Roedocker v. Farstad Oil, Inc., 1:16-cv-00029

Richard Roedocker was Billings branch manager for Farstad Oil (part of SPF Energy) and had worked there since 1991; Parkland acquired SPF in 2014 and Merv Carter became Roedocker's supervisor.
On January 12, 2015, after a managers’ teleconference, Roedocker sent a text to co-manager Roger Pelzer calling another manager (Lori Thom) a "c**t"; Pelzer had earlier sent an angry/profane text about Thom as well.
Profanity among managers was admitted to be common at Farstad; Pelzer was reprimanded but not terminated.
HR learned of Roedocker’s message months later; no investigation occurred for about four months, and an intervening performance review rated Roedocker as "meets expectations."
Carter terminated Roedocker on May 21, 2015, citing the offensive text and communication issues; Roedocker sued under Montana’s Wrongful Discharge from Employment Act.
Magistrate Judge Cavan recommended denying Farstad’s summary judgment motion; the district court adopted most of the recommendation but disagreed that the text indisputably provided a legitimate business reason for termination and denied summary judgment in full.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Farstad had "good cause" (a legitimate business reason) to terminate Roedocker under Montana law	Roedocker argues termination was wrongful because the stated reason was pretextual: profanity was common, a co-manager who used similar language was not fired, and the employer delayed investigation for months	Farstad argues the offensive text by a branch manager violated its code of conduct and provided a reasonable, job‑related ground for dismissal	Court held a genuine issue of material fact exists whether Farstad’s reason was legitimate or arbitrary; summary judgment denied

United States v. Syrax, 235 F.3d 422 (9th Cir. 2000) (standard for reviewing magistrate judge recommendations when no objections filed)
Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (U.S. 1986) (summary judgment standards; genuine issue and materiality)
Reeves v. Sanderson Plumbing Prods., 530 U.S. 133 (U.S. 2000) (courts must not weigh credibility on summary judgment)
Samper v. Providence St. Vincent Medical Center, 675 F.3d 1233 (9th Cir. 2012) (court must consider the record as a whole in employment cases)
Becker v. Rosebud Operating Servs., Inc., 191 P.3d 435 (Mont. 2008) (definition and analysis of "legitimate business reason" under Montana law)
Kestell v. Heritage Health Care Corp., 858 P.2d 3 (Mont. 1993) (employer discretion balanced against employee's right to employment)
Johnson v. Costco Wholesale, 152 P.3d 727 (Mont. 2007) (employee may show given reason is not good cause or is pretext)
Davis v. State Dep't of Pub. Health & Human Servs., 357 P.3d 320 (Mont. 2015) (undisputed facts providing good cause defeat wrongful discharge claim)
Vettel-Becker v. Deaconess Med. Ctr. of Billings, Inc., 177 P.3d 1034 (Mont. 2008) (all reasonable inferences drawn for nonmoving party on summary judgment)