State v. K.J.R., 2017 MT 45

K.J.R., a delinquent youth, was adjudicated in a Montana Youth Court after admitting to an act that would be a crime if committed by an adult (2012).
The original dispositional order committed him to the supervision of the Youth Court until age 18 (or sooner release) for placement at a specified therapeutic group home, with authority to substitute if unattainable.
Over several years, K.J.R. was placed in multiple facilities and foster care homes, with numerous removals for rule violations and disruptive behavior, often spending time in detention between placements.
On September 8, 2015, the State filed a petition to revoke his Youth Court probation due to truancy, insubordination, assault, and failing to return on time; adjudicatory hearing on September 30, 2015 found violations true.
At a dispositional hearing (October 29, 2015), the Youth Court revoked the initial private, out-of-home placement and, following the probation officer and placement committee recommendations, committed K.J.R. to the Montana Department of Corrections for placement at Pine Hills Youth Correctional Facility until age 18 (or sooner released), and ordered chemical dependency treatment.
The Court later acknowledged the proceeding was framed as probation revocation but held the Youth Court had continuing authority to modify the original placement under its broad discretion, allowing recommitment to DOC despite the mischaracterization.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did Youth Court err by revoking the prior commitment and committing to DOC?	K.J.R. argues the original order had no probation terms, so revocation was unlawful.	State contends the Youth Court had continuing authority to modify dispositions and commit to DOC; any labeling as probation was procedural error, not jurisdictional.	Yes; the Court held the Youth Court acted lawfully within its authority to revoke and recommit to DOC.
Was counsel ineffective for not objecting to the revocation due to lack of probation conditions?	K.J.R. contends counsel failed to object to improper characterization, causing prejudice.	State argues no ineffective assistance given lack of clear prejudice and that due process was satisfied.	No; defense failure to object did not prejudice the result; Strickland does not apply, and record supports a lawful outcome under A.S./K.G.F.-style considerations.

In re K.J., 2010 MT 41, 355 Mont. 257, 231 P.3d 75 (Mont. 2010) (juvenile disposition and modification authority; de novo review of statutory framework)
State v. Kotwicki, 2007 MT 17, 335 Mont. 344, 151 P.3d 892 (Mont. 2007) (review of objection requirements and final disposition standards in youth/criminal contexts)
State v. Lenihan, 184 Mont. 338, 602 P.2d 997 (1979) (Mont. 1979) (final disposition/exception to review when error not raised below)
In re Mental Health of K.G.F., 2001 MT 140, 306 Mont. 1, 29 P.3d 485 (Mont. 2001) (non-strict criteria for ineffective assistance in involuntary commitment proceedings)
In re A.S., 2004 MT 62, 320 Mont. 268, 87 P.3d 408 (Mont. 2004) (special considerations for ineffective assistance in child abuse/neglect remedial proceedings)