Matter of D.G.J. a Youth, 363 P.3d 1147

Between July 31 and August 6, 2014, multiple unlocked vehicles in Conrad, Montana were entered and items stolen (rifle, cash, prescription pills, electronics, sunglasses, wallet, broken window, stolen cooler).
D.G.J. was detained after being found in a vehicle with a rifle matching the stolen weapon; he and another youth admitted to "car-hopping."
State filed a juvenile petition alleging felony Theft by Accountability (dismissed) and two misdemeanor counts; D.G.J. pled True to misdemeanor Criminal Trespass to Vehicles and Theft by Accountability.
At disposition the District Court ordered joint and several restitution of $888.00 based on a compilation chart and value estimates created and testified to by the Conrad Police Chief (values taken from police reports).
On appeal D.G.J. argued denial of due process because victims did not file affidavits or testify, that the court used replacement value rather than market value, and that the court failed to consider his ability to pay.
The State and the Supreme Court noted D.G.J. failed to preserve those specific objections at the restitution hearing; the District Court had been given only general objections (hearsay/best evidence/confrontation) and no argument about replacement vs. market value or ability to pay.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether restitution hearing violated due process because victims neither filed affidavits nor testified	Victims' absence and lack of sworn affidavits denied D.G.J. procedural due process	State: restitution evidence through police testimony/records was sufficient; trial objections were too general	Court: Issue not preserved for appeal; general objections insufficient to raise this due process claim; affirmed
Whether court erred by using replacement value instead of market value for restitution	Replacement value was improperly used, inflating restitution	State: values derived from police reports; defendant never objected on this ground at hearing	Court: Not preserved — defendant did not object below, so court did not address merits; affirmed
Whether court failed to consider defendant's ability to pay restitution	Restitution award ignored D.G.J.'s ability to pay	State: no below-hearing objection about ability to pay; record lacks challenge	Court: Not preserved for appeal; defendant didn’t raise ability-to-pay at hearing; affirmed
Whether rules of evidence apply at sentencing/restitution hearings	D.G.J. suggested reliability concerns under evidentiary/confrontation rules	State: Rules of evidence do not apply at sentencing; testimony from police was permissible	Court: Notes M. R. Evid. 101(c)(3) and precedent; objections must specify grounds to preserve issues; affirmed

State v. Kotwicki, 335 Mont. 344 (2007) (appellate courts generally refuse to review unpreserved objections)
State v. Vukasin, 317 Mont. 204 (2003) (party must make grounds of objection clear to trial court to preserve issue for appeal)
State v. Collier, 277 Mont. 46 (1996) (rules of evidence do not apply at sentencing)