Justia Injury Law Opinion Summaries
Articles Posted in Montana Supreme Court
N. Cheyenne Tribe v. Roman Catholic Church
Defendants in this suit included the St. Labre Indian Education Association, Inc. and the St. Labre Home for Indian Children and Youth (collectively, St. Labre). After St. Labre experienced a decrease in government funding, St. Labor began a fundraising campaign that NCT asserted resulted in millions of dollars donated to St. Labre through efforts that marketed the plight and need of NCT. NCT filed suit against Defendants alleging (1) St. Labre's fundraising system created a constructive trust on behalf of NCT and St. Labre wrongfully converted those funds to its own use, thus unjustly enriching itself; (2) contract and fraud type issues; and (3) St. Labre unconstitutionally committed cultural genocide against NCT. The district court dismissed all of NCT's motions. The Supreme Court (1) reversed the district court's grant of summary judgment on NCT's claim for unjust enrichment and the imposition of a constructive trust that may arise from St. Labre's fundraising activities after 2002; (2) reversed the district court's grant of summary judgment regarding St. Labre's fundraising activities before 2002; and (3) affirmed the court's grant of summary judgment on all of NCT's remaining claims. View "N. Cheyenne Tribe v. Roman Catholic Church" on Justia Law
Lucas v. Stevenson
Tamara Lucas and her husband James brought a legal malpractice claim against attorney Mat Stevenson after they hired Stevenson to defend James against criminal charges and to represent them in a civil suit against the city police department, the city, and individual police officers that arrested James for disturbing the peace and felony assault on a peace officer. However, Stevenson later learned that the Lucases had previously filed for bankruptcy. The civil suit was determined to an asset of the bankruptcy estate, and Stevenson was reassigned to pursue the case on behalf of the bankruptcy estate. After a settlement agreement was reached, the Lucases brought this action against Stevenson. The district court granted summary judgment in favor of Stevenson. The Supreme Court affirmed, holding that the district court correctly determined (1) the Lucases' civil claims were properly determined to be an asset of the bankruptcy estate; and (2) Stevenson did not represent the Lucases at the time the claims were settled, and therefore, the Lucases had no standing to bring a legal malpractice claim against him. View "Lucas v. Stevenson" on Justia Law
Harris v. State
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
Steichen v. Talcott Props., LLC
Defendant owned a building and leased spaced in the building to Company. Plaintiff worked as an independent contractor for Company, providing cleaning services. After Plaintiff injured himself while working in Defendant's building, Plaintiff sued Defendant. The district court granted summary judgment to Defendant. The Supreme Court reversed, holding (1) the district court erred in applying construction industry liability standards to this case and in determining that Defendant owed no duty that Defendant as a property owner had a duty of care to Plaintiff because Plaintiff was an independent contractor working for Company; and (2) the court further erred in granting summary judgment to Defendant based upon the determination that "no reasonable jury" could find that Defendant had breached the duty of ordinary care under the facts of the case. View "Steichen v. Talcott Props., LLC " on Justia Law
McEwen v. MCR, LLC
MCR, LLC filed an action for condemnation of a compressor station site on property owned by Appellees. Appellees counterclaimed against MCR for damage to their property and claimed punitive damages. Appellees sought restoration costs as the measure of damages for their contract, trespass, and nuisance claims. The parties stipulated to the substitution of MCR Transmission, LLC (MCR-T) for MCR on the condemnation claim. The district court dismissed MCR-T's condemnation claim and granted Appellees' summary judgment motion allowing Appellees to seek restoration costs. The jury awarded restoration costs and punitive damages to Appellees. The Supreme Court affirmed in part, reversed in part, and remanded, holding that the district court (1) erred in dismissing MCR-T's motion to condemn Appellees' property for a compressor station, as genuine issues of material fact existed as to whether Appellees' property was necessary for the compressor station; (2) properly determined that Appellees were entitled to seek restoration costs as the measure of their damages; and (3) properly admitted evidence at trial that MCR had jumped Appellees' bid on state trust land leases. View "McEwen v. MCR, LLC" on Justia Law
Boyne USA, Inc. v. Spanish Peaks Dev., LLC
Boyne USA, Inc. filed an action for breach of contract against Blixseth Group, Inc. that covered a land sale for fifteen acres of property, seeking specific performance. Boyne joined Yellowstone Mountain Club, LLC (Yellowstone) as a party due to Yellowstone's acquisition of the contested property. Meanwhile, Yellowstone conveyed the property to Spanish Peaks Development, LLC (SPD). SPD, in turn, conveyed the property to Lone Mountain Holdings, LLC (LMH). Boyne joined SPD and LMH as parties. Boyne further alleged abuse of the legal process and deceit. The district court dismissed Blixeth Group and Yellowstone due to Yellowstone's bankruptcy. After a jury trial, (1) the jury awarded Boyne $300,000 from each SPD and LMH based on its determination that Defendants had deceived Boyne and had abused the legal process, (2) the district court awarded Boyne specific performance on the agreement; and (3) the court awarded attorney fees to Boyne. The Supreme Court affirmed subject to one minor modification, holding that the district court did not err in its judgment, and that Boyne was entitled to legal fees on appeal. View "Boyne USA, Inc. v. Spanish Peaks Dev., LLC" on Justia Law
