State v. Wilson

Summary

The Montana Supreme Court reversed the First Judicial District Court's grant of summary judgment in favor of the State of Montana in an interpleader action. The State, as the alleged tortfeasor through its employee Jose Ruiz, had filed a petition in interpleader and complaint for declaratory relief seeking to deposit $750,000 into the court registry, obtain a release from all liability, and be dismissed with prejudice, after Thomas Wilson (as Personal Representative of Haley Wilson's Estate and as Conservator of minor child J.M.W.) rejected the State's pre-litigation settlement offer. The Court held the State improperly invoked interpleader because it is the alleged tortfeasor rather than a disinterested stakeholder, and because the Estate's and J.M.W.'s claims are not adverse to one another. The Court further declined to reach the constitutionality of the statutory damages cap under § 2-9-108, MCA, finding the issue unripe and advisory because no lawsuit had been filed, no verdict obtained, and no damages exceeding the cap had been determined. Justice Beth Baker dissented, joined by Chief Justice Cory J. Swanson, arguing the interpleader was proper and the constitutional question justiciable.