Siebken v. Voderberg, 2012 MT 291

This is Montana Supreme Court decision Siebken v. Voderberg (2012) on appeal from a District Court grant of summary judgment.
Siebken, a on-duty law enforcement officer, was injured during a December 11, 2004 altercation at the Federal Reserve Bank in Helena.
Siebken filed a negligence action against Voderberg in March 2009; the District Court granted summary judgment based on a three-year statute of limitations.
Siebken had earlier workers’ compensation claims with noted dates (2005–2006) and disputes over when his injury origin became known.
Medical records and notes (2005–2006) created conflicts about whether the injury was caused by the December 2004 altercation or later gun-belt-related issues.
The Court held that genuine issues of material fact exist regarding accrual timing and remanded for trial, reversing the grant of summary judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the district court err in granting summary judgment on statute of limitations?	Siebken contends accrual was later (May 2006) and timely filed.	Voderberg argues accrual occurred before May 2006, rendering the March 2009 complaint untimely.	No, issues of accrual are disputed; summary judgment reversed.
Is accrual a jury question where conflicting evidence exists on when cause of action accrued?	Siebken asserts material facts about accrual are conflicted and should go to a jury.	Voderberg contends accrual date is determined by undisputed facts.	Yes; accrual is a jury question due to conflicting evidence.
Should the case have been decided on summary judgment given conflicting records?	Summary judgment was premature because facts about discovery and causation were material and disputed.	Court should decide accrual date as a matter of law based on the record.	No; summary judgment was inappropriate; remand for trial.

Nelson v. Nelson, 2002 MT 151 (MT) (jury to resolve accrual timing when evidence conflicts)
Werre v. David, 275 Mont. 376 (MT 1996) (accrual timing contingent on conflicts in evidence)
Renville v. Fredrickson, 2004 MT 324 (MT) (summary judgment standards and de novo review)