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Keywords

lawsuitstatutetrialmotionsummary judgmentcivil rightsstatute of limitationsgood faith
tortplaintiffdefendantdamagesliabilityappealmotionsummary judgmentcorporationcivil rightsmotion for summary judgment

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Sacco v. High Country Independent Press, Inc., 271 Mont. 209, 896 P.2d 411, 63 USLW 2768, 10 IER Cases 1041

Facts

Dianne Poynter Sacco was employed as a photographer/reporter at the High Country Independent Press in Belgrade, Montana, until she left her position on October 19, 1989. After her departure, the Sorlies, who owned the newspaper, accused her of stealing photographic materials, leading to a criminal complaint filed by Sergeant Ricky Dighans of the Belgrade Police Department. The charges against Sacco were eventually dismissed due to the statute of limitations, prompting her to file a lawsuit against the Sorlies, HCIP, and Dighans for various claims including malicious prosecution and defamation.

The plaintiff, Dianne Poynter Sacco (Sacco) was employed at the High Country Independent Press newspaper in Belgrade, Montana, as a photographer/reporter. She left her position on October 19, 1989. High Country Independent Press, Inc. (HCIP), a corporation, owns the newspaper and Devon and Glenn Sorlie (Sorlies) are the officers and stockholders of HCIP. After Sacco left the employ of HCIP, the Sorlies made allegations to the Belgrade Police that Sacco had stolen proof sheets and photographs from the HCIP offices.

Issue

Did the District Court err in granting summary judgment on Sacco's claims of civil rights violations, negligent infliction of emotional distress, intentional infliction of emotional distress, defamation, and malicious prosecution?

The following are issues on appeal: I. Did the District Court err by granting Dighans' motion for summary judgment with respect to Sacco's claim that Dighans violated Sacco's civil rights under 42 U.S.C. § 1983 ? II. Did the District Court err by granting Dighans' motion for summary judgment on the issue of negligent infliction of emotional distress? III. Did the District Court err by granting the Sorlies', High Country Independent Press (HCIP's) and Dighans' motions for summary judgment on the issue of intentional infliction of emotional distress? IV. Did the District Court err by granting the Sorlies' and HCIP's motion for summary judgment on the issue of defamation? V. Did the District Court err by granting the Sorlies', Dighans' and HCIP's motions for summary judgment on the issue of malicious prosecution?

Rule

The court applied the principles of qualified immunity, the existence of independent causes of action for emotional distress, and the standards for determining probable cause in criminal complaints.

Under Harlow v. Fitzgerald (1982), 457 U.S. 800, 102 S.Ct. 2727, 73 L.Ed.2d 396, government officials performing discretionary functions are shielded from liability for civil damages only where their conduct does not violate clearly established statutory or constitutional rights of which a reasonable person would have knowledge.

Analysis

The Supreme Court found that the criminal complaint against Sacco did not provide sufficient factual basis to establish probable cause, thus negating Dighans' claim to qualified immunity. The court also recognized that both negligent and intentional infliction of emotional distress could stand as independent claims under Montana law. The court noted that the Sorlies' statements to the police were not automatically privileged and that there were unresolved questions regarding their good faith in making those statements.

We conclude that the Notice to Appear and Complaint does not set forth sufficient facts which, in combination with Judge Smith's examination of Dighans, satisfy the statutory requirement that it appear 'from the contents of the [written] complaint and the examination [on oath] of the complainant and other witnesses, if any, that there is probable cause to believe that the person against whom the complaint was made has committed an offense.'

Conclusion

The Supreme Court reversed the District Court's summary judgment and remanded the case for trial, indicating that there were genuine issues of material fact that needed to be resolved.

Accordingly, we hold that the District Court erred as a matter of law in granting Dighans' summary judgment motion on Sacco's 42 U.S.C. § 1983 claim, and we remand for further proceedings.

Who won?

The Supreme Court ruled in favor of Sacco by reversing the summary judgment, allowing her claims to proceed to trial based on the lack of probable cause for the criminal complaint and the recognition of emotional distress as an independent cause of action.

Sacco alleged that defendant Dighans committed violations of her civil rights under 42 U.S.C. § 1983. She also alleged that Dighans committed the tort of negligent infliction of emotional distress.

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