Chouteau County v. Sayers
2017 MT 94N
| Mont. | 2017Background
- Robert Sayers previously sued Chouteau County (2012), disputing whether Lippard Road was a county road or his private driveway.
- The district court granted summary judgment to the County, and this Court affirmed in Sayers v. Chouteau County, 2013 MT 45.
- After that judgment, Chouteau County sued Sayers seeking an order requiring removal of fences and gates that intruded on Lippard Road.
- In the County’s enforcement action, the County moved for summary judgment to remove the obstructions.
- Sayers opposed summary judgment by arguing the prior 2012/2013 judgment was erroneous based on newly discovered facts and attempted to relitigate the road’s status.
- The district court granted summary judgment to the County, concluding res judicata barred Sayers from relitigating the issues; the Supreme Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Sayers may relitigate whether Lippard Road is a county road | County: prior judgment established road status; County seeks removal of obstructions | Sayers: new facts justify reopening or overturning prior summary judgment | Court: res judicata bars relitigation; summary judgment for County affirmed |
| Whether the County may obtain an order requiring removal of fences/gates | County: obstructions encroach on established county road and must be removed | Sayers: he retains rights as owner/driveway owner and may defend obstruction removal | Court: County entitled to relief because prior adjudication established road status |
| Whether newly discovered facts permit collateral attack on final judgment | County: final judgment precludes collateral attack | Sayers: newly discovered facts render original judgment erroneous | Court: new facts do not avoid res judicata; final judgment binding |
| Whether summary disposition under settled law was appropriate | County: law clearly supports preclusion and summary judgment | Sayers: factual dispute persists requiring further proceedings | Court: law is settled; memorandum opinion affirms summary judgment |
Key Cases Cited
- Denturist Ass’n of Mont. v. State, 372 P.3d 466 (Mont. 2016) (res judicata and finality of judgments principles)
- Baltrusch v. Baltrusch, 130 P.3d 1267 (Mont. 2006) (res judicata prevents piecemeal collateral attacks)
- Sayers v. Chouteau County, 297 P.3d 312 (Mont. 2013) (prior appeal affirming county road status)