Matter of MP-L

Matter of MP-L, 2015 MT 338 (Dec. 2, 2015) (Wheat, J.; McKinnon, J., concurring) (5-0, aff’d)

Issue: (1) Whether the district court erred in failing to provide a detailed statement of facts supporting its finding that MP-L required commitment in its first order; (2) whether the district court’s second order was procedurally invalid; and (3) whether the district court’s two orders together provide a sufficiently detailed statement of facts.

Short Answer: (1) Yes. The state acknowledges the order does not conform to the statute; (2) no; and (3) yes.

Affirmed

Facts: In May 2014, MP-L suffered a series of events triggered by her inability to obtain her depression/anxiety medication because of issues with Medicaid. She was voluntarily admitted to a crisis facility on May 27, 2014, and determined to be at high risk of suicide. The state petitioned for involuntary commitment on May 30, 2014, stating that she posed an unreasonable risk of danger to herself or others.

Procedural Posture & Holding: MP-L appeared by videoconference, said she was back on her medication, would see her counselor, and would like to go home to be with her family and friends. The mental health professional from the crisis center testified that he could not predict whether MP-L would follow through, and MP-L declined voluntary commitment, leaving the Montana State Hospital as the only option. The district court determined MP-L should be involuntarily committed at MSH for no more than 90 days. MP-L appeals and the Supreme Court affirms. 

Reasoning: The Court reiterates that district courts must strictly adhere to the statutory requirements for an involuntary commitment. Although the court’s first order did not contain findings sufficient under the statute, the second order three days later corrected that. Viewed as a whole, the findings in both orders are supported by the evidence and the record.

Justice McKinnon’s Concurrence: Justice McKinnon would affirm solely by holding that the district court’s findings and reasoning are supported by the evidence at the commitment hearing.