 in actual damages and $2,000 in punitive damages in the underlying trial relating to Defendant's potentially racial motivations for two incidents leading to Plaintiff's assault and battery and negligent and intentional infliction of emotional distress claims, holding that a new trial was required.On appeal, Plaintiff argued that the district court erred in granting Defendant's motion in limine to exclude Plaintiff's race-based evidence because of its prejudicial nature from the punitive damages phase of trial. The Supreme Court agreed and reversed, holding that the district court erred in excluding this evidence during the punitive damage phase of trial and that a new trial was required limited to the amount of punitive damages for which Defendant was liable to Plaintiff in accordance with this opinion. View "Two Leggins v. Gatrell" on Justia Law

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The Supreme Court affirmed the order of the district court granting a summary judgment motion filed by Petitioners and two insurers, Farmers Insurance Exchange and Truck Insurance Exchange (collectively, Insurers), and denying Respondent's cross-motion for summary judgment, holding that the district court did not err by finding that Insurers had no duty to defend Respondent under the terms of the relevant insurance policies.After a complaint in the underlying lawsuit alleging slander, malicious prosecution, and bodily injury was amended to add Respondent as a defendant Respondent tendered the complaint to Farmers seeking defense and indemnity under a series of homeowners insurance policies and commercial general liability policies. Later, the Insurers filed a declaratory judgment action seeking a judicial determination that they were not obligated to defend and indemnity Respondent. The district court found that Insurers had no duty to defend Respondent under any of the policies. The Supreme Court affirmed, holding that Respondent failed to meet his burden of demonstrating that the claims fell within the scope of coverage of any of the policies at issue. View "Farmers Insurance Exchange v. Minemyer" on Justia Law

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The Supreme Court reversed the order of the district court granting a new trial and vacating the underlying judgment on a $168,500 jury verdict in favor of Plaintiff in an admitted-liability automobile accident case, holding that the district court abused its discretion when it concluded that Plaintiff did not receive a fair trial under Mont. Code Ann. 25-11-102(1).Plaintiff sued Defendant seeking damages for the injuries she received when Defendant rear-ended her. The jury rendered a verdict that Plaintiff was not contributorily negligent, she was injured in the collision, and the general damages sustained totaled $168,500. Thereafter, the district court granted Plaintiff's motion for a mistrial, ordered a new trial, and vacated the judgment, concluding that two statements by Plaintiff's counsel constituted an irregularity preventing a fair trial under Mont. Code Ann. 25-11-102(1). The Supreme Court reversed, holding that the district court misapplied Mont. R. Evid. 411 and abused its discretion when it ordered a new trial because the disputed statements were not sufficiently prejudicial to warrant a new trial. View "Voegel v. Salsbery" on Justia Law

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The Supreme Court affirmed the judgment and orders approving a settlement between Robert Allum and Montana State Fund and dismissing Allum's claims for benefits, holding that Allum resolved all of his dispute benefits, and therefore, the Workers' Compensation Court (WCC) did not have jurisdiction over Allum's remaining stand-alone constitutional challenges.The State Fund accepted liability for the knee injury Allum received at work. Later, Allum notified State Fund that he also asserted a back condition resultant from his knee injury. Allum filed a petition seeking a hearing on his injury claims and also sought a hearing on his claims challenging the constitutionality of the Montana Workers' Compensation Act and the WCC. Allum and State Fund settled the injury claims prior to trial. The WCC approved the settlement agreement and then concluded that it lacked jurisdiction to address Allum's constitutional challenges because Allum had resolved all of his benefit disputes. The Supreme Court affirmed, holding that the WCC's conclusions of law were correct. View "Allum v. Mont. State Fund" on Justia Law