Harris Estate v. Reilly

Summary

The Montana Supreme Court affirmed the jury’s award of compensatory and punitive damages to the Estate, affirmed the district court’s denial of treble damages and attorney‑fees, but reversed and remanded on the sanction issue, holding that the district court abused its discretion by dismissing the plaintiff’s complaint without imposing sanctions. The Court explained that the late‑filed dismissal, extensive preparation by the Estate, and the plaintiff’s misrepresentation required sanctions under Rule 41(a)(2).