Difolco v. MT State Hospital

2026 MT 26
CourtMontana Supreme Court
DecidedFebruary 17, 2026
DocketDA 25-0165
StatusPublished
AuthorBaker

This text of 2026 MT 26 (Difolco v. MT State Hospital) is published on Counsel Stack Legal Research, covering Montana Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Difolco v. MT State Hospital, 2026 MT 26 (Mo. 2026).

Opinion

02/17/2026

DA 25-0165 Case Number: DA 25-0165

IN THE SUPREME COURT OF THE STATE OF MONTANA

2026 MT 26

LAUREN DIFOLCO and SHERRY SPEAR,

Petitioners and Appellees,

v.

MONTANA STATE HOSPITAL-DEPARTMENT OF PUBLIC HEALTH AND HUMAN SERVICES,

Respondent and Appellant.

APPEAL FROM: District Court of the Second Judicial District, In and For the County of Butte-Silver Bow, Cause No. DV-24-17 Honorable Kurt Krueger, Presiding Judge

COUNSEL OF RECORD:

For Appellant:

Justin Kraske, Staff Attorney, Department of Social and Health Services, Helena, Montana

For Appellees:

Adam Cook, Everett Cook Law, Anaconda, Montana

Submitted on Briefs: December 3, 2025

Decided: February 17, 2026

Filed:

__________________________________________ Clerk Justice Beth Baker delivered the Opinion of the Court.

¶1 Lauren Difolco and Sherry Spear filed sex discrimination claims with the Montana

Department of Labor and Industry’s Human Rights Bureau after the Montana State

Hospital awarded their male coworker, Trent Martin, a promotion. The Hearing Officer

found that the Hospital hired Martin based on his interview performance and did not

discriminate against Spear and Difolco. The Human Rights Commission (HRC) affirmed.

The District Court reversed, concluding that five of the Hearing Officer’s factual findings

were clearly erroneous. The court awarded damages and attorney fees to Difolco and

Spear. The dispositive issue on appeal is whether the District Court exceeded its authority

under the Montana Administrative Procedure Act when it reversed the HRC’s decision.

We reverse the District Court and reinstate the HRC’s final agency decision.

FACTUAL AND PROCEDURAL BACKGROUND

¶2 In 2019, the Montana State Hospital in Warm Springs, Montana, hired Lauren

Difolco and Sherry Spear as recreation therapists. Spear and Difolco had bachelor’s

degrees in recreation therapy and prior experience as recreation therapists. The Hospital

hired Trent Martin as a recreational services aid in May 2020, and he was promoted to

recreation therapist seven months later. Martin previously worked as a missionary, an

outdoor program coordinator at a youth residential center, a U-Haul and storage facility

manager, and a wilderness program field instructor. Martin had neither a bachelor’s degree

in recreation therapy nor, prior to his promotion at the Hospital, experience as a recreation

therapist.

2 ¶3 In July 2021, the Hospital sought to hire a Treatment Rehabilitation Manager

(TRM), a mid-level management position that oversees the Hospital’s rehabilitative

program and staff. Justin Lanes, a human resource generalist for the Hospital, created the

TRM job posting. It required the following minimum qualifications: (1) a bachelor’s

degree in rehabilitation therapy or a related field, (2) a minimum of four years of

management experience in a psychiatric setting “with work assignments including

management of a clinical area and supervision of staff,” and (3) Certified Therapeutic

Recreation Specialist preferred. Interested applicants were asked to submit the Hospital’s

online application form along with a resume and cover letter. The job posting contained

the following disclaimer: “Candidates will be evaluated to determine if they meet the

minimum qualifications listed above and on the extent to which the application materials

show the candidate possess[es] the knowledge, skills, and abilities associated with this

position . . . . Candidates whose application and supporting documentation . . . do not

clearly indicate all minimum qualifications are met will not be considered.”

¶4 Five current Hospital employees applied for the TRM position: Lauren Difolco,

Sherry Spear, Chad Peterson, Trent Martin, and Jamie Farmer. Lanes screened the

applications to determine whether the candidates met the minimum qualifications. Lanes

determined that only Peterson was minimally qualified. He recommended that the hiring

manager, George Sich, reject the remaining applications and interview Peterson.

