In re J.J., 422 P.3d 699

J.J., a 30-year-old with Bipolar I disorder and diabetes, was repeatedly unstable in May 2016 (manic, delusional, threatened others, asked an officer to shoot him) and missed medication; county crisis personnel petitioned for involuntary commitment.
The District Court found J.J. seriously mentally ill and ordered involuntary commitment to Montana State Hospital (MSH) for up to three months after expert evaluations.
Immediately after the commitment order, J.J. (through counsel) asked the court to order that he not be handcuffed while transported by sheriff’s deputy to MSH; the court denied the request, and the deputy planned to restrain him.
J.J. appealed the denial, arguing Montana statutes protect committed patients from physical restraint and that those protections should apply to transport.
The State argued the statutory protections (restraint/isolation rules) do not apply outside facilities and that transport restraints were reasonable given safety concerns.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Montana law precludes physical restraint of an involuntarily committed person during transport	§ 53-21-146 gives committed patients a statutory right to be free from restraint/isolation that applies to transport	The restraint/isolation statute does not apply outside a hospital; transport safety permits handcuffs	Court: § 53-21-146 does not contemplate transport; Montana law does not preclude restraint during transport and district court did not abuse discretion
Whether J.J.'s in-court request preserved the issue for appeal	J.J. timely raised the issue in district court when counsel asked not to handcuff him	State argued issue was inadequately preserved because counsel did not cite the specific statute	Court: Issue was preserved—motion was raised and ruled on by the district court
Whether J.J.'s notice of appeal was defective	J.J. appealed from the final judgment; he treated the post-judgment transport ruling as included	State argued notice didn’t identify the post-judgment order	Court: Notice was sufficient under § 46-20-104 and precedent
Whether the record supported restraint as necessary for safety	J.J. argued no present threat justified handcuffs	State and record showed recent manic, delusional, and dangerous conduct; transport presents foreseeable safety risks	Court: Evidence of unpredictable, dangerous behavior supported restraint; denial of J.J.’s request was not an abuse of discretion

In re C.K., 387 Mont. 127, 391 P.3d 735 (Mont. 2017) (standard of review for commitment orders)
In re B.W.S., 386 Mont. 33, 386 P.3d 595 (Mont. 2016) (appellate review and deference to trial court findings)
In re M.B., 350 Mont. 76, 204 P.3d 1242 (Mont. 2009) (standards for disturbing trial court determinations)
State v. Price, 311 Mont. 439, 57 P.3d 42 (Mont. 2002) (statutory construction principles)
State v. Boulton, 332 Mont. 538, 140 P.3d 482 (Mont. 2006) (legislative intent and plain-language statutory interpretation)
Bassett v. Lamantia, 391 Mont. 309, 417 P.3d 299 (Mont. 2018) (law-enforcement duty to preserve the peace and protect public)
Paull v. Park Cnty., 352 Mont. 465, 218 P.3d 1198 (Mont. 2009) (risks and liability associated with prisoner transport)
State v. Spotted Blanket, 288 Mont. 126, 955 P.2d 1347 (Mont. 1998) (appeal notice technicalities)
State v. Gardner, 318 Mont. 436, 80 P.3d 1262 (Mont. 2003) (a notice of appeal from the final judgment is sufficient)
State v. Betterman, 378 Mont. 182, 342 P.3d 971 (Mont. 2015) (court will affirm correct result even if reached for wrong reason)