In re C.C., 376 P.3d 105

In Sept. 2014 Lincoln County filed a petition seeking involuntary commitment of C.C. after a mental-health professional (Nancy Huus) diagnosed symptoms consistent with schizophrenia and recommended commitment. The district court initially dismissed an earlier petition on Oct. 6, 2014.
In late Oct. 2014 police responded to several disturbing incidents involving C.C. (possession of ammunition/loaded shotgun, odd early‑morning behavior, alleged statements to police and neighbors, and an entry into a neighbor’s home). Huus evaluated C.C. and recommended commitment to Montana State Hospital for observation and possible treatment.
The court held an adjudicatory hearing on Nov. 3, 2014. At the end of the hearing the court orally ordered commitment to Montana State Hospital (Warm Springs) and then signed a preprepared written order that included findings, conclusions, a 90‑day commitment, and authorization for involuntary medication.
C.C. moved to amend the written order to conform to the oral pronouncement (noting the oral ruling did not include findings authorizing involuntary medication). The court denied the motion, calling the omission inadvertent. C.C. appealed.
The central legal dispute was whether the written order complied with § 53‑21‑127(8)(a), MCA, which requires a detailed statement of facts supporting the commitment, and whether the written involuntary‑medication authorization (not spoken at the oral pronouncement) was permissible.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court’s written findings satisfied the statutory requirement to include a detailed statement of facts supporting involuntary commitment	C.C.: written order is preprepared, lacks detailed, case‑specific factual findings and thus fails § 53‑21‑127(8)(a)	State: testimony at hearing supplies facts; apply doctrine of implied findings to uphold the order	Court: Reversed — findings insufficient; preprepared "bare‑bones" order fails strict statutory requirement; vacated and remanded for dismissal
Whether the written order’s involuntary‑medication authorization (not orally pronounced) was proper and supported	C.C.: medication authorization was not orally pronounced, not statutorily supported, and unsupported by findings	State: urged supplementation or implied findings to validate medication provision	Court: Did not reach merits because commitment order vacated due to insufficient findings

In re L.L.A., 267 P.3d 1 (Mont. 2011) (reversed commitment where written findings were conclusory and not tied to respondent’s specific facts)
In re Mental Health of E.P.B., 168 P.3d 662 (Mont. 2007) (reversed where preprepared order lacked reference to hearing testimony and statutory findings)
In re Mental Health of O.R.B., 191 P.3d 482 (Mont. 2008) (discusses requirements for adequate commitment findings)
In re Mental Health of S.C., 15 P.3d 861 (Mont. 2000) (applied doctrine of implied findings where evidence supported omitted findings)
In re Mental Health of S.M., 339 P.3d 23 (Mont. 2014) (upheld minimally sufficient order by consulting hearing transcript under implied‑findings doctrine)
In re M.P.-L., 362 P.3d 627 (Mont. 2015) (first deficient order was remedied by a later order whose combined record supported commitment)
In re S.G.R., 368 P.3d 1180 (Mont. 2016) (applied implied findings where the order identified testimony supporting recommitment)