In re M.P.-L., 381 Mont. 496

Appellant M.P.-L., diagnosed with PTSD and borderline personality disorder, experienced worsening symptoms after losing access to medication and expressed suicidal ideation; she was voluntarily admitted to a crisis facility and later evaluated by LCSW Michael Sawicki.
Sawicki testified M.P.-L. made multiple suicide threats, was impulsive and unpredictable, remained at high suicide risk, and could not reliably cooperate with voluntary treatment.
The State petitioned for involuntary commitment on May 30, 2014; the District Court orally ordered commitment on June 2, 2014 and entered a two-page order that omitted a statutorily required detailed statement of facts.
M.P.-L. appealed; the District Court filed supplemental Findings of Fact, Conclusions of Law, and Order on June 5, 2014 providing more detail to support commitment.
The Supreme Court reviewed whether the June 2 order was deficient, whether the June 5 order was procedurally proper, whether the combined record satisfied statutory requirements, and whether the deficiency prejudiced M.P.-L.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the June 2, 2014 commitment order met § 53-21-127(8)(a)'s requirement for a detailed factual statement	June 2 order lacked required detailed factual findings and was therefore deficient	State conceded the June 2 order lacked the detailed facts	Court held the June 2 order was deficient for failing to include required detailed factual findings
Whether the June 5, 2014 Findings were procedurally invalid because they were issued after the commitment order	June 5 order was unauthorized and should be struck	Statute does not prohibit a second order; June 5 cured defects	Court held the June 5 order was not procedurally invalid; issuing a later order is not barred by statute
Whether the June 5 order (alone or combined with the June 2 record) supplied a sufficient detailed statement of facts to support commitment	June 5 order still too conclusory; late filing prejudiced respondent	June 5 contains sufficient factual findings; any June 2 error was harmless under O.R.B.	Court held the June 5 findings, read with hearing transcripts (implied findings), supplied sufficient facts to support commitment; errors in June 2 were harmless
Whether the defective June 2 order prejudiced M.P.-L. enough to warrant reversal	Late/deficient order prejudiced transporters and MSH and harmed respondent	No evidence of harm or wrongful detention; no substantial prejudice shown	Court held no substantial prejudice; error was harmless and did not require reversal

In re Mental Health of L.K-S., 359 Mont. 191, 247 P.3d 1100 (2011) (standard of review for civil commitment findings)
In the Matter of T.S.D., 326 Mont. 82, 107 P.3d 481 (2005) (review principles for commitment orders)
In re L.L.A., 362 Mont. 464, 267 P.3d 1 (2011) (statutory strictness for involuntary commitment findings)
In re O.R.B., 345 Mont. 516, 191 P.3d 482 (2008) (harmless-error analysis in commitment proceedings)
In re S.M., 377 Mont. 133, 339 P.3d 23 (2014) (doctrine of implied findings: hearing transcripts may supplement written findings)
In re Mental Health of S.C., 303 Mont. 444, 15 P.3d 861 (2000) (implied findings doctrine explained)