Montana Code Annotated

Mont. Code Ann. § 41-3-422 (2026)

Abuse And Neglect Petitions -- Burden Of Proof

✓ current as of May 2026
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TITLE 41. MINORS

CHAPTER 3. CHILD ABUSE AND NEGLECT

Part 4. Abuse or Neglect Proceedings

Abuse And Neglect Petitions -- Burden Of Proof

41-3-422. Abuse and neglect petitions -- burden of proof. (1) (a) Proceedings under this chapter must be initiated by the filing of a petition. A petition may request the following relief:

(i) immediate protection and emergency protective services, as provided in 41-3-427;

(ii) temporary legal custody, as provided in 41-3-442;

(iii) long-term custody, as provided in 41-3-445;

(iv) termination of the parent-child legal relationship, as provided in 41-3-607;

(v) appointment of a guardian pursuant to 41-3-444;

(vi) a determination that preservation or reunification services need not be provided; or

(vii) any combination of the provisions of subsections (1)(a)(i) through (1)(a)(vi) or any other relief that may be required for the best interests of the child.

(b) The petition may be modified for different relief at any time within the discretion of the court.

(c) A petition for temporary legal custody may be the initial petition filed in a case.

(d) A petition for the termination of the parent-child legal relationship may be the initial petition filed in a case if a request for a determination that preservation or reunification services need not be provided is made in the petition.

(2) The county attorney, attorney general, or an attorney hired by the county shall file all petitions under this chapter. A petition filed by the county attorney, attorney general, or an attorney hired by the county must be accompanied by:

(a) an affidavit by the department alleging that the child appears to have been abused or neglected and stating the basis for the petition; and

(b) a separate notice to the court stating any statutory time deadline for a hearing.

(3) Abuse and neglect petitions must be given highest preference by the court in setting hearing dates.

(4) An abuse and neglect petition is a civil action brought in the name of the state of Montana. The Montana Rules of Civil Procedure and the Montana Rules of Evidence apply except as modified in this chapter. Proceedings under a petition are not a bar to criminal prosecution.

(5) (a) Except as provided in subsection (5)(b), the person filing the abuse and neglect petition has the burden of presenting evidence required to justify the relief requested and establishing:

(i) probable cause for the issuance of an order for immediate protection and emergency protective services;

(ii) a preponderance of the evidence for an order of adjudication or temporary legal custody;

(iii) a preponderance of the evidence for an order of long-term custody; or

(iv) clear and convincing evidence for an order terminating the parent-child legal relationship.

(b) If a proceeding under this chapter involves an Indian child, as defined in the federal Indian Child Welfare Act, 25 U.S.C. 1901, et seq., or 41-3-1303, the standards of proof required for legal relief under the federal Indian Child Welfare Act and the Montana Indian Child Welfare Act provided for in Title 41, chapter 3, part 13, apply.

(6) (a) Except as provided in the federal Indian Child Welfare Act and the Montana Indian Child Welfare Act, if applicable, the parents or parent, guardian, or other person or agency having legal custody of the child named in the petition, if residing in the state, must be served personally with a copy of the initial petition and a petition to terminate the parent-child legal relationship at least 5 days before the date set for hearing. If the person or agency cannot be served personally, the person or agency may be served by publication as provided in 41-3-428 and 41-3-429.

(b) Copies of all other petitions must be served upon the person or the person's attorney of record by certified mail, by personal service, or by publication as provided in 41-3-428 and 41-3-429. If service is by certified mail, the department must receive a return receipt signed by the person to whom the notice was mailed for the service to be effective. Service of the notice is considered to be effective if, in the absence of a return receipt, the person to whom the notice was mailed appears at the hearing.

(7) If personal service cannot be made upon the parents or parent, guardian, or other person or agency having legal custody, the court shall immediately provide for the appointment or assignment of an attorney as provided for in 41-3-425 to represent the unavailable party when, in the opinion of the court, the interests of justice require. If personal service cannot be made upon a putative father, the court may not provide for the appointment or assignment of counsel as provided for in 41-3-425 to represent the father unless, in the opinion of the court, the interests of justice require counsel to be appointed or assigned.

