CHARLES DANIEL SMITH, Plaintiff and Appellant, v. CHARTER COMMUNICATIONS, INC., Defendant and Appellee., 2023 MT 92

Summary

HOLDINGS: [1]-Because the Galbreath Rule is an evidentiary rule predicated on the Montana Rules of Evidence, not Mont. Code Ann. § 39-2-801, it has not been superseded by the 1999 statutory amendments to § 39-2-801. However, while the Galbreath Rule precludes admitting irrelevant evidence of collateral reasons for discharge other than the sole reason stated in the discharge letter, evidence offered to substantiate the reasons already given in the discharge letter is admissible. The Galbreath Rule requires courts to exclude collateral or irrelevant evidence, but it does not restrict courts from considering evidence that supports or substantiates the reason in the discharge letter by making its existence more probable than not, Mont. R. Evid. 401 and 402.