In the Matter of CC, 2016 MT 174 (July 19, 2016) (Cotter, J.) (5-0, rev’d)
Issue: Whether the district court erred in failing to provide a detailed statement of facts justifying CC’s involuntary commitment.
Short Answer: Yes.
Reversed and remanded
Facts: In September 2014, the Lincoln County Attorney petitioned the district court for an order of involuntary commitment, alleging CC suffered from a mental disorder requiring commitment. A mental health professional form the Western Montana Mental Health Center requested the petition be filed, asserting that CC posed an imminent danger to herself and others. The district court issued an order finding probable cause and appointing an attorney, a statutory friend, and a professional person. Upon request by her attorney, CC was examined by a professional person of her own choosing. In October 2014, the district court concluded CC did not suffer from a mental disease and dismissed the petition.
Two weeks later, a police officer was dispatched to CC’s home at about 5 am via a 911 call. The officer spoke with CC for several minutes, and while her behavior was unusual and she had a loaded shotgun, the officer concluded no further action was necessary.
Several days later, the officer responded to a call from CC’s neighbor, who reported that CC was on her front porch at 4:45am and that she felt threatened by CC’s odd behavior and threatening statements. The officer arrested CC for disorderly conduct. While transporting CC to detention, the officer heard her having a conversation with Satan, in which CC was saying that some unidentified male, presumably the officer, must be killed before CC arrived at the jail. CC was booked, and the officer found ammunition in her pockets but no weapons. The jail staff transported her to the ER for a mental health evaluation, which occurred several hours later. Nancy Huus, who evaluated CC, found CC calm and functional when she examined her.
The next day, the Lincoln County Attorney filed a second petition seeking involuntary commitment die to mental disorder. The district court held a hearing and both the officer and Huus testified. Huus testified that CC displayed symptoms of paranoid schizophrenia, and recommended that CC be committed to the state hospital for observation, assessment, and treatment.
The district court held an adjudicatory hearing a few days later. Huus, the officer, the neighbor, the neighbor’s sister, and CC testified.
Procedural Posture & Holding: At the conclusion of the hearing, the district court orally concluded that CC should be involuntarily committed to the Montana State Hospital for 90 days. The state presented the court with a prepared order, which the court signed, and which included findings and conclusions. After the hearing, CC moved to amend the written order to conform to the oral pronouncement, noting the oral pronouncement did not include a finding of need nor a hospital authorization for involuntary medication. The district court denied the motion. CC appeals, and the Supreme Court reverses.
Reasoning: Section 53-21-127(8)(a) requires a district court to make a detailed statement of facts to support an involuntary commitment order. The state urges the court to apply the doctrine of implied findings, which the Court has occasionally done in involuntary commitment cases. It declines to do so here, as that would require expanding the doctrine to affirm a commitment order “that is beyond ‘bare-bones’ and ‘spartan.’” ¶ 23.