Centron v. Hollewijn: Summary Judgment Must Track the Motion; “Reasonable Time” to Object in Account-Stated Claims Is Generally for the Jury

1. Introduction

In Centron Services, Inc. d/b/a Rocky Mountain Professional Solutions v. Christopher Hollewijn and Alyson C. Hollewijn, the Montana Supreme Court reversed a Gallatin County order granting summary judgment to medical-debt defendants and dismissing the entire case. Centron, an assignee/collector, sued on a single theory—account stated—for five separate medical-debt accounts arising from services provided by three providers (Bozeman Health, Bridger Orthopedic & Sports Medicine, and Big Sky Endodontics).

The defendants’ summary judgment motion, however, focused factually on only one account: a Bozeman Health hospital account for services on November 4, 2021. The District Court nevertheless dismissed all five accounts and, as to the Bozeman Health account, held that the defendants objected “within a reasonable time” as a matter of law—defeating the “implied assent” element of account stated.

The Supreme Court addressed two issues: (1) whether the District Court could dismiss the entire suit when the motion targeted only one account, and (2) whether it was proper to resolve the “reasonable time to object” question on summary judgment. The Court answered both in the negative.

2. Summary of the Opinion

  • Scope of summary judgment: The District Court erred by dismissing accounts not addressed by the defendants’ motion or evidentiary showing. Under M. R. Civ. P. 56(c)(3), a movant must carry the initial burden for the claims on which judgment is sought.
  • Account stated—reasonable time to object: The District Court also erred by deciding, as a matter of law, that an objection lodged 93 days after the first billing statement was “within a reasonable time.” Whether a debtor retained a statement for an “unreasonable” time is typically fact-dependent, and competing inferences (acquiescence vs. justified delay) preclude summary judgment.

The Court reversed and remanded for a jury trial on Account 5 (the November 4, 2021 Bozeman Health account) and for further proceedings on the remaining accounts.

3. Analysis

3.1 Precedents Cited

A. Summary judgment framework and limits

  • Lone Moose Meadows, LLC v. Boyne USA, Inc. (standard of review): The Court reiterated de novo review of summary judgment and application of Rule 56 criteria, anchoring its approach to reassess the District Court’s legal conclusions without deference.
  • Estate of Wilson v. Addison (no genuine issue / entitlement as matter of law): Used to restate the baseline test that summary judgment is only proper when the record shows no genuine dispute of material fact and the movant is entitled to judgment as a matter of law.
  • Howard v. Conlin Furniture No. 2, Inc. (inferences for nonmovant; summary judgment disfavored with factual disputes): Supported the Court’s insistence that all reasonable inferences must be drawn for the nonmoving party and that courts may not “try” factual controversies via Rule 56.

These authorities collectively supplied the doctrinal basis for both reversals: the improper expansion of relief beyond what the movant supported, and the improper resolution of a fact-laden “reasonableness” question.

B. The account-stated doctrine and the role of silence/objection

  • Able, Inc. v. Kuzara (elements and implied assent): The Opinion relied on Able to define account stated—agreement on items and balance and an express or implied promise to pay—and to explain that implied agreement may be presumed from “course of dealing,” “antecedent indebtedness,” and retention of the statement for an unreasonable time without objection.
  • Holmes v. Potts (rebuttable presumption; “unreasonable time” typically fact-dependent): Holmes did the heaviest lifting on the dispositive point. The Court emphasized that failure to object does not conclusively establish an account stated; it creates only a presumption open to explanation. The “unreasonable” time inquiry is commonly for the factfinder, because a debtor may rebut the inference of assent with context, conduct, and “improbability.”
  • Montana Seeds, Inc. v. Holliday (silence can imply assent; competing inferences): The Court invoked Montana Seeds for the proposition that silence or inaction may create a rebuttable presumption of assent, reinforcing why timing disputes frequently generate triable issues.
  • Nelson v. Montana Iron Mining Co. (certainty/definiteness of balance, via Montana Seeds): Cited through Montana Seeds to underscore the related requirement that an account stated involves an “exact” and “certain” balance—supporting defendants’ argument that uncertainty in hospital billing can undercut implied agreement, even if the Court ultimately treated that as fact-bound on this record.

