Scrantom v. Masters

2018 MT 109, 417 P.3d 339, 391 Mont. 251
CourtMontana Supreme Court
DecidedMay 8, 2018
DocketDA 17-0588
StatusPublished
Cited by1 cases

This text of 2018 MT 109 (Scrantom v. Masters) 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
Scrantom v. Masters, 2018 MT 109, 417 P.3d 339, 391 Mont. 251 (Mo. 2018).

Opinion

Justice Laurie McKinnon delivered the Opinion of the Court.

***251¶1 Timothy D. Scrantom (Scrantom) objected to the findings of fact, conclusions of law, and order proposed by the Standing Master (Standing Master's Order) in a dissolution proceeding with Lila S. Masters (Masters). The Eighteenth Judicial District Court, Gallatin County, refused to review the Standing Master's Order because ***252Scrantom's objections lacked specificity. We reverse.

¶2 Scrantom presents the following issue for review:

Did the District Court err by determining Scrantom's objections to the Standing Master's Order lacked specificity under § 3-5-126, MCA ?

FACTUAL AND PROCEDURAL BACKGROUND

¶3 In April 2012, the District Court dissolved Scrantom and Masters's marriage. The parties entered into a property settlement agreement and the District Court's dissolution decree incorporated that agreement by reference. The property settlement agreement contained provisions regarding property division, spousal support, debts and obligations, default, and attorney fees. The provision on debts and obligations required Masters to indemnify Scrantom for debts, liabilities, and expenses, including attorney fees, costs, and interest, "relating to the assets allocated to her."

¶4 Balance Point Divorce Funding LLC (Balance Point), a third-party divorce financing company, provided litigation funding for Masters during the parties' dissolution proceeding in exchange for one-third of her recovery. Following dissolution, Balance Point sued Masters in a separate Montana-based federal district court action claiming she breached her obligation to pay. Balance Point also sued Scrantom in another separate New York-based federal district court action claiming tortious interference. After the New York action against Scrantom ended in dismissal, Scrantom moved the District Court to enforce the debts and liabilities provision incorporated into the parties' dissolution decree. Scrantom argued the provision entitled him to indemnification for the cost of defending the New York action. Masters responded by arguing that the New York action related to Scrantom's independent conduct-tortious interference-and not from "assets allocated to her" in the parties' dissolution. The Standing Master agreed with Masters, denied Scrantom relief, and granted Masters's conflicting motion to enforce the parties' dissolution decree.

*341¶5 Scrantom filed a notice of specific objections to the Standing Master's Order and a motion requesting the District Court review it. Scrantom's eighteen-page notice listed twelve portions of the Standing Master's Order he objected to. Scrantom divided his twelve objections into four categories based on topic and included a separate "Argument" section where he included the legal bases for his objections. In evaluating Scrantom's objections, the District Court noted Scrantom listed the particular findings and conclusions he objected to, but found his " 'Argument' simply rehashes the arguments presented in his ***253previous briefing" and "provides no clear reasoning" or "legal authority." The District Court concluded Scrantom's objections to the Standing Master's Order lacked specificity under § 3-5-126(2), MCA, and, accordingly, denied his request to review it. Instead, the District Court approved and adopted the Standing Master's Order. Scrantom appeals.

STANDARD OF REVIEW

¶6 "We review de novo a trial court's interpretation of a statute." In re Marriage of Taylor , 2016 MT 342, ¶ 5, 386 Mont. 44, 386 P.3d 599.

DISCUSSION

¶7 Scrantom argues the District Court erred by concluding his objections lacked specificity, failing to hold a hearing, and denying his request for review. Masters agrees with the District Court's characterization of Scrantom's objections as lacking specificity. Masters argues that specific objections are a prerequisite to both a hearing and review.

¶8 The Legislature authorized district courts to use standing masters to help manage the volume of filings in the area of family law. Sections 3-5-124 to -126, MCA ; Beals v. Beals , 2013 MT 120, ¶ 6, 370 Mont. 88, 300 P.3d 1158. District courts have discretion to refer dissolution proceedings to a standing master. Section 3-5-124(1), MCA ; Taylor , ¶ 7. Once referred, standing masters can issue findings of fact, conclusions of law, and "temporary orders that are subject to review by the district court, upon objection." Section 3-5-124(2)(a), (b)(v), MCA. A party has ten days after being served with notice of the filing of a standing master's findings and conclusions or temporary order to object by filing a motion including his or her "specific objections." Section 3-5-126(2), MCA. Providing specific objections is a prerequisite and a district court may only modify a particular finding of fact or conclusion of law if it was specifically objected to. Beals , ¶ 12. Once a party moves for review by filing a specific objection, the district court is "required to set a hearing, consider the specific objections raised, and accept, modify, or reject the Standing Master's findings and conclusions or conduct further proceedings regarding the objections." Beals , ¶ 12.

¶9 We considered § 3-5-126(2), MCA, in In re Marriage of McMichael , 2006 MT 237, 333 Mont. 517, 143 P.3d 439. There, the objecting party filed specific objections; however, the district court modified one finding that was not specifically objected to. McMichael , ¶¶ 15-16. We reversed, concluding "[a]llowing courts to modify findings and ***254conclusions not specifically objected to by either party would deny adequate notice and due process to the parties and lead to an absurd result." McMichael , ¶ 15. In Beals v. Beals , we held that a party may not appeal a standing master's decision directly to this Court, but must follow the procedure outlined in § 3-5-126(2), MCA. Beals , ¶ 13.

¶10 We considered the sufficiency of "specific objections" in In re Marriage of Taylor

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Cite This Page — Counsel Stack

Bluebook (online)
2018 MT 109, 417 P.3d 339, 391 Mont. 251, Counsel Stack Legal Research, https://law.counselstack.com/opinion/scrantom-v-masters-mont-2018.