Montana Supreme Court

D'Hooge v. Cincinnati Ins. Co.

March 31, 20262026 MT 63

Summary

The court held that the pre-2023 version of Montana's insurance-practices statute did not bar a third-party claimant from asserting contract, equitable, or tort claims based on an insurer's handling of a claim. It affirmed summary judgment against the breach-of-contract, promissory-estoppel, and insufficiently pleaded claims, but reversed summary judgment on negligent spoliation and equitable estoppel because factual disputes or inadequate analysis precluded judgment as a matter of law. The case was remanded for further proceedings on those surviving claims.