Matter of BD

Matter of BD, 2015 MT 339 (Dec. 8, 2015) (Rice, J.) (5-0, aff’d)

Issue: (1) Whether there was sufficient evidence to support a finding that BD required an order of involuntary commitment; and (2) whether the district court erred by failing to provide a detailed statement of the facts and basis for BD’’s commitment.

Short Answer: (1) Yes, and (2) no.

Affirmed

Facts: BD suffered a closed head injury in 2003 that led to secondary effects. He has been diagnosed with personality change due to traumatic brain injury. In February 2014, based on reports BD was not taking his medication and was decompensating, the county attorney petitioned for BD’s commitment an fro an order of apprehension, examination and treatment, which the district court issued. BD was detained and treated with medication.

Procedural Posture & Holding: The court held a commitment hearing on March 5, 2014, at which BD’s treating psychiatrist testified that BD had not picked up his medications from the pharmacy for six weeks, was increasingly paranoid, and had been making comments about obtaining a gun to protect himself. The district court issued an order for involuntary commitment. BD appeals and the Supreme Court affirms.

Reasoning: (1) BD’s increasing hostility, paranoia and suspicion, his multiple altercations with neighbors, including one that required police intervention, and his alarming comments inquiries about buying a gun support the finding that BD posed a danger to himself and others.

(2) The district court’s findings here are sufficiently detailed to satisfy the statute.