In re B.O.T., 342 P.3d 981

On Dec. 23–24, 2013, B.O.T. was found at a Missoula bus station in bad weather, taken to the ER, and admitted; testing revealed diabetes, hypertension, and hyperkalemia.
Hospital staff reported disorganized behavior (pulled/broke IV, uncooperative, refused meds); mental-health evals noted disorganized thought and delusions about money.
B.O.T. had a history of serious mental illness, prior injectable antipsychotic treatment, group-home placements terminated for inappropriate sexual behavior, recent jail time, and unstable housing (evicted from a motel).
He had a food-stamp card he would not activate (refused/failed to get a PIN) and lacked a reliable plan for shelter or food; evaluators concluded he could not utilize available resources.
The State petitioned for involuntary commitment; after hearing testimony from a clinical social worker (who diagnosed schizoaffective disorder and opined commitment was necessary), the district court ordered 90 days’ commitment to Montana State Hospital with involuntary medication authorized.
The Montana Supreme Court affirmed, finding substantial evidence that, because of a mental disorder, B.O.T. was substantially unable to provide for basic needs (food, shelter, health, or safety).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether substantial evidence shows respondent, because of mental disorder, is substantially unable to provide for basic needs (food, clothing, shelter, health, safety)	State: Evidence (clinical testimony, records, refusal to activate food stamps, homelessness, disorganized thought, medical needs) shows inability to meet basic needs and risk of harm	B.O.T.: Temporary homelessness doesn’t prove inability; no evidence of malnourishment; claims of medication compliance; much State evidence was hearsay	Court: Affirmed—substantial evidence supports finding that mental disorder rendered B.O.T. substantially unable to provide for basic needs; commitment upheld

In re Mental Health of L.K.-S., 359 Mont. 191, 247 P.3d 1100 (standard of review for commitment findings)
In re Mental Health of T.J.F., 359 Mont. 213, 248 P.3d 804 (view evidence in light most favorable to prevailing party)
In re R.F., 369 Mont. 236, 296 P.3d 1189 (overt acts not required to show inability to meet basic needs absent imminent threat)
In re G.P., 246 Mont. 195, 806 P.2d 3 (same principle regarding proof without overt acts)
Schmidt v. Cook, 326 Mont. 202, 108 P.3d 511 (appellate role in reviewing sufficiency of evidence)
In re Mental Health of J.D.L., 348 Mont. 1, 199 P.3d 805 (plain-error review can apply in involuntary commitment appeals)