Matter of T.M.L. Youth Under 18., 268 P.3d 1255

T.M.L., a youth who turned 18 on April 30, 2010, faced youth-court charges for felony burglary and related misdemeanors.
The Youth Court disposed of the case in March 2010, placing T.M.L. on probation and planning a transfer hearing after age 18 to the district court and adult supervision.
T.M.L. turned 18 before the transfer hearing, with the Youth Court retaining jurisdiction for purposes of transfer.
In November 2010, the State filed a motion to reinstate the petition and transfer to district court under § 41-5-208 and § 41-5-1501(4).
T.M.L. moved to dismiss for lack of jurisdiction, arguing the court lost jurisdiction when he turned 18; the Youth Court denied the motion in January 2011.
In March 2011 the Youth Court transferred T.M.L. to district court, transferred supervision to adult supervision, and ordered T.M.L. to register as a sexual offender; this order is the subject of the appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the Youth Court err by retaining jurisdiction until transfer?	T.M.L. did not commit a delineated sexual offense nor sign a plea requiring registration.	State contends registration can be imposed as a condition.	The registration condition was illegal; remand to strike.

In re J.A., 255 P.3d 150 (MT 2011) (youth court jurisdiction standards and transfer timing under the Youth Court Act)
In re Cascade Co. Dist. Ct., 353 Mont. 194, 219 P.3d 1255 (MT 2009) (application of Youth Court Act standards)
K.D.K., 141 P.3d 1212 (MT 2006) (jurisdiction continuation where exceptions to 21st birthday apply; financial obligations)
Olivares-Coster, 259 P.3d 760 (MT 2011) (remedial approach for illegal sentencing conditions; remand to strike condition when possible)
Heafner, 356 Mont. 128, 231 P.3d 1087 (MT 2010) (remand when illegal sentencing provisions; framework for correction)