(8) If a parent of the child is a minor, notice must be given to the minor parent's parents or guardian, and if there is no guardian, the court shall appoint one.

(9) (a) Any person interested in any cause under this chapter has the right to appear. Any foster parent, preadoptive parent, or relative caring for the child must be given legal notice by the attorney filing the petition of all judicial hearings for the child and has the right to be heard. The right to appear or to be heard does not make that person a party to the action. Any foster parent, preadoptive parent, or relative caring for the child must be given notice of all reviews by the reviewing body.

(b) A foster parent, preadoptive parent, or relative of the child who is caring for or a relative of the child who has cared for a child who is the subject of the petition who appears at a hearing set pursuant to this section may be allowed by the court to intervene in the action if the court, after a hearing in which evidence is presented on those subjects provided for in 41-3-437(4), determines that the intervention of the person is in the best interests of the child. A person granted intervention pursuant to this subsection is entitled to participate in the adjudicatory hearing held pursuant to 41-3-437 and to notice and participation in subsequent proceedings held pursuant to this chapter involving the custody of the child.

(c) Whenever a child is placed with a foster parent, preadoptive parent, or relative, the department shall provide written notice to the foster parent, preadoptive parent, or relative explaining the foster parent's, preadoptive parent's, or relative's rights under this subsection (9) to receive notice, to appear and be heard, and to attempt to intervene in proceedings under this chapter.

(10) An abuse and neglect petition must state:

(a) the nature of the alleged abuse or neglect and of the relief requested;

(b) the full name, age, and address of the child and the name and address of the child's parents or the guardian or person having legal custody of the child; and

(c) the names, addresses, and relationship to the child of all persons who are necessary parties to the action.

(11) Any party in a proceeding pursuant to this section is entitled to counsel as provided in 41-3-425.

(12) At any stage of the proceedings considered appropriate by the court, the court may order an alternative dispute resolution proceeding or the parties may voluntarily participate in an alternative dispute resolution proceeding. An alternative dispute resolution proceeding under this chapter may include a family engagement meeting, mediation, or a settlement conference. If a court orders an alternative dispute resolution proceeding, a party who does not wish to participate may file a motion objecting to the order. If the department is a party to the original proceeding, a representative of the department who has complete authority to settle the issue or issues in the original proceeding must be present at any alternative dispute resolution proceeding.

(13) Service of a petition under this section must be accompanied by a written notice advising the child's parent, guardian, or other person having physical or legal custody of the child of the:

(a) right, pursuant to 41-3-425, to appointment or assignment of counsel if the person is indigent or if appointment or assignment of counsel is required under the federal Indian Child Welfare Act or the Montana Indian Child Welfare Act, if applicable;

(b) right to contest the allegations in the petition; and

(c) timelines for hearings and determinations required under this chapter.

(14) If appropriate, orders issued under this chapter must contain a notice provision advising a child's parent, guardian, or other person having physical or legal custody of the child that:

(a) the court is required by federal and state laws to hold a permanency hearing to determine the permanent placement of a child no later than 12 months after a judge determines that the child has been abused or neglected or 12 months after the first 60 days that the child has been removed from the child's home;

(b) if a child has been in foster care for 15 of the last 22 months, state law presumes that termination of parental rights is in the best interests of the child and the state is required to file a petition to terminate parental rights; and

(c) completion of a treatment plan does not guarantee the return of a child.

(15) A court may appoint a standing master to conduct hearings and propose decisions and orders to the court for court consideration and action. A standing master may not conduct a proceeding to terminate parental rights. A standing master must be a member of the state bar of Montana and must be knowledgeable in the area of child abuse and neglect laws.

