Justia Health Law Opinion Summaries

Articles Posted in Montana Supreme Court
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This case involves an appeal against a judgment from the Montana Eighteenth Judicial District Court, Gallatin County, which committed the appellant, G.M., into the custody and care of the Montana State Hospital (MSH) for involuntary mental health treatment. The key issue at hand is whether the District Court erroneously found that G.M. was unable to adequately care for her own basic needs and safety based on hearsay statements made by her husband through the testimony of a court-appointed professional.G.M., aged 66 at the time of the petition for involuntary mental health commitment in 2021, was alleged to be suffering from a diagnosed psychotic mental disorder. G.M.'s husband's statements, along with her own behavior and assessments from mental health professionals, were the basis for the court's decision. G.M.'s counsel repeatedly objected to the court-appointed professional's testimony regarding her husband's out-of-court statements, but these objections were overruled.G.M. testified on her own behalf, denying having a mental disorder or requiring treatment. Despite this, the District Court found that due to her diagnosed schizophrenic and delusional mental disorder, G.M. was “substantially unable to provide for her own basic needs of food, clothing, shelter, health, or safety."On appeal, the Supreme Court of the State of Montana affirmed the judgment of the lower court. The court found that the lower court's decision was not clearly erroneous and was supported by substantial admissible evidence. The court stated that the hearsay statements of G.M.'s husband were admissible under the rules of evidence to explain the underlying rationale for the court-appointed professional person's expert opinion. The court also noted that the judgment was independently supported by the professional person's personal observations and opinions on G.M.'s condition and ability to care for her own needs and safety. View "In re Matter of G.M." on Justia Law

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The case involves an appellant, M.T.H., who was arrested for criminal endangerment after he pulled the steering wheel in his mother's vehicle while she was driving. M.T.H. was diagnosed with major depressive disorder and paranoid schizophrenia. Following his arrest, the State filed a petition for M.T.H.'s involuntary commitment to the Montana State Hospital (MSH) for up to three months. The District Court of the Twenty-First Judicial District, Ravalli County, ordered his commitment and authorized MSH to involuntarily administer medications to M.T.H. This led to an appeal to the Supreme Court of the State of Montana.The Supreme Court of Montana had two main issues to consider. The first issue was whether the District Court erroneously determined that a signed waiver constituted a sufficient record to commit M.T.H. The Supreme Court found that M.T.H.'s waiver and the District Court’s order committing him were sufficient to constitute an intentional and knowing waiver under the relevant statute. The court emphasized that the record reflected that M.T.H. understood his procedural rights and had a clear presence of mind to consider his position logically.The second issue was whether the District Court erroneously authorized MSH to administer involuntary medications to M.T.H. The Supreme Court held that the District Court erred in this aspect. It emphasized the importance of due process protections and noted that the State must demonstrate a need for involuntary medication before a court may authorize it. In this case, the State did not make this necessary showing. Therefore, the Supreme Court affirmed the District Court’s decision in part but reversed its decision to authorize involuntary medication for M.T.H. View "In re M.T.H." on Justia Law

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The Supreme Court reversed the oral pronouncement issued by the district court waiving Appellant's right to be physically present at his commitment hearing and the findings of fact, conclusions of law, and order of commitment issued by the district court, holding that the court committed reversible error by waiving Appellant's right to physically appear.The State filed a petition for involuntary commitment of Appellant supported by a mental health evaluation. Appellant advised the court that he desired to be present in-person at the commitment hearing. At the time of the hearing, however, counsel represented that he wished to waive Appellant's appearance and instead have him appear via two-way video conferencing due to improper behavior. The district court granted counsel's request and permitted him to appear via two-way video communication. The district court subsequently committed Appellant to the Montana State Hospital and authorized the use of involuntary medication. The Supreme Court reversed, holding that the statutory requirements for waiver of physical presence at the commitment hearing were not met. View "In re J.D.L." on Justia Law

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The Supreme Court affirmed in part and remanded in part the order of the district court denying Plaintiffs' application to preliminarily enjoin the State from enforcing House Bill 702, a "vaccination discrimination law," as enacted by the Legislature and signed by the Governor, holding that the district court did not abuse its discretion in declining to issue the preliminary injunction.HB 702, codified as Mont. Code Ann. 49-2-312, was an act "prohibition discrimination based on a person's vaccination status." Plaintiffs sought to preserve their ability to enforce a vaccine mandate on current and prospective employees by bringing this action. The lower court dismissed the complaint, ruling that Plaintiffs failed to satisfy their burden of establishing a prima facie case that they would suffer irreparable harm caused by implantation of the law prior to the final resolution of the case. The Supreme Court remanded in part, holding (1) the court's decision to deny preliminary injunctive relief did not constitute a manifest abuse of discretion; and (2) the court did not manifestly abuse its discretion in denying preliminary injunctive relief prior to final resolution on the merits. View "Netzer v. State" on Justia Law

