In re B.D., 381 Mont. 505

B.D., diagnosed with personality change due to traumatic brain injury after a 2003 closed-head injury, had prior involuntary commitments (2005, 2008).
In Feb 2014 county petitioned for involuntary commitment after reports B.D. stopped taking medications, became increasingly paranoid and suspicious, and decompensated.
Before detention, B.D. had escalating conflicts with neighbors (including at least one physical altercation requiring police) and increased hostility at work.
B.D. reportedly inquired about obtaining a firearm for “self protection” against perceived threats; after seven days of treatment he was less vehement but still expressed desire to possess a firearm.
District Court ordered involuntary commitment to Montana State Hospital for up to 90 days; B.D. appealed, challenging the sufficiency of evidence and the court’s failure to specify the statutory subsection and provide detailed factual findings.

Issue	B.D.'s Argument	State's Argument	Held
Whether evidence supported involuntary commitment under § 53-21-126(1)	Evidence insufficient; after treatment B.D. was improving and not an imminent threat	District Court implicitly relied on § 53-21-126(1)(c); record shows overt recent acts and statements supporting imminent threat	Affirmed — substantial credible evidence supported commitment under subsection (c)
Whether court erred by failing to cite specific statutory subsection	Omission violated strict-adherence requirement and prejudiced B.D.	Failure to cite was oversight; court’s language and findings show it relied on subsection (c)	No reversible error — implicit citation was adequate in context
Whether factual findings were detailed enough under § 53-21-127(8)(a)	Findings were conclusory and lacked required factual detail	Findings recited medication noncompliance, paranoia, altercations, firearm interest, and treatment refusal	Findings were sufficient here to meet statutory detail requirement
Admissibility/relevance of gun-related statements given federal prohibition on firearm possession	Statements irrelevant because B.D. was already federally prohibited from owning firearms	Statements remained relevant to dangerousness assessment regardless of legal prohibition	Statements were relevant and properly considered by the court

In re Mental Health of A.S.B., 180 P.3d 625 (Mont. 2008) (standard of review for district-court findings in commitment proceedings)
In re D.M.S., 203 P.3d 776 (Mont. 2009) (district court must first find mental disorder before commitment)
In re Mental Health of L.K.-S., 247 P.3d 1100 (Mont. 2011) (need for strict adherence to statutory commitment procedures)
In re S.L., 339 P.3d 73 (Mont. 2014) (threat need not be certain; imminence standard explained)
In re Mental Health of R.J.W., 736 P.2d 110 (Mont. 1987) (court may commit before use of weapons; preventive rationale)
In re G.M., 157 P.3d 687 (Mont. 2007) (conclusory findings insufficient under statutory mandate)
In re A.K., 139 P.3d 849 (Mont. 2006) (trial courts must enter detailed factual findings for commitment)
In re Mental Health of L.R., 231 P.3d 594 (Mont. 2010) (illustrates sufficient factual findings supporting commitment)