Teeter v. Mid-Century Insurance Co.
389 Mont. 407
| Mont. | 2017Background
- On May 30, 2014 Derek Colberg rear‑ended Jennifer Teeter; Colberg (Mid‑Century’s insured) was cited for careless driving and Mid‑Century initially made advance payments for Teeter’s medical bills and lost wages (≈ $53,347.97 through Dec. 2014).
- Mid‑Century requested medical records and an IME; Teeter refused those requests; Mid‑Century obtained a records review by Dr. Lennard Wilson and stopped advance payments in Dec. 2014, concluding continuing care was not causally related to the crash.
- Teeter filed a declaratory judgment action under §§ 33‑18‑201(6) & (13), MCA, seeking payment of medical expenses and wage loss after Dec. 16, 2014.
- During discovery Mid‑Century obtained IMEs: Dr. William Stratford (forensic psychiatry) and Dr. Emily Heid (orthopedics); each opined the ongoing complaints lacked physiological basis or were psychological; Mid‑Century relied on those opinions to dispute causation and damages.
- The District Court granted Teeter summary judgment, finding liability reasonably clear and Teeter’s affidavits/treating providers established causation; the court excluded or discounted Mid‑Century’s doctors as unsworn and lacking foundation and awarded fees/costs to Teeter.
- The Montana Supreme Court reversed: it held the District Court erred in disregarding Mid‑Century’s experts and that a genuine factual dispute exists about causation and damages, making a Ridley declaratory remedy inappropriate; the fee award was vacated and the case remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether summary judgment under Ridley is proper on causation/damages | Teeter: no material factual dispute; her affidavit + treating providers show expenses causally related to the crash | Mid‑Century: expert opinions create objective, reasonable debate over causation and reasonableness of treatments/wage loss | Reversed: disputed material fact exists; summary judgment inappropriate |
| Whether a declaratory (Ridley) action is the proper vehicle | Teeter: declaratory relief appropriate to compel payments where liability and causation are reasonably clear | Mid‑Century: Ridley is improper where causation is genuinely disputed; those issues belong in tort trial | Court: declaratory action is improper when factual disputes exist; leave for tort/jury resolution |
| Admissibility/foundation of Mid‑Century’s expert affidavits | Teeter: experts’ affidavits lacked foundation/weren’t compliant and could be disregarded | Mid‑Century: experts’ affidavits complied with Rule 56 and their foundation (post‑accident records and history) was a factual matter for trial | Court: District Court erred to disregard experts; affidavits met Rule 56(e) and foundation challenges go to cross‑examination/jury weight |
| Fee and cost award to Teeter tied to summary judgment win | Teeter: entitled to fees/costs after prevailing on declaratory judgment | Mid‑Century: appealed summary judgment; award premature if judgment reversed | Court: fee award reversed because summary judgment ruling was reversed |
Key Cases Cited
- Ridley v. Guaranty Nat’l Ins. Co., 951 P.2d 987 (1997) (insurer must pay medical expenses when liability and causal relation are reasonably clear)
- Peterson v. St. Paul Fire & Marine Ins. Co., 238 P.3d 904 (2010) (defines “reasonably clear” standard as akin to clear and convincing; little room for objectively reasonable debate)
- Giambra v. Travelers Indem. Co., 78 P.3d 880 (2003) (Ridley declaratory relief inappropriate where material facts about liability remain disputed)
- Safeco Ins. Co. v. Montana Eighth Judicial Dist. Court, 2 P.3d 834 (2000) (declamatory relief proper only for undisputed causation; disputed facts reserved for trial)
- Beehler v. E. Radiological Assocs. P.C., 289 P.3d 131 (2012) (challenge to expert foundation and application is for cross‑examination and jury determination)