In re M.C., 403 P.3d 1266

Mother (J.C.) signed a court-approved treatment plan requiring a psychological evaluation and agreement to follow its recommendations as part of reunification with her child M.C.
Dr. Theresa Reed performed the psychological evaluation on September 3, 2015; the report included history, mental status, test results, conclusions, and recommendations.
The Department filed to terminate Mother's parental rights in November 2016 after reunification efforts failed; a termination hearing occurred in January 2017.
At the hearing the Department sought to admit Dr. Reed’s evaluation; Mother objected on hearsay grounds.
The District Court admitted the evaluation as part of the court-ordered proceedings but limited use to the recommendations; Mother appealed the evidentiary ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court properly admitted Mother’s psychological evaluation at the termination hearing	The evaluation is inadmissible hearsay and should not be used against Mother.	The evaluation was court-ordered as part of the treatment plan and thus properly considered in the proceedings (alternative: business‑records exception).	The evaluation was properly considered because the court ordered it and it became part of the court record; Mother could have subpoenaed the evaluator to confront/test the report.

In re A.D.B., 305 P.3d 739 (Mont. 2013) (parental rights are fundamental and termination must follow statutory guidelines)
In re A.N., 995 P.2d 427 (Mont. 2000) (standard for reviewing district court evidentiary rulings)
In re D.B., 288 P.3d 160 (Mont. 2012) (statutory factors for termination include treatment-plan compliance and parental condition unlikely to change)
In re T.E., 54 P.3d 38 (Mont. 2002) (issues not raised in district court are generally waived on appeal)