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The Supreme Court reversed the order of the district court committing Appellant to the Montana State Hospital at Warm Springs for a period of up to ninety days, holding that the district court committed reversible error when it allowed a professional person to testify by telephone over Appellant's objection.The State filed a petition for Appellant's involuntary commitment due to her disorganized thinking and confusion. At a hearing on the petition, the State called Amanda Torres, a licensed clinical professional counselor, to testify by telephone due to technical difficulties with courtroom video capabilities. The district court overruled Appellant's rejection and allowed Torres to testify by telephone. Relying on Torres's testimony, the district court concluded that Appellant suffered from a mental disorder and required commitment. The Supreme Court reversed, holding that the district court erroneously overruled Appellant's objection and that the court was statutorily mandated to prohibit Torres's testimony by telephone because it did not satisfy the requirement for two-way audio-video communication and because Appellant objected. View "In re S.E." on Justia Law

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The Supreme Court affirmed the district court's grant of a preliminary injunction temporarily enjoining the implementation of three laws the Legislature enacted in 2021 that regulate or restrict abortion services, holding that there was no error of law or manifest abuse of discretion.In 2021, the Montana Legislature passed into law and the governor signed into law bills regulating or restricting abortions services and providing for various criminal penalties and civil remedies. The district court granted a preliminary injunction, finding that Plaintiffs made a prima facie showing that the challenged laws violated their rights under the Montana Constitution and determining that Plaintiffs would suffer irreparable injury if the challenged laws took effect. The Supreme Court affirmed, holding that either ground on which the district court granted a preliminary injunction would have been sufficient to justify relief. View "Planned Parenthood of Montana v. State" on Justia Law

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The Supreme Court accepted certification of two questions by the United States Court of Appeals for the Ninth Circuit regarding whether a charitable write-off of medical expenses may be recovered as damages or is subject to the collateral source rule.Specifically, the Supreme Court concluded (1) for a claim that accrued prior to the effective date of Mont. Code Ann. 27-1-308 a plaintiff in a survival action may not recover the reasonable value of medical care and related services when the costs of such services or care are wholly written off under the provider's charitable care program and the patient receives a zero-balance bill; and (2) for a claim that accrued prior to the effective date of Mont. Code Ann. 27-1-308, such a charitable care write-off is not a collateral source within the meaning of section 27-1-307. View "Gibson v. United States" on Justia Law

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The Supreme Court reversed the judgment of the district court involuntarily committing Respondent to the Montana State Hospital, holding that the waiver of Respondent's presence at the initial hearing on the State's petition was invalid.The Flathead County Attorney filed a petition for involuntary commitment, and the district court convened an initial appearance. Respondent, who suffered from vascular dementia and was hard of hearing, was not present in court, and his counsel asked to waive his presence at the initial hearing. The district court agreed to waive the initial appearance. After a hearing, the court found that Respondent suffered from a mental disorder and required commitment. The Supreme Court reversed, holding (1) the district court did not meet the statutory standards when it accepted counsel's waiver of Respondent's presence; and (2) the error prejudiced Respondent's substantial rights and compromised the integrity of the judicial process required in commitment proceedings. View "In re F.S." on Justia Law

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The Supreme Court affirmed the order issued by the district court concerning the conservatorship and estate planning efforts of Appellant's elderly mother, H.D.K., holding that the district court did not err or abuse its discretion.Specifically, the Supreme Court held that the district court (1) did not abuse its discretion when it declined to issue a scheduling order; (2) did not abuse its discretion in declining to quash a subpoena for the file of H.D.K.'s attorney; (3) did not abuse its discretion when it concluded the conservatorship hearing after three days; (4) did not err when it issued findings regarding how H.D.K. intended to allocate her estate; (5) did not err by determining the present values of the properties in H.D.K.'s estate; and (6) did not err when it found H.D.K. had testamentary capacity. View "In re H.D.K." on Justia Law

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The Supreme Court affirmed the order of the district court recommitting B.A.F. to the Montana Mental Health Nursing Care Center (MMHNCC) for a period of one year, holding that the district court did not err.In 2016, B.A.F., who had been diagnosed with paranoid schizophrenia and antisocial personality disorder, was involuntarily committed to the MMHNCC for his mental illness. The district court extended B.A.F.'s initial commitment period by one year each in 2017, 2018, and 2019. In this case, B.A.F. appealed the district court's 2019 order for recommitment, arguing that the court erred when it recommitted him without a post-petition mental health evaluation by a court-appointed professional, as statutorily required. The Supreme Court affirmed, holding that B.A.F. failed to establish that the district court's error resulted in substantial prejudice, and therefore, B.A.F. did not meet the second prong of plain-error review. View "In re B.A.F." on Justia Law