Teeter v. Mid-Century Insurance, 2017 MT 292

On May 30, 2014 Derek Colberg rear-ended Jennifer Teeter; Colberg (insured by Mid‑Century) was cited for careless driving and Mid‑Century accepted liability and made advance payments for Teeter’s medical bills and lost wages through Dec. 16, 2014 (about $53,348).
Mid‑Century sought past medical records and an IME; Teeter initially refused. After a records review (Dr. Lennard Wilson) Mid‑Century stopped advance payments concluding later expenses were not causally related to the crash.
Teeter filed a declaratory action seeking payment of medical expenses and lost wages incurred after Dec. 16, 2014. During discovery Mid‑Century obtained three IMEs/reports (Drs. Stratford, Heid, Wilson) concluding psychological/ chronic pain explanations and disputing causal relation and reasonableness of ongoing treatment and wage loss.
The District Court granted Teeter summary judgment under §§ 33‑18‑201(6) & (13), MCA, concluding liability and causation were reasonably clear and rejecting Mid‑Century’s doctors’ affidavits as noncompliant and lacking foundation; the court awarded Teeter unpaid medicals, lost wages, mileage, fees and costs.
The Montana Supreme Court reversed: it held the District Court erred in disregarding Mid‑Century’s expert affidavits, and that reasonable, objective debate about causation/damages remained — making a Ridley declaratory action inappropriate; case remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the District Court properly granted summary judgment under §§ 33‑18‑201(6) & (13), MCA, concluding no genuine dispute of material fact exists as to causation and damages	Teeter: liability and causal relation of post‑Dec.16 medical expenses and wage loss are reasonably clear; declaratory relief is appropriate	Mid‑Century: experts’ opinions create objective, reasonable debate about causal connection and reasonableness of expenses/wage loss; disputed facts should go to a jury in tort	Reversed: disputed material facts exist as to causation/damages; the District Court erred in excluding defense experts and in granting summary judgment and fees; remanded

Ridley v. Guaranty Nat’l Ins. Co., 951 P.2d 987 (Mont. 1997) (establishes insurer must pay medical expenses when liability is reasonably clear but insurer may dispute causal relation)
Peterson v. St. Paul Fire & Marine Ins. Co., 238 P.3d 904 (Mont. 2010) (defines "reasonably clear" standard as akin to clear-and-convincing; leaves little room for objectively reasonable debate)
Giambra v. Travelers Indem. Co., 78 P.3d 880 (Mont. 2003) (declaratory Ridley action inappropriate where factual disputes about liability exist and should be resolved in negligence action)
Safeco Ins. Co. v. Montana Eighth Judicial Dist. Court, 2 P.3d 834 (Mont. 2000) (upholds declaratory relief where causation and liability are not materially disputed; reserves disputed damages for trial)
Beehler v. E. Radiological Assocs. P.C., 289 P.3d 131 (Mont. 2012) (expert foundation and reliability challenges are ordinarily addressed by cross‑examination and are questions of fact for the jury)