¶5 Sich was concerned that Lanes recommended only one candidate for an interview.

Because of its frequent limited applicant pools, the Hospital commonly included in job

3 postings the alternative minimum qualification that “[o]ther combinations of experience

and education may be considered on a case by case basis.” Lanes forgot to include this

alternative in the TRM posting, which closed before he could update it. After Sich

expressed concern about advancing just one applicant, Lanes applied the alternative (the

“catch-all provision”) to the existing applicant pool and recommended that the Hospital

interview all five.

¶6 George Sich, Jamie Foy, and Holly Callarman conducted the interviews for the

TRM position. They asked candidates a series of behavioral-based questions about their

leadership and management experience. All three interviewers determined that Martin

outperformed the others and that he possessed the leadership skills necessary for the TRM

position. The Hospital hired Martin based on the panel’s recommendation. Spear and

Difolco felt upset and humiliated when they learned that Martin received the position

because he lacked their education and experience in recreation therapy.

¶7 Spear and Difolco filed separate complaints with the Human Rights Bureau in

September 2021. They alleged that the Hospital discriminated against them on the basis

of sex when it hired Martin as TRM because they were qualified for the position and Martin

was not.1 The Hospital denied these allegations, explaining that it hired Martin because he

was the most qualified candidate.

1 The complaints also alleged that the Hospital discriminated against the women during the hiring of two other management positions. Spear and Difolco focused on the July 2021 TRM position throughout the proceedings and do not challenge the other hiring decisions on appeal.

4 ¶8 A Hearing Officer was appointed and conducted a consolidated contested case

hearing on Spear and Difolco’s claims. Spear and Difolco testified, along with Martin,

Lanes, Callarman, Sich, and Foy. The Hearing Officer issued his Findings of Fact,

Conclusions of Law and Notice of Issuance of Administrative Decision on August 22,

2023. The Officer found that although Spear and Difolco established prima facie cases of

sex discrimination,2 they failed to prove that Martin’s interview performance was mere

pretext and not the Hospital’s legitimate, nondiscriminatory reason for hiring him. Based

on these findings, the Hearing Officer concluded that the Hospital did not unlawfully

discriminate against Spear and Difolco. Spear and Difolco appealed to the HRC. The HRC

determined that the Hearing Officer’s findings were supported by substantial evidence and

affirmed.3

¶9 Difolco and Spear petitioned for judicial review of the HRC’s final agency decision

in the Second Judicial District Court, Butte-Silver Bow County. Difolco and Spear argued

that several administrative findings were not supported by substantial evidence. The

District Court agreed and reversed the HRC. The court found that the contested findings

were clearly erroneous, that the Hospital’s proffered reason for hiring Martin was mere

Free access — add to your briefcase to read the full text and ask questions with AI

Related

McDonnell Douglas Corp. v. Green
411 U.S. 792 (Supreme Court, 1973)
Texas Department of Community Affairs v. Burdine
450 U.S. 248 (Supreme Court, 1981)
Thompson v. BOARD OF TRUSTEES, SCH. DIST., ETC.
627 P.2d 1229 (Montana Supreme Court, 1981)
Johnson v. Bozeman School District No. 7
734 P.2d 209 (Montana Supreme Court, 1987)
Montana Rail Link v. Byard
860 P.2d 121 (Montana Supreme Court, 1993)
State Personnel Division v. Child Support Investigators
2002 MT 46 (Montana Supreme Court, 2002)
Benjamin v. Anderson
2005 MT 123 (Montana Supreme Court, 2005)
Peretti v. State, Department of Revenue
2016 MT 105 (Montana Supreme Court, 2016)
Blaine and Hill Co. v. Stricker
2017 MT 80 (Montana Supreme Court, 2017)
Bollinger v. Billings Clinic
2019 MT 42 (Montana Supreme Court, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
2026 MT 26, Counsel Stack Legal Research, https://law.counselstack.com/opinion/difolco-v-mt-state-hospital-mont-2026.