Putnam v. C. Montana Med. Ctr, 460 P.3d 419

Elizabeth Putnam served as CMMC’s In-Home Care Services Director (2004–2017), supervising ~36 employees and overseeing billing and collections.
Beginning in 2006–2007 Putnam received repeated notices (including a 2007 written warning) about overdue employee evaluations and high accounts receivable (AR).
AR worsened over time (≈$311k in 2015 to ≈$809k by May 2017); AR Days remained well above the goal (over 100; last full month 128.66).
CMMC management repeatedly emailed AR analyses (2014–2017) and placed Putnam on a Performance Action Plan in late June/July 2017 to cure evaluation delinquency by July 31, 2017; Putnam missed meetings and did not read minutes.
On July 14, 2017 CMMC terminated Putnam for unsatisfactory performance, neglecting duties, discourtesy, and intentional discrimination (the latter two were not relied on at summary judgment). Putnam sued under Montana’s Wrongful Discharge from Employment Act (WDEA); the district court granted summary judgment for CMMC and denied Putnam’s partial summary judgment. The Montana Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CMMC had "good cause" to terminate a managerial employee under the WDEA	Putnam: CMMC’s stated reasons were false, arbitrary, and pretextual; she was working to resolve AR and had been told she had until July 31 to finish evaluations	CMMC: Loss of trust/confidence in a managerial employee and documented performance failures constitute legitimate business reasons/good cause	Held: Affirmed for CMMC — documented failures on AR and evaluations constituted legitimate business reasons; Putnam did not raise evidence showing reasons were false or pretextual
Whether CMMC violated its written personnel policies by terminating without required written warnings	Putnam: Handbook requires a written warning before termination and prior written warning was too remote (2007) or missing for some listed grounds	CMMC: Handbook allows skipping steps and immediate discharge in some cases; Putnam had at least a 2007 written warning and additional written notices in evaluations/emails	Held: Affirmed for CMMC — handbook expressly permits skipping disciplinary steps; prior written warning(s) and other notices satisfy policy

Buck v. Billings Mont. Chevrolet, Inc., 811 P.2d 537 (Mont. 1991) (employer practice of installing its trusted manager is a legitimate business reason supporting termination)
Bird v. Cascade Cnty., 386 P.3d 602 (Mont. 2016) (loss of trust in a managerial employee handling sensitive matters can constitute good cause)
Moe v. Butte-Silver Bow Cnty., 371 P.3d 415 (Mont. 2016) (managerial-employee termination may present factual issues where employee rebuts allegations in detail)
Sullivan v. Cont'l Constr. of Mont., LLC, 299 P.3d 832 (Mont. 2013) (courts should defer to employer discretion for managerial positions absent pretext)
McConkey v. Flathead Elec. Coop., 125 P.3d 1121 (Mont. 2005) (summary judgment proper where employer shows job-related grounds and employee fails to show pretext)
Becker v. Rosebud Operating Servs., 191 P.3d 435 (Mont. 2008) (summary judgment is appropriate where employer establishes good cause and employee offers only speculation)
Davis v. State, 357 P.3d 320 (Mont. 2015) (legitimate business reason must have logical relationship to needs of the business)