History: En. 10-1310 by Sec. 6, Ch. 328, L. 1974; amd. Sec. 20, Ch. 100, L. 1977; R.C.M. 1947, 10-1310; amd. Sec. 4, Ch. 567, L. 1979; amd. Sec. 5, Ch. 511, L. 1981; amd. Sec. 2, Ch. 659, L. 1985; amd. Sec. 2, Ch. 463, L. 1987; amd. Sec. 43, Ch. 609, L. 1987; amd. Sec. 2, Ch. 329, L. 1993; amd. Sec. 11, Ch. 458, L. 1995; amd. Sec. 168, Ch. 546, L. 1995; amd. Sec. 6, Ch. 516, L. 1997; amd. Sec. 1, Ch. 428, L. 1999; amd. Sec. 8, Ch. 566, L. 1999; amd. Sec. 4, Ch. 83, L. 2001; amd. Sec. 2, Ch. 194, L. 2001; amd. Secs. 4, 18(2), Ch. 281, L. 2001; amd. Sec. 7, Ch. 311, L. 2001; Sec. 41-3-401, MCA 1999; redes. 41-3-422 by Sec. 17(2), Ch. 281, L. 2001; amd. Sec. 1, Ch. 189, L. 2003; amd. Sec. 7, Ch. 504, L. 2003; amd. Sec. 1, Ch. 118, L. 2005; amd. Sec. 30, Ch. 449, L. 2005; amd. Sec. 5, Ch. 166, L. 2007; amd. Sec. 1, Ch. 52, L. 2017; amd. Sec. 7, Ch. 19, L. 2021; amd. Sec. 1, Ch. 333, L. 2023; amd. Sec. 33, Ch. 716, L. 2023; amd. Sec. 2, Ch. 79, L. 2025.

