Watson v. West
2011 MT 57
Mont.2011Background
- Watson, a former business consultant, performed two distinct projects for West: restructuring Circle of Divine Unity (non-profit) and developing Millennia Mind, Inc. (for-profit).
- Watson was to receive a salary and 22% ownership in Millennia Mind; first-year salary later set at $50,000–$60,000, with second-year salary around $120,000; ownership contingent on ongoing compensation expectations.
- Watson developed Millennia Mind’s structure, image, business plan, and strategy during early 2002 under West’s direction and control.
- Mid-2002 West’s representations regarding Millennia Mind’s capitalization and ownership deteriorated; West asserted unpaid work was Seva and refused to issue shares or fund the venture.
- In July 2002, West stopped compensating Watson for Millennia Mind work and revealed no funding or future ownership plan; Watson stopped working and sued West on multiple theories.
- After extensive delays, the District Court in 2008 granted Watson damages (and sanctions for West’s conduct) and later on remand awarded $42,000 for January–July 2002; West appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Remand compliance accuracy | Watson | West | District Court complied with remand instructions |
| Subject-matter jurisdiction for 2002 damages period | Watson | West | District Court had jurisdiction; no error |
| Due process notice for Millennia Mind damages | Watson | West | Watson reasonably notified; no due process violation |
| Reasonableness of $42,000 damages | Watson | West | Damages supported by substantial evidence; reasonable |
Key Cases Cited
- Haines Pipeline Constr. v. Montana Power Co., 265 Mont. 282, 876 P.2d 632 (Mont. 1994) (remand conformity standards; appellate review of remand guidance)
- In re Marriage of Pfeifer, 291 Mont. 23, 965 P.2d 895 (Mont. 1998) (scope of remand and de novo review on damages)
- Watson v. West (Watson I), 353 Mont. 120, 218 P.3d 1227 (Mont. 2009) (remand for reasonable and non-speculative damages; prior findings)
- Steab v. Luna, 356 Mont. 372, 233 P.3d 351 (Mont. 2010) (due process and notice; constitutional concerns)
- Lorang v. Fortis Ins. Co., 345 Mont. 12, 192 P.3d 186 (Mont. 2008) (subject-matter jurisdiction defined; authority to hear civil matters)