Northern Cheyenne Tribe v. Roman Catholic Church
2013 MT 24
Mont.2013Background
- NCT appeals a district court summary judgment ruling related to St. Labre fundraising and disbursement practices.
- Dispute centers on whether St. Labre’s fundraising created unjust enrichment and a constructive trust for NCT.
- NCT alleges post-2002 and pre-2002 fundraising targeted at NCT funds, with potential equitable redistribution.
- District Court granted summary judgment on unjust enrichment, constructive trust, and several contract/fraud-like claims; granted judgment on pleadings on cultural genocide and constitutional claims.
- The Montana Supreme Court reverses in part and remands for further factual development on unjust enrichment and constructive trust; otherwise affirms other claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court properly granted summary judgment on unjust enrichment/constructive trust for post-2002 fundraising | NCT asserts unjust enrichment via a constructive trust on funds raised by St. Labre | St. Labre contends no misconduct or adverse interest proven; no basis for constructive trust | Reversed and remanded for further fact-finding on accrual and adverse-interest issues |
| Whether the district court properly granted summary judgment on unjust enrichment/constructive trust for pre-2002 fundraising | NCT seeks constructive trust due to long-running fundraising tied to NCT’s plight | No clear accrual evidence; limitations analysis contested | Remanded to assess accrual date and evidence of adverse-interest awareness |
| Whether the district court properly granted summary judgment on contract, negligent misrepresentation, fraud, and wrongful conversion | NCT pressed express/implied contract and related claims | Lack of admissible personal-knowledge evidence; no triable contract basis | Affirmed summary judgment on these contract/related claims (Hiebert critique) |
Key Cases Cited
- Ragland v. Sheehan, 256 Mont. 322 (Mont. 1993) (unjust enrichment requires misconduct for implied contracts (pre-Trust Code))
- Peterson v. Randolph, 239 Mont. 1 (Mont. 1989) (implied contract analyses; bounds of unjust enrichment)
- Brown v. Thorton, 150 Mont. 150 (Mont. 1967) (misconduct element in lien-related actions (historical context))
- Butler v. Peters, 62 Mont. 381 (Mont. 1922) (attachment statutes; corporate-director liability context)
- McDermott, 2002 MT 164 (Mont. 2002) (trust code eliminated requirement of wrongdoing for constructive trusts)
- Opp v. Boggs, 121 Mont. 131 (Mont. 1948) (accrual of constructive trusts when adverse interest arises)
- Eckart v. Hubbard, 184 Mont. 320 (Mont. 1979) (constructive trusts when equity requires; no need to show intent)
- Simmonds v. Simmonds, 380 N.E.2d 189 (N.Y. 1978) (unjust enrichment without wrongful act; restitution principle)
- Rawlings v. Rawlings, 240 P.3d 754 (Utah 2010) (unjust enrichment supports constructive trust absent underlying wrongdoing)
- Lawrence v. Clepper, 263 Mont. 45 (Mont. 1993) (constructive trust as equitable remedy for unjust enrichment)
- Riv. v. Dobbs (Dobbs Law of Remedies), Dobbs, Law of Remedies () (restatement-based views on unjust enrichment and restitution)