3.2 Legal Reasoning

Issue 1: A Rule 56 motion cannot silently dispose of unaddressed claims

The Supreme Court treated the first issue as a straightforward application of M. R. Civ. P. 56(c)(3) burden allocation and procedural fairness. The defendants moved on (and presented facts about) only the November 4, 2021 Bozeman Health account, yet the District Court dismissed four additional accounts involving different service dates and even different providers.

The Court’s reasoning is practical and rule-based: if the movant does not present record support negating essential elements (or otherwise showing legal entitlement) as to those other accounts, the court has no proper basis to enter judgment on them. In effect, the District Court granted relief beyond the “evidentiary and legal reach” of the motion.

Issue 2: “Reasonable time to object” in account stated is a jury question when inferences compete

The second issue turned on whether the defendants’ 93-day silence after Bozeman Health’s first direct statement (April 5 to July 7, 2022), despite multiple consistent statements, was “unreasonable” such that implied assent could be presumed. The District Court decided it was reasonable as a matter of law.

The Supreme Court reversed because the record supported competing, plausible inferences:

  • Centron’s inference (assent by silence): four statements over nearly three months with a consistent balance could support a factfinder’s inference of acquiescence, especially where account stated doctrine permits implied agreement from retention without objection.
  • Hollewijns’ inference (delay explained/justified): the hospital’s own billing timeline and the complexities of reference-based pricing and insurer/provider disputes could support a factfinder’s view that the response time was not unreasonable and that assent should not be implied.

Under Holmes v. Potts, the defendants’ conduct “is open to explanation,” and the presumption from silence is rebuttable—not conclusive. Because jurors could differ on reasonableness, the court could not resolve it on summary judgment without weighing evidence and choosing among inferences—functions reserved for the trier of fact.

3.3 Impact

A. Procedural impact: tighter alignment between motion scope and judgment scope

The decision serves as a clear warning in multi-claim or multi-account cases: a district court may not grant global dismissal when the movant’s Rule 56 showing is claim-specific. Litigants seeking comprehensive summary judgment must build a record and legal argument for each discrete claim or account.

B. Substantive impact: account-stated claims in medical-debt litigation will more often reach juries

By treating the “reasonable time” objection inquiry as fact-laden—especially on a timeline like 93 days with multiple statements—the Court makes it harder to terminate account-stated disputes at summary judgment when either side can marshal context supporting competing inferences.

C. Medical billing context: insurer/provider pricing disputes do not automatically defeat account stated

The Opinion does not hold that reference-based pricing, chargemaster variability, or lack of pre-service price certainty categorically prevents account stated. Instead, it suggests these realities can supply factual explanations relevant to assent, certainty, and reasonableness—questions a jury may need to sort out.

4. Complex Concepts Simplified

  • Summary judgment (Rule 56): A pretrial ruling that ends a claim only if there is no genuine dispute over important facts and the law clearly favors one side. Courts must not decide “who is more believable” or which inference is better.
  • Account stated: A doctrine allowing a creditor to prove a debt by showing the parties agreed on a final balance due. Agreement can be express (explicitly accepting the balance) or implied (keeping a statement without objecting for an unreasonably long time).
  • Rebuttable presumption: A legal inference (here, assent from silence) that applies unless the other party offers evidence explaining or undermining it. It is not automatic or conclusive.
  • Reasonable vs. unreasonable time to object: Not a fixed number of days. It depends on context—how many statements were sent, what the parties were doing, and whether silence reasonably suggests acceptance.
  • Reference-based pricing: A health plan method that pays providers based on a benchmark rather than negotiated contract rates; providers may reject the benchmark and bill the patient for the remainder, creating disputes about what is “really” owed.
  • Chargemaster: A hospital’s internal list price schedule, often criticized as opaque and disconnected from negotiated or paid rates. In litigation, it can fuel arguments that the “true” price was uncertain—though not necessarily dispositive.

5. Conclusion

Centron v. Hollewijn reinforces two practical rules in Montana civil litigation. First, summary judgment relief must be tethered to the claims and accounts actually supported by the movant’s Rule 56 record; courts err by dismissing unaddressed claims. Second, in an account stated case, whether a debtor’s delay in objecting—here, 93 days after the first statement—was “unreasonable” is ordinarily a fact question when the evidence supports competing inferences.

The broader significance is a renewed insistence on the jury’s role in evaluating implied assent and reasonableness in debt cases, particularly where modern medical billing practices generate plausible explanations for silence and delay alongside plausible inferences of acquiescence.