## Facts

- Russell E. Meech, a former employee of Hillhaven West, Inc., sued his employer and an individual defendant after his employment ended.
- Meech asserted common-law claims including wrongful termination, breach of the implied covenant of good faith and fair dealing, and intentional/negligent infliction of emotional distress, and sought punitive damages.
- Defendants argued that the Montana Wrongful Discharge from Employment Act (WDEA) provides the exclusive remedy for covered wrongful-discharge claims, displacing common-law theories and limiting damages.
- Meech contended the WDEA was unconstitutional under Article II, § 16 of the Montana Constitution (open courts/“full legal redress”) and under equal protection principles, focusing on the Act’s bar on noneconomic damages and limits on punitive damages.
- The United States District Court for the District of Montana certified constitutional questions to the Montana Supreme Court regarding Article II, § 16 and the WDEA’s remedial limits.

## Issues

1. Whether Article II, § 16 creates a fundamental right to “full legal redress” that prevents the legislature from replacing common-law wrongful-discharge actions with an exclusive statutory remedy.
2. Whether the WDEA’s prohibition of noneconomic damages and its restrictions on punitive damages violate Article II, § 16 or equal protection.

## Decision

- The court answered both certified questions “No” and upheld the WDEA against the Article II, § 16 challenges.
- Article II, § 16 was construed primarily as guaranteeing access to courts for recognized causes of action, not as entitling plaintiffs to particular common-law remedies or a specific measure of damages.
- Because no fundamental right was implicated, the court applied rational-basis review and held the WDEA’s exclusive-remedy structure and damages limits rationally related to legitimate legislative objectives.
- The court overruled prior Montana decisions to the extent they treated Article II, § 16 as guaranteeing a fundamental right to “full legal redress” that constrained legislative authority to modify remedies.

## Legal Principles

- Article II, § 16 guarantees meaningful access to the courts for causes of action recognized by law, but does not constitutionalize any particular common-law cause of action, remedial theory, or amount/type of damages.
- The legislature may modify or abolish common-law causes of action and may limit available damages, so long as the statutory scheme satisfies rational-basis review.
- Under rational-basis review, remedy-limiting statutes may be upheld where the legislature pursues legitimate goals such as reducing liability uncertainty and promoting economic stability.
- The WDEA operates as an exclusive remedy for covered wrongful-discharge disputes and may lawfully preclude noneconomic damages and restrict punitive damages to specified conditions.

## Conclusion

The Montana Supreme Court held that the WDEA’s exclusive remedy and its limits on noneconomic and punitive damages are constitutional because Article II, § 16 protects court access rather than guaranteeing any particular common-law remedy or “full” measure of damages, and the Act’s restrictions satisfy rational-basis review.


Meech v. Hillhaven W., Inc., 238 Mont. 21, 776 P.2d 488 (Mont. 1989)