Chipman v. Northwest Healthcare Corp., 2012 MT 242

Plaintiffs Chipman, Wallen, and Hames are KRMC employees and class representatives challenging the discontinuation of the CIB sick-leave buy-back program.
NWHC is the umbrella parent; KRMC, Brendan House, The Summit are affiliates; AHS and NOSM are for-profit subsidiaries.
CIB allowed eligible employees to accrue and cash out hours at retirement/severance; policy adopted at different times across entities (2002-2007).
KRMC terminated CIB on July 1, 2008; 1,254 employees were eligible at termination, later growing to over 1,500 by 2011.
District Court certified a class defined as status employees employed on or before June 30, 2008 across multiple Employers; this appeal challenges standing and certification.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing of named Plaintiffs to sue non-KRMC Employers	Employees have a contractual/withdrawal-right interest via a unified policy.	Plaintiffs lack injury against non-KRMC Employers; no direct dealings with those entities.	Standing to sue non-KRMC Employers affirmed due to juridical link and concerted scheme.
Whether class certification under Rule 23(a)-(b) was proper	Common contract terms and uniform CIB policy support class treatment.	Differences among employees could require individual inquiries; commonality not met under Wal-Mart guidance.	Class certification affirmed under Rule 23(a) and (b)(1)-(2) for a unified policy and substantial common issues.

Powder River County v. State, 2002 MT 259 (Mont. 2002) (three-part justiciability test for standing)
McKamey v. State, 268 Mont. 137 (Mont. 1994) (declaratory judgments for threatened injuries to rights)
Gryczan v. State, 283 Mont. 433 (Mont. 1997) (standing for declaratory relief based on threatened prosecution)
La Mar v. H&B Novelty & Loan Co., 489 F.2d 461 (9th Cir. 1973) (juridical link concept in class actions)
Murer v. Montana State Compensation Fund, 257 Mont. 434 (Mont. 1993) (juridical link and conspiracy/court-type exceptions to class action)
Wal-Mart Stores, Inc. v. Dukes, 131 S. Ct. 2541 (U.S. 2011) (Wal-Mart commonality standard following stricter class-wide proof)
Diaz v. Blue Cross & Blue Shield, 363 Mont. 151 (Mont. 2011) ( Rule 23 analysis; rigorous analysis required)
Cates v. Cooper Tire & Rubber Co., 253 F.R.D. 422 (N.D. Ohio 2008) (illustrative of typicality where benefits stem from same plan)
Bova v. City of Medford, 564 F.3d 1093 (9th Cir. 2009) (ripeness/standing in post-retirement benefits)
Auerbach v. Board of Educ., 136 F.3d 104 (2d Cir. 1998) (standing when benefits are contingent on future retirement)