Montana State Fund v. Simms
2012 MT 22
| Mont. | 2012Background
- Simms was injured at work and MSF provided workers’ compensation benefits; he was later found permanently disabled with CRPS.
- MSF settled in 2006 for $610,000 but continued medical benefits related to the injury.
- MSF’s Fraud Unit, including the SIU, videotaped Simms in public as part of disability status verification and potential fraud investigations.
- MSF sought CCJI from SIU; in 2007 the District Court ordered dissemination of videos to MSF for use in ongoing proceedings.
- MSF filed a petition under § 44-5-303, MCA to disseminate CCJI; Simms challenged MSF’s standing and the court’s balancing analysis.
- District Court granted MSF’s petition in June 2011, allowing dissemination for use in the related WC case; Simms appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did MSF have standing to seek dissemination? | Simms | MSF | No error; MSF had standing under § 44-5-303(6). |
| Did the court properly balance privacy against disclosure merits? | Simms | MSF | District Court properly balanced interests; disclosure legitimate. |
Key Cases Cited
- Jefferson Co. v. Mont. Std., 2003 MT 304 (2003 MT) (two-part privacy vs. public disclosure balancing test)
- Bozeman Daily Chronicle v. City of Bozeman Police Dept., 260 Mont. 218 (1993 MT) (burden-shifting framework in disclosure determinations)
- In re Adoption of S.R.T., 2011 MT 219 (2011 MT) (statutory interpretation of state court procedures)
- Grizzly Sec. Armored Express, Inc. v. Armored Group, LLC, 2011 MT 128 (2011 MT) (standing and de novo review of district court rulings)
- United States v. Jones, 132 S. Ct. 945 (2012) (GPS monitoring and privacy expectations; Fourth Amendment)