Seamster v. Musselshell County Sheriffs Office, 321 P.3d 829

Seamster filed a constructive discharge claim against Musselshell County Sheriff’s Office in 2012.
Sheriff’s Office moved to dismiss, arguing it is not an independent entity subject to suit (Jan 11, 2013).
Seamster sought to amend (Jan 24, 2013) to add Musselshell County as a defendant.
District Court denied leave to amend and dismissed the complaint without prejudice (May 6, 2013).
Seamster appeals, and Montana Supreme Court reverses and remands for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is the district court’s dismissal order appealable?	Seamster argues the order is appealable as a final judgment due to statute of limitations.	Sheriff’s Office contends the order is nonappealable.	Order is appealable
Did the court err in denying leave to amend and dismissing the complaint?	Amendment to substitute the proper party was not futile and should be allowed.	Amending would not cure the defect because the Sheriff’s Office is immune and misjoinder existed.	Court abused discretion; allowed amendment and remanded

Bitterroot Intl. Sys. v. W. Star Trucks, Inc., 336 Mont. 145, 153 P.3d 627 (Mont. 2007) (leave to amend reviewed for abuse of discretion)
H & H Dev., LLC v. Ramlow, 364 Mont. 283, 272 P.3d 657 (Mont. 2012) (relation back under Rule 15(c))
Farmers Union Mut. Ins. Co. v. Bodell, 346 Mont. 414, 187 P.3d 913 (Mont. 2008) (appealability of dismissal without prejudice under special circumstances)
Schoof v. Nesbit, 316 P.3d 831 (Mont. 2014) (equitable tolling in rare circumstances)
Williams v. Zortman Mining, 914 P.2d 971 (Mont. 1996) (savings statute considerations in amended filings)