Jade Landers v. Custer County, Custer County Sheriff's Department, Sheriff Brandon Kelm in his official and individual capacity

Summary

The document is a United States magistrate judge’s Findings and Recommendations concerning Defendants’ motion for summary judgment in Jade Landers’s action arising from the termination of his employment as a Custer County deputy sheriff. The court recommends denying summary judgment on Landers’s civil-rights and Montana constitutional claims because the related administrative proceedings had not been upheld on judicial review, but recommends granting summary judgment on his infliction-of-emotional-distress and negligence claims. The document is dated December 19, 2025, and advises the parties of their right to object.

Holdings

1. The uncompleted state-court review of the Human Rights proceeding meant that the administrative decision had not been upheld on judicial review and therefore had not acquired preclusive effect under Montana law. Summary judgment on Counts I through III was properly recommended for denial on res judicata grounds.
2. Landers did not present evidence from which serious or severe compensable emotional distress could be found. Summary judgment was therefore recommended for Defendants on Count III.
3. Summary judgment was recommended for Defendants on Count IV because Landers did not contest dismissal of his negligence claim.

Questions Presented

1. Whether the pending Montana Human Rights administrative proceeding barred Counts I through III under res judicata.
2. Whether Landers presented sufficient evidence of serious or severe emotional distress to maintain his Montana infliction-of-emotional-distress claim.
3. Whether Defendants were entitled to summary judgment on Landers's negligence claim when Landers did not contest dismissal of that claim.

Disposition

other