Matter of J.W. a Youth, 2016 MT 330

In 2013 J.W. pled true to two counts of sexual intercourse without consent and one count of solicitation; youth court designated him a delinquent youth and serious juvenile offender and placed him on probation with a requirement to complete a sexual offender treatment program (SOTP).
After violating probation by having unsupervised contact with a minor, the youth court revoked probation in June 2014, committed J.W. to DOC placement at Pine Hills Youth Correctional Facility until 18, and ordered completion of Pine Hills phases I–II SOTP.
J.W. entered the SOTP in July 2014, was expelled in March 2015, and the State later moved to transfer jurisdiction to district court under § 41-5-208, MCA, to ensure compliance with the treatment requirement.
The State’s first transfer motion was denied because an attached letter referenced polygraph results; a revised motion (without polygraph reference) was later filed and the hearing proceeded after J.W. turned 18 and was released to his parents.
The youth court admitted evidence including a letter from J.W. acknowledging termination from the SOTP, denied his suppression/strike motions, ordered him to remain on house arrest pending further proceedings, and transferred the case to district court to ensure completion of the SOTP.
The district court adopted the interim house-arrest order; J.W. appealed the transfer and the interim house-arrest conditions. The Supreme Court affirmed.

Issue	Plaintiff's Argument (J.W.)	Defendant's Argument (State)	Held
Whether youth court erred by transferring the case to district court under § 41-5-208	Transfer relied on evidence tainted by polygraph and statements to treatment providers that should be suppressed; transfer violates double jeopardy	Transfer was authorized to ensure compliance with the youth-court disposition because J.W. failed to complete SOTP; admission of the letter was proper and polygraph was not the basis	Transfer affirmed: undisputed failure to complete SOTP justified transfer; no double-jeopardy violation
Whether youth and district courts erred by imposing restrictive house arrest pending final disposition	House-arrest conditions exceeded statutory limits and were improper once J.W. turned 18	Court had jurisdiction to continue supervision and impose conditions to ensure compliance with disposition; district court may impose conditions consistent with youth disposition	Interim house arrest upheld as consistent with disposition, but State concedes and Court instructs district court to comply with statutory limits if house arrest continues

In re S.M.K.-S.H., 367 Mont. 176, 290 P.3d 718 (Mont. 2012) (standard of review for youth court legal conclusions and factual findings)
In re Z.M., 337 Mont. 278, 160 P.3d 490 (Mont. 2007) (standard for reviewing youth court factual findings)
In re A.D.T., 379 Mont. 452, 351 P.3d 682 (Mont. 2015) (district court may impose conditions consistent with youth-court disposition)
In re N.V., 320 Mont. 442, 87 P.3d 510 (Mont. 2004) (youth court error where psychological evaluation relied on polygraph information)
State v. Anderson, 293 Mont. 472, 977 P.2d 315 (Mont. 1999) (sentence reversed where probation officer’s recommendation relied on psychosexual evaluation using polygraph results)