Labair v. Carey
The Labairs lost their newborn baby after an early delivery by C-section. The Labairs retained Steve Carey and Carey Law Firm (Carey) to pursue their medical malpractice claim against their obstetrician. More than two and a half years later, Carey filed a complaint against the obstetrician. However, Carey failed to file an application with the Montana Medical Legal Panel (MMLP) before filing a complaint with the district court as required by statute and further failed to file an MMLP application within the three-year statute of limitations applicable to medical malpractice claims. The district court later dismissed the Labairs' medical malpractice case with prejudice as time-barred by the statute of limitations. The Labairs subsequently filed a complaint for legal malpractice against Casey. The district court entered summary judgment for Carey, concluding that Carey's conduct of failing to file the application with the MMLP did not cause the Labairs injury or damages because the Labairs failed to show that the underlying medical malpractice claims would have succeeded but for the error. The Supreme Court reversed and remanded, holding (1) the Labairs' loss of their medical malpractice case was an injury; and (2) the damages associated with that injury remained unproven. View "Labair v. Carey " on Justia Law
Gatlin-Johnson v. Miles City
When Plaintiff brought her daughter to play in a city park, the child fell from a slide in the playground area and suffered a severe head injury. Plaintiff sued the City for negligently failing to maintain a safe depth of impact-absorbing material in the area under the slide. The district court granted summary judgment to the City, (1) determining that the "public duty doctrine" applied in this case, that the City owed no duty to Plaintiff's daughter, and therefore, the City could not be held liable for the accident; and (2) rejecting Plaintiff's argument that the recreational use statute applied to this case and imposed liability upon the City for willful or wanton misconduct. The Supreme Court reversed, holding (1) based upon an analysis of foreseeability, it was reasonable and proper to hold the City to a duty to exercise reasonable care in maintaining its public parks, and thus, the public duty doctrine did not apply here; and (2) the recreational use statute applied to this case, and the determination of whether the City's conduct rose to the level of willful or wanton misconduct should be decided at trial. View "Gatlin-Johnson v. Miles City" on Justia Law
Alexander v. Bozeman Motors, Inc.
Mike Alexander was one of two former employees of Bozeman Motors who filed suit against Bozeman Motors and its president and managers, alleging negligence, battery, and negligent or intentional infliction of emotional distress. Plaintiffs claimed long-term physical and emotional injuries resulting from exposure to carbon monoxide and propane. Alexander died after filing suit. Bozeman Motors moved for summary judgment on the basis that the claims against it were barred by the exclusive remedy provision of Montana's Workers' Compensation Act. The district court granted Bozeman Motors' motion, holding that the conduct of Defendants did not rise to the level of deliberate intent to cause specific harm, and that Mont. Code Ann. 39-71-413, which provides an exception to the exclusive remedy provision of the Act, was constitutional. The Supreme Court reversed and remanded with respect to Alexander's claims. On remand, the jury returned a verdict for Defendants on all claims. The Supreme Court affirmed, holding (1) section 39-71-413(2) does not create an impermissible class of employees in violation of equal protection; (2) the district court did not err in instructing the jury; and (3) the court did not err in denying Plaintiffs' motion to exclude Alexander's cause of death. View "Alexander v. Bozeman Motors, Inc." on Justia Law
Murray v. Whitcraft
Plaintiff was injured in a car accident when the car in which he was a passenger and which Defendant was driving crashed after Defendant lost control of the vehicle. Plaintiff filed an action against Defendant seeking damages for injuries allegedly caused by Defendant's negligence. Following a jury trial, the jury found in favor of Plaintiff and awarded him $27,000. Plaintiff, having presented evidence of past medical expenses totaling $35,030, filed a motion for a new trial on the issue of damages. The district court denied the motion. The Supreme Court affirmed, holding (1) substantial evidence supported the jury's conclusion that Plaintiff was not entitled to the full amount of damages he requested; and (2) thus, the district court did not abuse its discretion by denying Plaintiff's motion for a new trial. View "Murray v. Whitcraft" on Justia Law
Posted in:
Injury Law, Montana Supreme Court