State v. Coburn, 428 P.3d 243

In 2015 Coburn (through an Alford plea) was convicted of deliberate homicide for causing the death of a two‑year‑old (P.N.) who suffered numerous non‑accidental blunt‑force injuries and later died.
Coburn had FASD (alcohol related neurodevelopmental disorder), ADHD, substance‑use disorders, and antisocial personality features; experts agreed on diagnoses but disagreed about causal significance at the time of the offense.
Dr. Brown (defense expert) opined Coburn’s FASD produced severe executive‑functioning loss during stress such that he could not appreciate or conform his behavior; Dr. Hill (State/DPHHS psychiatrist) concluded drugs/alcohol primarily caused the incident and that Coburn remained high‑functioning and could be managed in prison outpatient care.
The court ordered the statutorily required pre‑sentence investigation and 90‑day DPHHS observation/evaluation at the State Hospital; both experts testified at sentencing.
The District Court found Coburn failed to prove by the required evidence that a mental disease/defect rendered him unable to appreciate criminality or conform conduct under § 46‑14‑311, MCA, and sentenced him to life in MSP rather than commitment to DPHHS custody.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the court erred by sentencing Coburn to prison instead of committing him to DPHHS under § 46‑14‑311	Coburn: his FASD produced irreversible executive‑function failure at the time of the offense, so he was unable to appreciate criminality or conform his conduct	State: the court properly weighed competing expert opinions and found Coburn failed to meet his burden to show the statutory incapacity	Court affirmed: no abuse of discretion; record supports conclusion that Coburn did not prove inability to appreciate or conform his conduct

State v. Gallmeier, 349 Mont. 424, 203 P.3d 852 (district court may rely on pre‑sentence investigations and expert evaluations when deciding § 46‑14‑311 claim)
State v. Spell, 389 Mont. 172, 404 P.3d 725 (district court may find defendant able to appreciate and conform conduct despite intellectual disability where evidence supports that finding)
State v. Korell, 213 Mont. 316, 690 P.2d 992 (sentencing court must independently evaluate defendant’s mental condition and record must reflect deliberative process)
State v. Raty, 214 Mont. 114, 692 P.2d 17 (remand required where district court failed to evaluate or make any finding under § 46‑14‑311)
State v. Burke, 329 Mont. 1, 122 P.3d 427 (court may affirm imprisonment where mental diagnoses do not satisfy statutory incapacity requirements)