Baumgart v. Dep’t of CommerceAnnotate this Case
In 2002, Elizabeth “Betsy” Baumgart was appointed to be the administrator of the Montana Tourism and Promotion Division of the Department of Commerce (DOC). In 2010, after Dore Schwinden was appointed as DOC director, Schwinden terminated Baumgart’s employment, citing a lack of management competencies and sufficient understanding of the Division’s budgeting process. Baumgart sued the DOC and Schwinden, individually and as DOC’s agent, alleging that DOC wrongfully discharged her and discriminated against her on political grounds because she was a Republican and Schwinden was a Democrat. The district court granted DOC’s motion for summary judgment as it pertained to Baumgart’s political affiliation discrimination claims and all claims against Schwinden. The Supreme Court affirmed, holding (1) because Baumgart failed to establish a prima facie case for political discrimination, the district court did not err in granting DOC’s motion for summary judgment on this issue; (2) the district court correctly dismissed the individual claims against Schwinden, as Schwinden was entitled to statutory immunity under the circumstances of this case; and (3) the district court correctly concluded that the DOC had good cause to terminate Baumgart.