Folsom v. Montana Public Employees' Ass'n

¶1 Montana Public Employees’ Association (MPEA) appeals judgments of the Montana Eleventh Judicial District Court, Flathead County: (1) decreeing that MPEA breached its duty of fair representation (DFR) to Jeffrey R. Folsom (Folsom) and engaged in related common law fraud; (2) awarding Folsom $47,550 in attorney fees as an element of compensatory damages on his DFR claim; and (3) awarding $50,000 in punitive damages on his related common law fraud claim. MPEA further appeals the court’s denial of MPEA’s subsequent M. R. Civ. P. 59(e) and 60(b)(6) motions for post-judgment relief. Folsom…