Miller v. State Fund
2021 MT 187N
| Mont. | 2021Background
- In 1983 Michael L. Miller suffered a work-related closed-head injury; Montana State Fund accepted liability.
- In 1988 Miller entered a compromise settlement for total disability benefits: a lump sum of $132,145.10 to support self-employment; the Department of Labor and Industry approved the 1988 Settlement.
- Miller sued in 1998 seeking rescission of the 1988 Settlement for mutual mistake; the Workers’ Compensation Court dismissed under the statute of limitations and this Court affirmed.
- Miller filed a second petition in 2000 raising mistake-of-law and mistake-of-fact theories; the Workers’ Compensation Court applied res judicata and the parties later entered a 2001 Settlement resolving medical benefits and closing all claims for $67,500.24, with a 2001 final order.
- In 2020 Miller filed a third petition seeking rescission of the 1988 Settlement and the 2001 final order; the Workers’ Compensation Court granted summary judgment for State Fund (res judicata and untimeliness/meritless Rule 60 arguments). This appeal affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Miller may relitigate and rescind the 1988 Settlement | Miller argued the court failed to properly consider rescission of the 1988 Settlement and his mistake claims | State Fund argued res judicata and prior rulings bar relitigation of issues related to the 1988 Settlement | Court held res judicata bars Miller’s claims about the 1988 Settlement; summary judgment for State Fund affirmed |
| Whether Miller may reopen or rescind the 2001 final order via Rule 60(d) / otherwise | Miller argued Rule 60(d) or similar relief allows setting aside the 2001 final order | State Fund argued Rule 60(d) cannot be used to relitigate decided issues; Rule 60(b) claims were untimely and Miller presented no new, valid grounds for relief | Court held Miller’s attempt to set aside the 2001 final order was untimely, lacked legal basis, and Rule 60(d) does not permit further review of issues already decided; summary judgment affirmed |
Key Cases Cited
- Baltrusch v. Baltrusch, 130 P.3d 1267 (Mont. 2006) (res judicata/claim preclusion bars relitigation once final judgment entered)
- Bird v. Cascade County, 386 P.3d 602 (Mont. 2016) (standard for reviewing summary judgment)
- Abfalder v. Nationwide Mut. Fire Ins. Co., 75 P.3d 1246 (Mont. 2003) (standard of review for workers’ compensation findings of fact and conclusions of law)
- McConkey v. Flathead Elec. Coop., 125 P.3d 1121 (Mont. 2005) (opposing party must present material and substantial evidence to create genuine issues of fact on summary judgment)
- Holtman v. 4-G’s Plumbing and Heating, 872 P.2d 318 (Mont. 1994) (res judicata bars relitigation of an entire cause once final judgment is entered)