In re B.H., 430 P.3d 1006

B.H., diagnosed with bipolar disorder, experienced a severe manic episode in late 2016–early 2017; police and mental-health facilities were involved after disruptive and threatening conduct.
Gallatin County filed a petition to involuntarily commit B.H. to the Montana State Hospital, alleging mental disorder, inability to care for basic needs, and imminent danger to self/others. A written rights statement was attached to the petition.
The district court found probable cause under § 53-21-122, MCA, appointed counsel, and held an initial hearing by videoconference on Jan. 9, 2017; B.H. interrupted and temporarily left before a full oral advisement of rights was completed.
The court appointed a professional person to evaluate B.H. before the contested hearing; the evaluation occurred and a contested hearing was held Jan. 11, where evidence was presented and B.H. testified with counsel.
The court committed B.H. to the Montana State Hospital for up to 90 days. Neither B.H. nor his counsel objected at trial to the alleged failure to give the full statutorily required advisement at the initial hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court plainly erred by failing to give the full § 53-21-122(2)(a) advisement at the initial hearing	The initial oral advisement was not given; this deprived B.H. of notice of constitutional/statutory rights and could have affected his interaction with the evaluator and litigation choices	State concedes the oral advisory was not fully given but contends no prejudice and that plain error review should not apply absent an objection	Court declined to exercise plain error review because B.H. failed to show the error caused a manifest miscarriage of justice, unsettled fundamental fairness, or compromised judicial integrity; commitment affirmed

In re M.K.S., 350 P.3d 27 (Mont. 2015) (plain-error framework and balancing of procedural safeguards against prejudice)
In re N.B., 620 P.2d 1228 (Mont. 1980) (courts may review unpreserved constitutional issues in commitment cases)
State v. Finley, 915 P.2d 208 (Mont. 1996) (formulation of plain-error doctrine)
In re J.D.L., 199 P.3d 805 (Mont. 2008) (applying plain-error review to involuntary commitment)
In re B.O.T., 342 P.3d 981 (Mont. 2015) (requirement that plain-error be raised and argued on appeal)
In re R.H., 385 P.3d 556 (Mont. 2016) (importance of strict adherence to commitment statutes due to loss of liberty)
In re R.M., 889 P.2d 1201 (Mont. 1995) (earlier authority on appellate review of unpreserved issues in commitment cases)
In re Mental Health of A.S.B., 180 P.3d 625 (Mont. 2008) (procedural protections in commitment proceedings)