Justia Contracts Opinion Summaries

Blue Cross and Blue Shield of Montana (BCBS) signed an employment agreement with Plaintiff containing a clause to compel arbitration for any disputes regarding the employment agreement. After Plaintiff's employment was terminated, Plaintiff brought an action against BCBS claiming that BCBS violated the Wrongful Discharge from Employment Act (WDEA). Plaintiff, however, could bring a WDEA claim only if she did not have a written contract of employment for a specific term. The district court compelled arbitration to allow the arbitrator to determine in the first instance whether Plaintiff had a term employment contract. The Supreme Court affirmed the district court's order to compel arbitration, holding that because the instant dispute implicated the terms or provisions of the employment agreement, the district court correctly determined that an arbitrator should decide, in the first instance, whether Plaintiff was an at-will employee or whether she had a term contract. View "Marsden v. Blue Cross & Blue Shield of Mont., Inc." on Justia Law

In this dispute over real property, Roslyn Shephard, in her capacity as personal representative of the estates of real property owners (Lessors), terminated the third lease of Lessees based on an alleged violation of the terms of the lease. Shephard then sued Lessees, seeking to invalidate Lessees' third lease due to the fact that she had not signed it on Lessors' behalf. Shephard alternatively sought an order declaring that Lessees had breached the terms of the lease. Lessees counterclaimed, alleging that Shephard had breached the terms of the lease by wrongfully terminating the lease and by failing to provide notice to them of the alleged breach. The district court found in favor of Lessees. The Supreme Court affirmed, holding (1) the district court correctly determined that the lease was valid without Shephard's signature; (2) substantial evidence supported the district court's finding that Lessees had not violated the lease; and (3) the district court correctly determined that the terms of the lease entitled Lessees to notice of their alleged breach and an opportunity to cure. View "Shephard v. Widhalm" on Justia Law

Plaintiff owned and operated a ranch with an 18,000 square-foot lodge. Defendant was a custom manufacturer of high-end wood flooring from whom Plaintiff brought wood flooring while building the lodge. After it was installed, the wood flooring began buckling and had to be replaced. Plaintiff sued Defendant for negligent misrepresentation, breach of an implied warranty of suitability for a particular purpose, and violation of the Montana Unfair Trade Practices and Consumer Protection Act (MCPA). The jury returned a verdict in Defendant's favor on all of Plaintiff's claims. The district court then granted Defendant attorney fees as the prevailing party under the MCPA. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion when it found good cause to amend the scheduling order to allow Defendant's late disclosure of an expert witness; and (2) did not err when it awarded Defendant attorney fees under the MCPA. View "B Bar J Ranch, LLC v. Carlisle Wide Plank Floors, Inc." on Justia Law

At issue on review in this case was whether the State Board of Land Commissioners properly issued leases to Ark Land Co., a subsidiary of Arch Coal, Inc., without first conducting environmental review under the Montana Environmental Policy Act (MEPA). The State Land Board did not conduct environmental review prior to entering the leases, relying on Mont. Code Ann. 77-1-121(2). The district court granted summary judgment to the State Land Board, Ark Land Co., and Arch Coal (Defendants), determining that the State retained sufficient ability to require adequate environmental protections sufficient to meet its constitutional and trust responsibilities. The Supreme Court affirmed, holding (1) because the leases did not allow for any degradation of the environment and specifically required full environmental review and full compliance with applicable State environmental laws, the act of issuing the leases did not impact or implicate the right to a clean and healthful environment in Mont. Const. art II, 3; and (2) therefore, section 77-1-121(2) was not subject to strict or "middle-tier" scrutiny. View "N. Plains Res. Council, Inc. v. Bd. of Land Comm'rs" on Justia Law

Johnson Farms, Inc. and Floyd Johnson filed a complaint against Ethel Halland alleging (1) in her capacity as secretary of Johnson Farms, Inc., Ethel breached her fiduciary duties by diverting corporate funds to herself and others; and (2) Ethel conferred gifts to herself and other family members in contravention of a written trust agreement. The district court granted Ethel's motion for summary judgment, finding that the complaint was barred by the statute of limitations and that equitable estoppel did not toll the statute of limitations. The district court also awarded Ethel attorneys' fees and costs. The Supreme Court affirmed, holding (1) Johnson's claims were barred by the statute of limitations; and (2) the district court did not err in awarding Ethel attorneys' fees and costs. View "Johnson Farms, Inc. v. Halland" on Justia Law

