Davis v. DPHHS, 2015 MT 264

Donna Davis was an attorney in DPHHS Office of Legal Affairs from Aug 2006 until her termination in June 2011.
Beginning in 2010 supervisors received complaints that Davis was rude to coworkers, produced inadequate work, failed to follow supervisors’ instructions, and violated DPHHS policies.
On April 15, 2011 Davis alleged a supervisor verbally assaulted her; she emailed HR and legal on April 19, did not attend two scheduled meetings addressing the dispute, and did not return to work (absence not excused).
Davis filed a grievance on April 28, 2011; the agency denied the grievance after an administrative hearing and the director adopted the denial.
DPHHS terminated Davis June 23, 2011. Davis sued for wrongful discharge (arguing termination lacked good cause and was retaliatory/violated personnel policy).
District Court granted DPHHS’s motions for partial summary judgment on the retaliation/personnel-policy claim and on the good-cause issue; Davis appealed only the good-cause ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether DPHHS was entitled to summary judgment because Davis was terminated for "good cause" under § 39-2-904(1)(b) MCA	Davis disputed many factual assertions and argued material facts are in dispute so summary judgment is improper	DPHHS pointed to undisputed facts (unexcused absences, refusal to attend meetings, workplace disruption, performance problems) that constitute failure to satisfactorily perform and disruption of operations	Affirmed: court held undisputed facts establish statutory good cause (failure to perform and disruption), so summary judgment was proper
Whether Buck (broad employer discretion for sensitive/managerial employees) controlled	Davis argued Buck was misapplied because she was not a "sensitive managerial" employee and thus DPHHS should not get Buck’s broad deference	DPHHS relied on Buck for employer discretion; court found Buck inapplicable because this case turned on statutory grounds (failure to perform/disruption), not the Buck catchall rationale	Court explained Buck was not controlling; outcome rests on statutory good-cause grounds and characterization as managerial was unnecessary

Buck v. Billings Mont. Chevrolet, 248 Mont. 276 (1991) (discusses employer discretion and "legitimate business reason" under wrongful discharge analysis)
Becker v. Rosebud Operating Servs., 345 Mont. 368 (2008) (summary judgment may stand if some undisputed facts independently establish good cause)
McConkey v. Flathead Elec. Coop., 330 Mont. 48 (2005) (courts should avoid micromanaging employer personnel decisions)
Stoican v. Wagner (In re Estate of Lawlor), 378 Mont. 281 (2015) (appellate courts may affirm district court that reached correct result even if reasoning differs)