Articles Posted in Montana Supreme Court

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The Supreme Court affirmed the judgment of the district court granted the State’s motion to dismiss and Jefferson County’s motion for summary judgment as to Plaintiffs’ complaint against special deputy prosecutor Steven Shapiro, the State, and Jefferson County, holding that the district court properly concluded that Shapiro was entitled to absolute prosecutorial immunity and that this immunity was properly extended to both Jefferson County and the State. Plaintiffs brought this complaint seeking damages under 42 U.S.C. 1983, alleging violations of their child’s constitutional rights, a Dorwart claim, and a malicious prosecution claim. Plaintiffs also filed a negligence claim against Jefferson County. The district court granted the motion to dismiss brought by the State and Shapiro on the grounds of absolute prosecutorial immunity. The court then granted summary judgment for Jefferson County on the grounds that the public duty doctrine barred Plaintiffs’ claims. The Supreme Court affirmed, holding that the district court (1) correctly concluded that Shapiro was entitled to absolute prosecutorial immunity when he signed an affidavit establishing probable cause to file a petition initiating delinquency proceedings against Plaintiffs’ child; (2) properly extended this immunity to Jefferson County and the State; and (3) correctly concluded that the public duty doctrine prevented recovery against Jefferson County. View "Renenger v. State" on Justia Law

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The Supreme Court affirmed the district court’s orders granting motions to dismiss Plaintiffs’ negligence claims against BNSF Railway Company, holding that a company does not consent to general personal jurisdiction by registering to do business in Montana and voluntarily conducting in-state business activities. BNSF, a rail carrier incorporated in Delaware with its principal place of business in Texas, registered to do business in Montana and designated an in-state agent for service of process. Plaintiffs filed suit against BNSF under the Federal Employers’ Liability Act for injuries allegedly sustained while working for BNSF in states other than Montana. BNSF moved to dismiss Plaintiffs’ claims for lack of personal jurisdiction. The district court determined that BNSF did not consent to personal jurisdiction in Montana and, accordingly, granted BNSF’s motions to dismiss. The Supreme Court affirmed, holding (1) a foreign corporation does not consent to general personal jurisdiction when it registers to do business in Montana and then voluntarily conducts in-state business activities; and (2) accordingly, BNSF did not consent to general personal jurisdiction in this case. View "Deleon v. BNSF Railway Co." on Justia Law

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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

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The Supreme Court affirmed the decision of the district court refusing to strike for cause a juror who was a state employee in this action filed against the State to recover damages for injuries sustained in a collision with a vehicle owned and operated by the Montana Department of Transportation. Plaintiff sued the State for its employee’s negligence. After a trial, a jury found Plaintiff fifty-one percent at fault in the accident. On appeal, Plaintiff challenged the district court’s refusal to excuse a juror for cause due to his employment with the State. The Supreme Court affirmed, holding that the district court did not abuse its discretion by denying Plaintiff’s challenge for cause because the juror demonstrated that he could act with entire impartiality. View "Bockman-Fryberger v. State" on Justia Law

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In this insurance dispute, the Supreme Court reversed in part the entry of summary judgment in Plaintiff’s declaratory action regarding underinsured motorist coverage (UIM) in favor of Farmers Insurance Exchange, holding that the district court erred by holding that Farmers could offset its underinsured motorist coverage (UIM) obligation to Plaintiff dollar-for-dollar with GEICO’s entire UIM payment. Plaintiff was one of five passengers injured in an accident. The tortfeasor was underinsured by $48,686 as to Plaintiff’s damages. The vehicle in which Plaintiff was a passenger was insured by GEICO, and Plaintiff carried personal vehicle coverage with Farmers, including medical payment (MedPay) coverage and UIM coverage. GEICO paid Plaintiff its individual UIM coverage limit and Farmers paid Plaintiff under her MedPay coverage. In total, Plaintiff received payments of $2,500 less than her total stipulated damages. Disputes Plaintiff had with Farmers led Plaintiff to file this declaratory action. The district court held in Farmers’ favor on the two contested issues. The Supreme Court held (1) the policy language did not permit Farmers to offset its UIM obligation dollar-for-dollar with the entire GEICO UIM payment; (2) Farmers was entitled to offset its UIM obligation with its MedPay payments to Plaintiff; and (3) Plaintiff was entitled to recover attorney fees. View "Cramer v. Farmers Insurance Exchange" on Justia Law

