Meech v. Hillhaven West, Inc.

Russell Meech (plaintiff) worked for Hillhaven West, Inc. (Hillhaven) (defendant). After Meech was terminated, he sued Hillhaven in federal district court for wrongful termination. Meech also sued for negligent or intentional infliction of emotional distress and for violation of the implied covenant of good faith and fair dealing. In addition, Meech sought punitive damages for Hillhaven’s alleged misconduct. Hillhaven sought dismissal of Meech’s claims on the ground that the Montana Wrongful Discharge from Employment Act (the act) had prohibited these common-law claims in relation to wrongful discharge and limited noneconomic damages to cases of actual fraud or malice. Legislators had sought to protect Montana’s economic interests by limiting employer liability for common-law judgments in wrongful-discharge cases that could be so large as to cause new employers not to come to Montana. The act had preempted the former common-law remedies and provided its own exclusive remedy, with some exceptions. For example, the act did not hinder claims under federal or state statutes, and union employees and other employees with written contracts with a specific duration were exempt. All other employees were subject to the act’s exclusive procedure, which limited recovery to lost wages and fringe benefits for a period of four years, the amount of time by which a claimant could find a comparable position. In response to Hillhaven’s move for dismissal, Meech argued that the act violated his fundamental right to a full legal remedy under the Montana constitution and violated equal protection by creating classes based on the remedies available in the absence of a legitimate state interest. Claimants seeking four years or less of lost wages or not seeking noneconomic damages were in a different class from claimants seeking more than four years of lost wages or noneconomic damages, who were prevented from doing so by the act. Hillhaven countered that the act did not violate Meech’s fundamental right to a full legal remedy, because the constitution only mandated access to courts to pursue available remedies. Hillhaven argued that the act did not violate equal protection, because the legislature had the authority to remove common-law remedies in pursuit of a legitimate state interest. The United States District Court for the District of Montana certified two questions to the Montana Supreme Court regarding whether the act transgressed fundamental rights to full legal remedies under the Montana constitution and whether the elimination of punitive damages and noneconomic damages transgressed fundamental rights to full legal remedies.