Knights Towing, Inc. v. KP Transport LLC

CourtDistrict Court, D. Montana
DecidedMarch 3, 2025
Docket6:24-cv-00001
StatusUnknown

This text of Knights Towing, Inc. v. KP Transport LLC (Knights Towing, Inc. v. KP Transport LLC) is published on Counsel Stack Legal Research, covering District Court, D. Montana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Knights Towing, Inc. v. KP Transport LLC, (D. Mont. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA HELENA DIVISION

KNIGHT’S TOWING, INC. a Domestic

Montana Profit Corporation, JOSHUA Case No. CV-24-01-H-BMM BARBAGELLO, individually, and

JOELLEN BARBAGELLO, individually,

ORDER Plaintiffs,

v.

KP TRANSPORT LLC, aka FUEL EXPRESS, LLC, Defendant.

INTRODUCTION Plaintiffs Knight’s Towing, Inc., Joshua and Joellen Barbagello (“Knight’s Towing” or “Barbagellos” respectively) filed this action against KP Transport (“KP) for economic damages, emotional and general damages, and costs and disbursements. (Doc. 1.) KP filed a motion for partial summary judgment on the alleged lost income and emotional distress damages suffered individually by Barbagellos. (Doc. 21.) Barbagellos concede they do not have a claim for lost income but maintain their claim for emotional distress. (Doc. 34.) FACTUAL BACKGROUND The parties were involved in a motor vehicle accident north of Helena, Montana on January 5, 2022. (Doc. 1 at 3.) The accident involved a tow truck (“tow truck”) owned by Knight’s Towing and a freightliner (“semi”) owned by KP. Both vehicles were driving northbound on Interstate 15. The KP owned semi moved into

the passing lane and attempted to pass Knight’s Towing’s tow truck. (Doc. 34 at 2- 3.) Knight’s Towing’s tow truck travelled off the roadway and sustained damages. (Id. at 3.) Knight’s Towing employee Seth Harrison operated the tow truck at the

time of the accident. (Id.) Knight’s Towing’s owners, Joellen Barbagello and Joshua Barbagello, were not present at the accident. (Id.) Knight’s Towing and the Barbagellos assert damages for economic and emotional loss. (Doc. 1. At 4-5.) LEGAL STANDARD Summary judgment proves appropriate when “the movant shows that there is

no genuine dispute as to any material fact and the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). Material facts are those that may affect the outcome of the case. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986). A

genuine material fact dispute requires sufficient evidence for a reasonable jury to return a verdict for the nonmoving party. Id. at 248. DISCUSSION Barbagellos concede that they assert no personal claims for lost income related to the accident. (Doc. 22 at 2.) The Court addresses only Barbagellos’ claim

for emotional distress damages. (Id.) KP argues that Montana law precludes recovery of damages for emotional distress related to purely economic loss. (Id. at 6-7, citing Childress v. Costco Wholesale Corp., 493 P.3d 314, 318. (Mont. 2021)) KP contends that Barbagellos’ alleged loss of property falls outside the narrow exception allowing recovery of emotional damages for injury to property. (Doc. 22

at 5.) The Montana Supreme Court has a long history of carving out rules and exceptions for when a party may recover damages for emotional distress. See Sacco

v. High Country Indep. Press, Inc., 271 Mont. 209, 223, 896 P.2d 411, 419 (1995) (collecting cases). The Court seeks to determine how the Montana Supreme Court would rule given the unique set of circumstances here. Generally, the “proscription against recovery for emotional injury when the underlying harm is economic is

nearly universal.” Maloney v. Home & Inv. Ctr., Inc., 994 P.2d 1124, 1136 (Mont. 2000). Barbagellos first must overcome the fact that their alleged emotional distress

stems entirely from alleged economic losses suffered by their corporate entity Knight’s Towing. “As a general rule stockholders may not sue upon a cause of action belonging to their corporation whether in their own names or in the name of the corporation itself.” Malcom v. Stondall Land Co., 284 P.2d 258, 260, (1955). The