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The Supreme Court affirmed the jury verdict in favor of Burlington Northern Santa Fe Railway Company (BN) on Plaintiff’s claims that BN violated the standard of care under the Federal Employers Liability Act (FELA) and the Locomotive Inspection Act (LIA), holding that Plaintiff’s allegations of error on appeal were unavailing. Plaintiff alleged injury for exposure to asbestos during his work at a treatment plant operated by BN’s predecessor. A jury found in favor of BN. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion by excluding certain evidence at trial; (2) Plaintiff was not denied a fair trial due to any alleged trial misconduct on the part of BN; and (3) Plaintiff was not denied a fair trial due to any alleged discovery misconduct on the part of BN. View "Daley v. Burlington Northern Santa Fe Railway Co" on Justia Law

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The Supreme Court affirmed the judgment of the district court in this dispute between Associated Management Services, Inc. (AMS) and Daniel R. Ruff and Ruff Software, Inc. (collectively, Ruff) over the parties’ relative rights regarding the web-based payroll processing software, TimeTracker, developed by Ruff and licensed to AMS. The district court granted summary judgment to Ruff on AMS’s claims and granted summary judgment to AMS on Ruff’s counterclaims. The Supreme Court affirmed, holding that the district court (1) did not err in ruling that the 2008 licensing agreement was valid and enforceable and that AMS had no right to TimeTracker other than as provided under the terms of the agreement; (2) correctly granted summary judgment on the Ruff counterclaims for breach of the licensing agreement, tortious conversion, contract and tortious misappropriation of intellectual property, violation of the Montana Uniform Trade Secrets Act, tortious interference with business relations or prospective economic advantage, and unjust enrichment; and (3) did not abuse its discretion in denying Ruff’s second motion to compel or claim for attorney fees. View "Associated Management Services, Inc. v. Ruff" on Justia Law

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Under Montana law, when a plaintiff claims he or she was injured directly by a law enforcement officer’s affirmative acts, the public duty doctrine does not exclude all duties that may arise pursuant to generally applicable principles of negligence. Plaintiff was injured in the course of a law enforcement officer’s (Officer) pursuit of a criminal suspect. Plaintiff brought a state-law negligence claim and a 42 U.S.C. 1983 violation against the Officer and the City of Billings, alleging that he was injured directly by the Officer’s affirmative acts. A federal court entered summary judgment in favor of Defendants on both claims. Regarding the negligence claim, the court found that the public-duty doctrine shielded Defendants from liability because no special relationship existed. The court of appeals certified to the Supreme Court the public duty doctrine question. The Supreme Court held (1) the public-duty doctrine applies only to an officer’s duty to protect the general public and therefore does not apply to exclude the legal duty an officer may owe to a person injured directly by the officer’s affirmative actions; and (2) in this case, the Officer owed Plaintiff a legal duty to exercise the same care that a reasonable officer with similar skill, training, and experience would under the same or similar circumstances. View "Bassett v. Lamantia" on Justia Law

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The Supreme Court affirmed in part and reversed in part the order of the district court dismissing Plaintiff’s amended complaint against several lenders, holding that the district court did not err in dismissing some of Plaintiff’s claims but erred in dismissing the remaining claims. After Plaintiff defaulted on her loan on real property, she received at least nine notices of sale. Plaintiff filed an amended complaint against Lenders, alleging six causes of action. The district court granted Lenders’ motion to dismiss the amended complaint pursuant to Mont. R. Civ. P. 12(b)(6). The Supreme Court held that the district court (1) did not err in dismissing Plaintiff’s declaratory judgment claim as a matter of law or in dismissing Plaintiff’s negligent and/or intentional infliction of emotional distress claim fore failure to state sufficient facts to entitle her to relief; and (2) incorrectly determined that Plaintiff’s amended complaint failed to state a claim on her asserted breach of contract and breach of the implied covenant of good faith and fair dealing, Fair Debt Collection Practices Act (FDCPA), and Montana Consumer Protection Act (MCPA) claims. View "Puryer v. HSBC Bank" on Justia Law

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The Supreme Court affirmed the order of the district court dismissing with prejudice this action filed by Plaintiffs against Defendant seeking damages for personal injuries allegedly sustained in an automobile collision. The district court dismissed the action under Mont. R. Civ. P. 37(d) due to each plaintiff’s failure to answer fully interrogatories or to produce relevant documents during discovery. In affirming, the Supreme Court held that the district court did not abuse its discretion by granting Defendant’s motion for sanctions, denying one plaintiff’s motion to strike, and denying the other plaintiff’s motion to reconsider because the trial court’s discovery sanction related to the extent of the prejudice that resulted from the discovery abuse. View "Cox. v. Magers" on Justia Law