538 P.3d 394
Mont.2023Background
- A Blaine County deputy arrested A.J. Longsoldier and transported him to the Hill County Detention Center, where Blaine housed arrestees under an intercounty agreement.
- Longsoldier developed severe alcohol-withdrawal symptoms, was taken to Northern Montana Hospital twice in late November 2009, and died from delirium tremens on November 23, 2009.
- The Estate first pursued a discrimination claim with the Montana Human Rights Bureau (MHRB); the Hearing Officer found no unlawful discrimination, and this Court affirmed that ruling in Stricker I.
- The Estate separately sued Hill and Blaine Counties for negligence (and originally the State and the Hospital); earlier district-court rulings found Hill vicariously liable for the Hospital’s negligence (and Blaine not liable), but this Court reversed Hill’s vicarious liability in Stricker II.
- On remand the district court granted summary judgment to Hill County based on collateral estoppel from the MHRB proceedings and entered judgment for Blaine County as a matter of law (finding Hill had assumed custody duties); the Estate’s cross-motion for partial summary judgment was denied.
- On this appeal the Montana Supreme Court reversed the district court’s issue-preclusion ruling as to Hill and reversed the no-duty ruling as to Blaine; it affirmed denial of the Estate’s partial summary-judgment motion and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether issue preclusion (collateral estoppel) bars the Estate’s negligence claims against Hill County | Estate: MHRB lacked authority to decide negligence; the MHRB focused on discriminatory animus, not negligence, so preclusion is improper | Hill: MHRB adjudication decided the determinative facts about the Counties’ actions and thus precludes re-litigation | Court: Reversed — issue preclusion does not bar negligence claims because MHRB lacked authority over negligence and its findings on discrimination were not essential to a negligence judgment |
| Whether Blaine County owed a duty to Longsoldier (entitling Blaine to summary judgment) | Estate: Blaine retained a limited duty (transportation/communications); its dispatcher’s communication about the hospital’s assessment was a negligent act that could have caused delay in care | Blaine: The intercounty agreement transferred custody and care to Hill; Blaine had no duty regarding detention/medical care and earlier rulings foreclose relitigation | Court: Reversed the district court — Blaine may have a narrow duty (transport/communications); summary judgment for Blaine on duty was error |
| Whether the District Court erred in denying the Estate’s motion for partial summary judgment on liability | Estate: Presented unrebutted expert evidence showing Hill and/or Blaine breached duties; therefore partial summary judgment should have been granted | Counties: Disputed facts and expert evidence create genuine issues; summary judgment inappropriate | Court: Affirmed — genuine issues of material fact remain; denial of Estate’s partial summary judgment stands |
Key Cases Cited
- Blaine Cty. v. Stricker, 394 P.3d 159 (Mont. 2017) (Stricker I) (affirming administrative finding of no discrimination)
- Stricker v. Blaine Cty., 453 P.3d 897 (Mont. 2019) (Stricker II) (reversing district court’s vicarious liability finding as to Hill County)
- Baltrusch v. Baltrusch, 130 P.3d 1267 (Mont. 2006) (explaining policies and tests for claim and issue preclusion)
- Rooney v. City of Cut Bank, 286 P.3d 241 (Mont. 2012) (holding preclusion applied where agency and court issues were identical and fully litigated)
- McDaniel v. State, 208 P.3d 817 (Mont. 2009) (articulating factors for collateral estoppel and comparing pleadings/evidence to determine issue identity)
- Clark v. McDermott, 518 P.3d 76 (Mont. 2022) (applying preclusion where administrative and court claims were essentially identical)
- Smith v. Johnson, 779 F.3d 867 (8th Cir. 2015) (administrative forum lacking authority on an issue precludes collateral estoppel against later suit asserting that distinct issue)
- Polk v. Yellow Freight Sys., Inc., 801 F.2d 190 (6th Cir. 1986) (administrative body's limited authority means some related tort or statutory claims are not precluded)