In re C.R.
367 Mont. 1
| Mont. | 2012Background
- Petition for involuntary commitment filed January 9, 2012 after Billings Clinic evaluated C.R. as possibly mentally ill.
- District Court found probable cause, detained C.R., appointed counsel, and set an evidentiary hearing for January 11, 2012.
- Dr. Masood diagnosed severe psychosis with schizophrenia, recommended 90‑day commitment and possible involuntary medication to facilitate treatment.
- District Court ordered involuntary commitment up to three months and authorized involuntary medication if needed; C.R. hospitalized and later released.
- On appeal, issues raised: disregard of C.R.’s hearing testimony, failure to offer a court‑appointed friend, and ineffective assistance of counsel.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court improperly disregarded hearing testimony | C.R. asserts the court ignored coherent denial of disorder at hearing | State contends findings supported by Dr. Masood and others | Not clearly erroneous; findings supported by substantial evidence |
| Whether failure to offer a court‑appointed friend violated rights | C.R. argues constitutional right to a friend and failure to inquire violated due process | State contends statute no longer mandates a friend and no plain error shown | Plain error not established; statute not mandatory and no manifest miscarriage |
| Whether C.R. received ineffective assistance of counsel | C.R. claims counsel did not obtain independent evaluation or adequately represent him | State asserts record shows effective representation and vigorous advocacy | Affirmed; record shows effective representation and no denial of substantial rights |
Key Cases Cited
- In re Mental Health of L.K.-S., 359 Mont. 191, 247 P.3d 1100 (2011 MT 21) (strict adherence to commitment standards; review standard)
- In re Mental Health of M.C.D., 225 P.3d 1214 (2010 MT 15) (clear error standard of review for mental disorder findings)
- In re Mental Health of C.R.C., 207 P.3d 289 (2009 MT 125) (ineffective assistance framework in commitment cases)
- In re Mental Health of J.D.L., 199 P.3d 805 (2008 MT 445) (court-appointed friend constitutional considerations)
- In re Mental Health of A.S.F., 199 P.3d 808 (2008 MT 450) (statutory framework for court-appointed friend)
- In re Mental Health of T.J.F., 248 P.3d 804 (2011 MT 28) (counsel's role and effectiveness considerations)