James Turner and Julie Viers opened a line of credit with Wells Fargo Bank and granted Wells Fargo a deed of trust on property they owned as security for the line of credit. Later, John Turner, Christina Turner, and Sandy Couch (the John Turners) purchased the property. Julie and James paid off the entire outstanding balance under the credit line agreement using the proceeds from the sale of the property to the John Turners, but Julie subsequently borrowed $169,090 under the credit line agreement secured by the property. Thereafter, Wells Fargo refused to release the deed of trust. The John Turners then filed a complaint to quiet title to the property. The district court granted Wells Fargo's motion for summary judgment, concluding that the John Turners could not enforce the terms of the credit line agreement because they were not intended beneficiaries of the agreement. The Supreme Court affirmed, holding that the district court correctly concluded (1) the John Turners were not entitled to judgment requiring Wells Fargo to release the deed of trust the bank held on the property; and (2) the John Turners failed to establish prima facie claims of promissory or equitable estoppel. View "Turner v. Wells Fargo Bank, N.A." on Justia Law

This case arose from claims asserted by multiple persons against Blue Cross and Blue Shield of Montana (BCBSMT) and Montana Comprehensive Health Association (MCHA). Claimants asserted that while they were fully insured by BCBSMT or MCHA, they submitted claims that the insurers denied based upon exclusions contained in their insurance policies. These exclusions were subsequently disapproved by the Montana Commissioner of Insurance (Commissioner) and the insureds sought the previously-denied benefits. The matter evolved into a class action and three of the claimants, Krista Lucas, Brittany Smith, and Alice Speare, were named class representatives. Subsequently, a settlement was negotiated. Three other claimants, Tyson Pallister, Kevin Budd and Jessica Normandeau, objected to the settlement and sought review by the Second Judicial District Court. The District Court approved the settlement. Pallister, Budd and Normandeau appealed asserting numerous errors by the District Court including but not limited to the court’s error in denying Pallister’s motion to conduct discovery. Upon review, the Supreme Court reversed and remanded on a discrete issue of discovery and vacated the District Court’s approval of the Settlement Agreement. View "Pallister et al v. Blue Cross & Blue Shield of Montana" on Justia Law

Mountain West Bank obtained a summary judgment against Helena Christian School and several individual defendants (HCS) following HCS’s default on loans from Mountain West. HCS appealed the decision of the Montana First Judicial District Court. The issues on appeal were: (1) whether the District Court erred by granting Mountain West’s motion for summary judgment without complying with the requirements of 71-1-222, MCA; and (2) whether the District Court erred by entering a judgment that did not comply with 25-9-203, MCA. Upon review, the Supreme Court reversed and remanded, giving the lower court the mandate to compute and state the exact judgment amount, including interest, pertaining to the unsecured loan; for the secured loan, the court must comply with the provisions of 71-1-222, MCA. Upon receipt of notice of the proceeds received in the sheriff’s sale, in the event of a deficiency, the court must determine the appropriate rate of interest vis-a-vis the deficiency, and enter an order of judgment computing and stating the amount owed by Defendants. View "Mtn. West Bank, NA v. Helena Christian School, Inc." on Justia Law

Candice Brilz filed an action in Montana state court purportedly asserting statutory and common law bad-faith claims against Metropolitan General Insurance Company (Metropolitan). Metropolitan removed the action to federal court and filed a motion for summary judgment, which the federal court granted. Thereafter, Brilz commenced this suit district court seeking a determination that she may pursue her common law bad-faith claim against Metropolitan. Because the statute of limitations on that claim had since expired, Brilz requested a ruling that she may pursue the claim pursuant to 27-2-407, MCA, or the Supreme Court's doctrine of equitable tolling. The District Court dismissed the action, and Brilz appealed. The Supreme Court concluded that principles of claim preclusion barred her from filing a second action against Metropolitan arising out of the same underlying facts. Accordingly the Court affirmed the District Court's judgment. View "Brilz v. Metropolitan General Ins." on Justia Law

Pro se litigant Sharon McCrea appealed a district court's judgment that awarded over eight thousand dollars to CBM Collections, a Missoula collection agency. McCrea owned a business which had an outstanding credit card bill with the Missoula Federal Credit Union (MFCU). She was notified that the debts were being assigned to CBM for collection. CBM subsequently filed its complaint to seek the full amount owned plus interest. McCrea answered, arguing that MFCU was unfairly and deliberately targeting her for collection and that the matter should be "remanded" to the credit union so that she could continue making incremental payments. McCrea did not deny owing the debts. She sought discovery of credit card statements and cell phone billing statements to establish she had been in regular contact with MFCU in an attempt to resolve the matter. The district court granted CBM's motion for judgment on the pleadings without ruling on McCrea's discovery request and entered the award. Finding no error in the district court's ruling, the Supreme Court affirmed. View "CBI Inc. v. McCrea" on Justia Law