Walters v. FLATHEAD CONCRETE PRODUCTS, INC.
2011 MT 45
| Mont. | 2011Background
- Tim Walters died 12/14/2006 after being run over by a forklift at work; he was 42, unmarried, with no legal dependents.
- Walters is Tim's mother, who pursued survivorship and wrongful death claims on Tim's behalf.
- Flathead Concrete Products (FCP) carried workers' compensation through MCCF, which paid Tim's medical bills, burial costs ($4,000), and a $3,000 nondependent-parent benefit to Walters.
- Tim had no dependents under the statutory dependency definitions, so Walters received the §39-71-721(4) lump-sum as a nondependent.
- District court granted summary judgment for FCP citing the exclusive remedy rule §39-71-411, MCA; Walters challenged the constitutionality of §39-71-411 and §39-71-721(4).
- Montana Supreme Court reviewed de novo and affirmed the district court’s rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Walters’ claims are barred by the exclusive remedy provision. | Walters argues quid pro quo may be lacking; exclusive remedy unconstitutional. | FCP contends Tim's injury was covered and the exclusive remedy applies. | Yes, the exclusive remedy bars the claims. |
| Whether §§39-71-411 and 39-71-721(4) violate substantive due process or equal protection. | Walters contends the quid pro quo is unfair/insufficient, making the statute unconstitutional. | FCP argues the scheme serves legitimate governmental objectives and is rational. | No; the provisions are rational and satisfy substantive due process. |
Key Cases Cited
- State Farm Fire & Cas. Co. v. Bush Hog, LLC, 353 Mont. 173 (MT 2009) (recognizes exclusive remedy quid pro quo rationale)
- Satterlee v. Lumberman's Mut. Cas. Co., 222 P.3d 566 ( mt 2009) (develops substantive due process and quid pro quo framework)
- Stratemeyer v. Lincoln Co. (Stratemeyer II), 915 P.2d 175 ( MT 1996) (limits of quid pro quo for non-covered injuries)
- Maney v. La. Pac. Corp., 15 P.3d 962 ( MT 2000) (exclusive remedy applies where injury is covered and there is some recovery possibility)
- Satterlee v. Lumberman's Mut. Cas. Co., 353 Mont. 265 ( MT 2009) (reiterates quid pro quo and due process analysis)
- Germann v. Stephens, 137 P.3d 545 ( MT 2006) (discusses property interest threshold in due process claims)
- Raisler v. Burlington Northern R.R. Co., 717 P.2d 541 ( MT 1985) (substantive due process standard guidance)
- Taylor v. Southeast-Harrison Western Corp., 694 P.2d 1160 ( Alaska 1985) (equal protection context for dependents vs. non-dependents)