In re D. L. B., 386 Mont. 180

Respondent D.L.B., a 75-year-old with a 53-year history of paranoid schizophrenia, has a long pattern of medication noncompliance leading to repeated psychotic episodes and involuntary hospitalizations.
After stabilization at the Montana State Hospital (MSH) in 2015, D.L.B. was transferred to the Montana Mental Health Nursing Care Center in Lewistown; staff considered him an elopement risk who continued to have hallucinations, delusions (including Nazi persecution themes), and aggressive conduct.
The State petitioned in June 2015 to extend (recommit) D.L.B.’s commitment to the Nursing Care Center for up to six months; professionals testified he remained medication noncompliant and posed danger to himself and potentially others.
At the July 8, 2015 hearing the District Court orally extended commitment and later issued a sparse written order that did not specify which subsection of § 53-21-126(1), MCA, it relied upon.
On appeal, D.L.B. argued the recommitment met only § 53-21-126(1)(d), which would bar commitment to the Nursing Care Center, and that the court failed to make the statutorily required specific findings; the State urged that recommitment may consider the broader historical and treatment context.
The Montana Supreme Court affirmed, finding adequate factual support to recommit under § 53-21-126(1)(a) based on continued inability to provide for basic needs due to mental disorder, despite noting the district court’s written findings were sparse.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred in extending recommitment to the Nursing Care Center	D.L.B.: recommitment must satisfy the same statutory subsections as an initial commitment; evidence only supports (d), which prohibits commitment to the Nursing Care Center	State: recommitment requires consideration of the respondent’s continuing history and treatment needs; the § 53-21-126(1) factors are to be evaluated in context	Affirmed: record supports recommitment under § 53-21-126(1)(a) (substantial inability to provide for basic needs) and thus commitment to Nursing Care Center was authorized
Whether the district court’s sparse written findings rendered the order invalid	D.L.B.: failure to specify which § 53-21-126(1) subsection was relied on and lack of detailed factual findings violated statutory requirements	State: oral findings and the record may be used to supplement written findings in recommitment context	Court: acknowledged deficiencies but found oral findings and record adequate to imply findings necessary to support commitment under subsection (a); warned courts must adhere to statutory finding requirements

In re S.G.R., 368 P.3d 1180 (Mont. 2016) (standard of review for commitment orders and use of oral findings to supplement written findings)
In re S.M., 339 P.3d 23 (Mont. 2014) (doctrine of implied findings and review standards)
In re L.K.-S., 247 P.3d 1100 (Mont. 2011) (importance of strict adherence to statutory requirements in involuntary commitment)
In re L.L.A., 267 P.3d 1 (Mont. 2011) (statutory interpretation and commitment standards)
In re M.P.-L., 362 P.3d 627 (Mont. 2015) (evaluating bare-bones written findings against the record)
In re C.C., 376 P.3d 105 (Mont. 2016) (declining to expand implied findings to cure spartan orders)
O'Connor v. Donaldson, 422 U.S. 563 (U.S. 1975) (continued confinement may be unconstitutional once the basis for initial confinement no longer exists)