Collateral Estoppel

Where the determination that a claim is precluded by collateral estoppel forms part of the district court's rationale on summary judgment, the decision is reviewed de novo. Lorang v. Fortis Ins. Co., 2008 MT 252, ¶ 54, 345 Mont. 12, 192 P.3d 186.  The Court does not parse out aspects of a summary judgment ruling for differing standards of review.  Lorang, ¶ 53.