In re S.G.R.
2016 MT 70
| Mont. | 2016Background
- Respondent S.G.R., a 76-year-old with alcohol-induced dementia and long history of severe alcoholism and institutionalizations, was originally involuntarily committed in 2014 and transferred to the Montana Mental Health Nursing Care Center.
- Nursing Care Center staff petitioned to extend commitment before expiration, citing danger to self, repeated elopement attempts (including rolling into traffic and attempting to wheel down an embankment), seizures from withdrawal, noncompliance with treatment, and lack of insight into dementia and alcoholism.
- A contested hearing was held December 16, 2014; staff testimony and a written mental health assessment documented repeated relapses, dangerous behavior, poor judgment, and inability to live independently.
- The District Court orally found S.G.R. suffered from alcohol-induced dementia and was a danger to himself, and issued a written Order for Recommitment on January 12, 2015 committing him to the Nursing Care Center up to one year and directing continued treatment and search for less restrictive placements.
- On appeal, S.G.R. argued the District Court’s written findings were legally insufficient under §§ 53-21-127 and -128, MCA, and that the court failed to identify which statutory subsection authorized commitment (raising whether commitment to the Nursing Care Center was permissible).
- The Montana Supreme Court affirmed, holding the written order, together with oral findings and the record, was "minimally sufficient" and supported by substantial evidence; two justices dissented, arguing the order lacked required statutory specificity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether district court satisfied § 53-21-127(8)(a) requirement for a "detailed statement" supporting extension | District court’s written findings were too sparse and failed to identify facts showing which § 53-21-126(1) criterion justified recommitment | Even if written findings were terse, the court’s summary of testimony and oral findings are properly considered as implied findings and supply necessary factual detail | Affirmed: written order, read with oral findings and record, was "minimally sufficient" and supported by substantial evidence |
| Whether the court specified which § 53-21-126(1) subsection authorized commitment (a, b, c, or d) | Failure to identify the subsection renders commitment procedurally deficient and prevents assessing statutory limits on placement | The court’s findings (lack of insight, inability to live independently, dangerous elopements, seizures) imply subsection (a) (substantially unable to provide for own basic needs) | Held impliedly under (a); not a reversible error because record supports commitment under § 53-21-126(1)(a) |
| Whether commitment to the Nursing Care Center (an inpatient facility) was permissible if court relied on § 53-21-126(1)(d) | If court relied solely on (d), statute permits only community placement, not state hospital or Nursing Care Center; absence of explicit subsection means error | The court’s findings imply commitment under (a), so the statutory bar on inpatient placement tied to (d) does not apply | Court affirmed; rejection of challenge because record supports inpatient placement under (a) |
| Whether district court’s findings were supported by substantial evidence | N/A (Respondent contests sufficiency) | Testimony and written assessment documented repeated dangerous acts, relapses, poor insight, elopement attempts, seizures, and inability to live independently | Affirmed: substantial evidence supports recommitment |
Key Cases Cited
- In re S.M., 377 Mont. 133 (2014) (doctrine of implied findings may be used; written order must be minimally sufficient when read with transcript)
- In re L.K.S., 359 Mont. 191 (2011) (standard of review for factual findings and clear error)
- In re L.L.A., 362 Mont. 464 (2011) (reversal where findings recited statutory language without tying facts to respondent’s behavior)
- In re M.P.-L., 381 Mont. 496 (2015) (upholding commitment where findings, though terse, referenced specific testimony showing danger to self)
- In re Mental Health of S. C., 303 Mont. 444 (2000) (definition and application of implied findings doctrine)