Stokes v. Montana Thirteenth Judicial District Court

Summary

The Montana Supreme Court granted supervisory control and reversed a district court order requiring the plaintiff to choose between negligence and strict-liability claims involving an allegedly defective vehicle occupant-restraint system. The court held that Montana Code § 61-13-106 does not bar evidence of seatbelt use or nonuse when the alleged injury results from the condition or design of the restraint system, regardless of whether the claim sounds in negligence or strict liability. The court directed the district court to provide a limiting instruction restricting the evidence to consideration of the restraint system's condition and crashworthiness.

Holdings

1. Supervisory control was appropriate because the district court was proceeding on a purely legal question under a potential mistake of law, the ruling would significantly affect the course of litigation, and ordinary appeal would be an inadequate remedy.
2. Section 61-13-106, MCA, does not prohibit evidence of seatbelt use or nonuse when the plaintiff alleges that injuries resulted from a defect in the vehicle's occupant-restraint system, whether the claim sounds in negligence or strict liability.
3. When a plaintiff's restraint-system claim is combined with a claim against another driver, the trial court must give a limiting instruction restricting the use of seatbelt evidence to the condition or crashworthiness of the occupant-restraint system and prohibiting its use to attribute comparative negligence, contributory fault, or causation of injury to the plaintiff's seatbelt use or nonuse.

Questions Presented

1. Whether the Montana Supreme Court should exercise supervisory control over the district court's interlocutory evidentiary ruling.
2. Whether Montana Code Annotated § 61-13-106 bars evidence of seatbelt use or nonuse when the plaintiff alleges that injuries resulted from a defect in the vehicle's occupant-restraint system.
3. Whether such seatbelt evidence may be admitted in combined negligence and strict-products-liability litigation subject to a limiting instruction.

Disposition

reversed_and_remanded