Montana Supreme Court confirmed the general prohibition on individual shareholders who control all the stock of the corporation being allowed to disregard the corporate entity and sue as individuals on the corporation's cause of action. Id.,

at 260. The Montana Supreme Court in Moats Trucking Co. v. Gallatin Dairies, Inc., specifically addressed the issue of whether shareholders in a corporation could

recover emotional distress damages related to economic losses allegedly suffered by the corporation. 753 P.2d 883, 885 (Mont. 1988). Lloyd Moats and his wife, Lucille, incorporated their trucking business. Lloyd and Lucille Moats were the directors and

sole stockholders. The Montana state district court disallowed evidence of emotional distress to be presented based on the general rule that shareholders could “not sue upon a cause of action belonging to their corporation.” Id. The Montana Supreme Court declined to allow a “reverse piercing of the

corporate veil” that would permit Lloyd and Lucille Moats to bring an action for emotional distress in their personal capacities. The Montana Supreme Court recognized that such reverse piercing of the corporate veil for the benefit of the

shareholders would allow persons who have incorporated to invoke the corporate entity only when it would be to their advantage. Id. Shareholders controlling all the shares in a corporation “do not have the right to pursue an action on their own behalf when the cause of action accrues to the corporation.” Id. (citing Malcom, 284 P.2d

at 260). Barbagellos concede that Knight’s Towing is a corporation registered with the Secretary of the State of Montana. (Doc. 34 at 4.) It remains undisputed that Knight’s

Towing owned the damaged tow truck and that Barbagellos owned all the shares in their corporate entity Knight’s Towing. (Doc. 34 at 2 and 4.) Barbagellos seek to overcome this bar to the “reverse piercing of the corporate veil,” Moats Trucking

Co., 753 P.2d at 885, by arguing that Knight’s Towing “is a Family-Owned Business and as a practical matter, does not function like a corporation.” (Doc. 34 at 4.) Knight’s Towing cites to no case or statute that permits “reverse piercing of the

corporate veil” when the corporation functions as a family business for purposes of seeking emotional distress damages for loss of personal property. Even if Barbagellos could overcome the restriction of reverse piercing of the corporate veil, they seek to recover emotional distress damages for loss of personal

property. The Montana Supreme Court in Maloney applied an exception to this “nearly universal” prohibition to the recovery of emotional distress damages for loss of property. 994 P.2d at 1136. The plaintiffs in Maloney sought emotional distress

damages parasitic to their claim for loss of use and enjoyment of real property after a real estate agent sold the parcel adjacent to their property to a third party despite a written commitment from the seller to first offer the property to them. Id. Maloney reasoned that the loss of “the use and enjoyment of land[,]” involved

a unique property interest that qualified for emotional distress damages. Id., at 1137. The Montana Supreme Court supported this exception for real property based on the unique facts of the case. The plaintiff landowners testified that they were devastated

when the adjacent property they had been promised was wrongfully sold to someone else and later re-sold for almost six times what the plaintiffs may have paid for it themselves. The plaintiffs had sought to purchase a neighboring parcel from their

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Related

Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Dawson v. Hill & Hill Truck Lines
671 P.2d 589 (Montana Supreme Court, 1983)
Moats Trucking Co. v. Gallatin Dairies, Inc.
753 P.2d 883 (Montana Supreme Court, 1988)
Sacco v. High Country Independent Press, Inc.
896 P.2d 411 (Montana Supreme Court, 1995)
Maloney v. Home and Investment Center, Inc.
2000 MT 34 (Montana Supreme Court, 2000)
Vortex Fishing Systems, Inc. v. Foss
2001 MT 312 (Montana Supreme Court, 2001)
Jacobsen v. Allstate Insurance
2009 MT 248 (Montana Supreme Court, 2009)
Malcom v. Stondall Land and Investment Company
284 P.2d 258 (Montana Supreme Court, 1955)

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Knights Towing, Inc. v. KP Transport LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/knights-towing-inc-v-kp-transport-llc-mtd-2025.