In the Matter of G.M.

Summary

The Montana Supreme Court reviewed two orders committing G.M. to the Montana State Hospital for treatment of a mental disorder. It held that the district court retained jurisdiction over a subsequent commitment petition despite G.M.'s pending appeal of an earlier order. The court nevertheless reversed both commitment orders because the district court failed to provide the detailed factual findings required by Montana law.

Holdings

1. The pending appeal divested the District Court of jurisdiction only over the May 5, 2006 order from which the appeal was taken; it did not divest the court of jurisdiction over a subsequent commitment petition merely because that petition was filed under the same cause number.
2. A civil commitment order must contain a detailed statement of the facts supporting the findings that the respondent suffers from a mental disorder and requires commitment. Conclusory restatements of statutory criteria and vague references to testimony do not satisfy that requirement.

Questions Presented

1. Whether the District Court had subject matter jurisdiction to consider the State's June 2, 2006 petition for civil commitment after G.M. appealed the May 5, 2006 commitment order filed under the same cause number.
2. Whether the District Court's statements of facts in its May 5, 2006 and June 9, 2006 orders sufficiently supported its determinations that G.M. was suffering from a mental disorder and required commitment.

Disposition

reversed