In re L.L.A.
362 Mont. 464
| Mont. | 2011Background
- State petitioned for involuntary commitment to MSH under §53-21-121 on February 14, 2011, based on reports alleging bizarre behavior.
- Reports by Grussling and Huskey described acts supporting a diagnosis of Schizophrenia, Paranoid Type, and recommended commitment.
- Hearing held February 17, 2011; father testified, and Huskey testified about paranoid delusions and implausible explanations.
- District Court orally ordered commitment for up to 90 days; written order later recited seven findings of fact including diagnosis and need for commitment.
- Findings stated the respondent had a mental disorder and was in need of commitment; other findings addressed treatment options, medication, and aftercare.
- L.L.A. challenged the sufficiency of the district court’s detailed statement of facts required by §53-21-127(8)(a).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court provided a detailed statement of facts supporting commitment | L.L.A. argues findings merely echoed statutory criteria without specifics. | State contends findings were adequate and substantially complied with precedents. | Commitment order reversed for failure to provide detailed facts |
Key Cases Cited
- In re Mental Health of O.R.B., 345 Mont. 516, 191 P.3d 482 (Mont. 2008) (fact-specific findings required; detailed review of evidence)
- In re Mental Health of L.R., 356 Mont. 20, 231 P.3d 594 (Mont. 2010) (some behavior-specific findings permitted but must reflect individual facts)
- In re D.L.T., 314 Mont. 297, 67 P.3d 189 (Mont. 2003) (strict compliance with statutory mandates emphasized)
- In re D.D., 277 Mont. 164, 920 P.2d 973 (Mont. 1995) (waiver and harmless-error considerations discussed; not controlling for current statute)
- In re G.M., 337 Mont. 116, 157 P.3d 687 (Mont. 2007) (refused harmless error relief for deficient findings; emphasized detailed statements)
- In re E.P.B., 359 Mont. 191, 247 P.3d 1100 (Mont. 2011) (district courts must ensure proposed findings comply with statute)
- In re Mental Health of R.J.W., 226 Mont. 419, 736 P.2d 110 (Mont. 1987) (harmless-error review acknowledged but cautioned detailed basis is preferred)
- In re Mental Health of O.R.B. (duplicate listing), 345 Mont. 516, 191 P.3d 482 (Mont. 2008) (see above for O.R.B. holding on factual detail)