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Montana Court Upholds Defamation Award Against Housing Authority

The Montana Supreme Court affirmed a jury's defamation award to Lori Collins against the Whitefish Housing Authority in a February 10, 2026 decision. The court rejected the housing authority's appeal challenging evidence admission and damage cap applications while also denying Collins' request for attorney fees.

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4 min readcourtlistener
Seal of the Montana Supreme Court

Case Information

Case No.:
DA 25-0335
Judges:
Rice

Key Takeaways

  • Montana Supreme Court affirmed jury's defamation award to Lori Collins against Whitefish Housing Authority
  • Court rejected housing authority's challenges to evidence admission and statutory damage caps
  • Collins' request for attorney fees for defending against alleged bad faith counterclaims was denied

The Montana Supreme Court affirmed a defamation judgment against the Whitefish Housing Authority in *Collins v. Whitefish Housing Authority* (2026 MT 19), issued February 10, 2026. The decision resolves a complex dispute that originated in Flathead County District Court and involved both appeals and cross-appeals from the parties.

Justice Jim Rice delivered the court's opinion affirming the trial court's judgment in favor of Lori Collins, who successfully pursued a defamation claim against the public housing authority. The case arose from a jury trial that resulted in damages awarded to Collins, though the specific amount and underlying facts of the defamation claim are not detailed in the available court documents.

The Whitefish Housing Authority, represented by Natalie A. Hammond of Gordon Rees Scully Mansukhani LLP in Missoula, raised two primary issues on appeal. First, the housing authority argued that the District Court erred by admitting what was referred to as "the subject Article" into evidence over their hearsay objection. This suggests that a published article played a central role in the defamation case, though the specific nature and content of this article remain unclear from the court's preliminary materials.

Second, the housing authority contended that the District Court abused its discretion by denying their Motion to Amend Judgment to apply a statutory cap on damages. This indicates that Montana law may provide certain limitations on damage awards against public housing authorities, which the defendant sought to invoke to reduce the jury's award to Collins.

Meanwhile, Collins, represented by Sean S. Frampton of Frampton Purdy Law Firm in Whitefish, filed a cross-appeal challenging the trial court's denial of her motion for attorney fees. Collins argued she was entitled to fees for defending against counterclaims that were allegedly made in bad faith by the housing authority. This aspect of the case suggests that the housing authority not only defended against Collins' defamation claim but also pursued counterclaims against her.

The Montana Supreme Court's decision to affirm indicates that the trial court properly handled all three disputed issues. The court found that the admission of the article into evidence was appropriate despite the hearsay objection, suggesting either that the evidence fell within a recognized exception to the hearsay rule or that it was not hearsay at all. The affirmation also means the court agreed with the trial court's decision not to apply the statutory damage cap that the housing authority sought.

However, the court's affirmation of the trial court's decision also means Collins will not receive attorney fees for defending against the housing authority's counterclaims. This suggests that while Collins prevailed on her main defamation claim, the court did not find that the housing authority's counterclaims were frivolous or made in bad faith to the extent that would justify fee-shifting.

The case was submitted on briefs December 24, 2025, indicating that the parties chose not to present oral arguments before the Montana Supreme Court. This procedural choice often signals that the legal issues were considered straightforward enough to resolve based solely on written submissions.

The Whitefish Housing Authority operates as a Montana incorporated public housing authority in the resort town of Whitefish. As a public entity, the authority is subject to various legal standards and protections that differ from those applicable to private parties. The case illustrates the complex legal landscape facing public housing authorities when disputes arise with individuals.

Defamation law in Montana, like in other states, requires plaintiffs to prove that false statements were published that damaged their reputation. When public entities are involved as defendants, additional considerations may apply regarding the scope of official immunity and damage limitations.

The original case was heard in the District Court of the Eleventh Judicial District in Flathead County under cause number DV-23-1277A, with Honorable Amy Eddy presiding. The case's progression from trial court through the state's highest court demonstrates the significance of the legal issues involved for both parties.

While the Montana Supreme Court's brief procedural summary does not reveal the underlying facts that gave rise to the defamation claim, the case's resolution provides clarity on important evidentiary and procedural issues that may guide future litigation involving public housing authorities in Montana.

The decision represents the conclusion of what appears to have been contentious litigation between Collins and the housing authority, with both sides sufficiently invested in the outcome to pursue appeals challenging different aspects of the trial court's rulings. The supreme court's affirmation of the trial court's judgment suggests that the lower court appropriately balanced the various legal standards and procedural requirements that applied to this dispute.

Topics

defamationemployment disputepublic housingjury trialappealsattorney fees

Original Source: courtlistener

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