Lenoir v. Sellers

Summary

The Montana Supreme Court affirmed a Yellowstone County District Court judgment in favor of Lois Lenoir on her claim that she was discriminated against because of her political beliefs. The court upheld the partial denial of summary judgment, admission of a collective bargaining agreement, and various evidentiary rulings, while declining to reach inadequately briefed issues and an injunctive-relief claim not preserved by cross-appeal. The decision was designated noncitable precedent and filed as a public document.

Holdings

1. Summary judgment was properly denied because genuine issues of material fact existed regarding whether Lenoir was discriminated against because of her political support for Lenington.
2. The court declined to reach the merits of the County's challenge because the parties inadequately briefed the issue.
3. The District Court did not abuse its discretion by admitting the collective bargaining agreement and allowing related testimony because Lenoir's discrimination claim was factual and did not require interpretation of the agreement.
4. The District Court did not abuse its discretion by permitting Agnes Kovach to testify or by limiting the County's cross-examination of Tony Sellers concerning his psychological evaluation.
5. The court would not address Lenoir's challenge to the denial of injunctive relief because she did not file a cross-appeal.

Questions Presented

1. Whether the District Court erred in partially denying the County's summary judgment motion on Lenoir's Montana political-discrimination claims.
2. Whether the District Court erred by allowing Lenoir to proceed under a continuing-violation theory and permitting coworkers to testify about allegedly discriminatory acts outside the statutory limitations period.
3. Whether admission of the collective bargaining agreement and related testimony was improper or caused § 301 Labor Management Relations Act preemption.
4. Whether the District Court abused its discretion by permitting Kovach and Tony Sellers to testify and by restricting cross-examination concerning Tony Sellers's psychological evaluation.
5. Whether Lenoir could obtain appellate review of the denial of injunctive relief without filing a cross-appeal.

Disposition

affirmed