Notes of Decisions
Cited in 78 cases (11 in the last 5 years), 2002–2026 · leading case: In re L.N., 2014 MT 187 (Mont. 2014).
In re L.N., 2014 MT 187 (Mont. 2014). · cites it 12× “Section 41-3-422(l)(a), MCA. A petition for termination of parental rights may be the initial petition filed if the petition also requests a determination that reunification services are not required.”
In re T.S.B., 2008 MT 23 (Mont. 2008). · cites it 9× “” Section 41-3-422, MCA, provides that a petitioner may request the termination of the parent-child relationship in the abuse and neglect petition.”
In re M.N., 2011 MT 245 (Mont. 2011). · cites it 8× “Section 41-3-422(4), MCA; M. R. Evid. 402.”
In re B.S., 2009 MT 98 (Mont. 2009). · cites it 9× “¶19 The relief sought in a petition filed under § 41-3-422, MCA, may include immediate protection and emergency protective services, TLA, temporary legal custody, long-term custody, termination of the parent-child legal relationship, appointment of a guardian, a determination…”
Adoption of A.W.S. & K.R.S., 2014 MT 322 (Mont. 2014). · cites it 6× “Thus, Montana’s statutes create two similarly situated classes: indigent parents facing involuntary termination of parental rights on a petition by the state under § 41-3-422, MCA, and indigent parents facing involuntary termination of parental rights in an adoption proceeding…”
In re S.R., 436 P.3d 696 (Mont. 2019). · cites it 6× “" Section 41-3-422(1)(a)(i), MCA (emphasis added).”
In re D.B., 2004 MT 371 (Mont. 2004). · cites it 5× “Section 41-3-422(5)(a)(i), MCA (2001). Subsequent discovery that the initial probable cause determination was based on faulty information does not change the fact that the district court initially had probable cause based upon information available at the time of the…”
In re A.N.W., 2006 MT 42 (Mont. 2006). · cites it 7× “Consequently, I join in the Court’s refusal to address the substantive merits of Issue Three, adding a fervent hope that the enactment of § 41-3-425, MCA (providing for the right to counsel in all proceedings involving any petition filed pursuant to § 41-3-422, MCA), and the…”
In re G.S., 2002 MT 245 (Mont. 2002). · cites it 3× “” Section 41-3-422(5)(b), MCA. Moreover, this Court has recognized the importance of preserving Indian culture, noting that the reasonable doubt standard of proof applied in ICWA “was intended *120 by Congress to stop the all-too-common removal of Indian children from their…”
In re B.J.J., 443 P.3d 488 (Mont. 2019). · cites it 3× “The district court, as the fact finder, evaluates if the Department has met its burden of presenting clear and convincing evidence regarding *494 all required elements for termination of a parent's rights.”
In Re the Adoption of K.P.M., 2009 MT 31 (Mont. 2009). · cites it 4× “NOTES [1] The Child Abuse and Neglect Act does not apply here because a termination of parental rights under that Act may only be brought by the county attorney, the attorney general, or an attorney hired by the county, § 41-3-422(2), MCA, none of whom did so in this case.”
Matter of L.H., YINC, 2021 MT 199 (Mont. 2021). · cites it 4× “§§ 1912 (e) and 1922; §§ 41-3-422(5)(a)(i),(b), -427(1)(b)-(c), and (2), MCA.”
— Mont. Code Ann. § 41-3-422(1) — 2 cases
In re D.B., 2008 MT 272 (Mont. 2008).
In Re Db, 2008 MT 272 (Mont. 2008).
— Mont. Code Ann. § 41-3-422(1)(a) — 2 cases
In the Matter of Bs, 2009 MT 98 (Mont. 2009).
Matter of S.W. & D.W., YINC, 2025 MT 178 (Mont. 2025).
— Mont. Code Ann. § 41-3-422(1)(a)(i) — 1 case
In re S.R., 436 P.3d 696 (Mont. 2019). “" Section 41-3-422(1)(a)(i), MCA (emphasis added).”
— Mont. Code Ann. § 41-3-422(1)(a)(ii) — 1 case
In re S.R., 436 P.3d 696 (Mont. 2019). “" Section 41-3-422(1)(a)(i), MCA (emphasis added).”
— Mont. Code Ann. § 41-3-422(1)(a)(iii) — 1 case
In re S.R., 436 P.3d 696 (Mont. 2019). “" Section 41-3-422(1)(a)(i), MCA (emphasis added).”
— Mont. Code Ann. § 41-3-422(1)(a)(v) — 3 cases
In the Matter of Tsb, 2008 MT 23 (Mont. 2008).
Matter of L.V-B., 2014 MT 13 (Mont. 2014).
In Re Rmt, 2011 MT 164 (Mont. 2011).
— Mont. Code Ann. § 41-3-422(1)(a)(viii) — 3 cases
In Re Jjl, 2010 MT 4 (Mont. 2010).
Matter of J.J.L. D.J.L. R.d.l.l, 2010 MT 4 (Mont. 2010).
Matter of J.J.L. D.J.L. R.d.l.l, 2010 MT 4 (Mont. 2010).
— Mont. Code Ann. § 41-3-422(1)(b) — 1 case
In the Matter of Bs, 2009 MT 98 (Mont. 2009).
— Mont. Code Ann. § 41-3-422(1)(c) — 1 case
In Re Anw, 2006 MT 42 (Mont. 2006).
— Mont. Code Ann. § 41-3-422(1)(d) — 3 cases
In the Matter of Tsb, 2008 MT 23 (Mont. 2008).
In Re Mn, 2011 MT 245 (Mont. 2011).
Matter of A.S.W. YINC, 2014 MT 251N (Mont. 2014).
— Mont. Code Ann. § 41-3-422(11) — 2 cases
Adoption of A.W.S. & K.R.S., 2014 MT 322 (Mont. 2014). “Thus, Montana’s statutes create two similarly situated classes: indigent parents facing involuntary termination of parental rights on a petition by the state under § 41-3-422, MCA, and indigent parents facing involuntary termination of parental rights in an adoption proceeding…”
In re L.F.R., 432 P.3d 1030 (Mont. 2019).
— Mont. Code Ann. § 41-3-422(12) — 1 case
Matter of K.L.N., YINC, 2021 MT 56 (Mont. 2021).
— Mont. Code Ann. § 41-3-422(13) — 2 cases
In Re L.m.a.t, 2002 MT 163 (Mont. 2002).
In Re Lmat, 2002 MT 163 (Mont. 2002).
— Mont. Code Ann. § 41-3-422(14) — 2 cases
In Re L.m.a.t, 2002 MT 163 (Mont. 2002).
In Re Lmat, 2002 MT 163 (Mont. 2002).
— Mont. Code Ann. § 41-3-422(2) — 5 cases
In Re the Adoption of K.P.M., 2009 MT 31 (Mont. 2009). “NOTES [1] The Child Abuse and Neglect Act does not apply here because a termination of parental rights under that Act may only be brought by the county attorney, the attorney general, or an attorney hired by the county, § 41-3-422(2), MCA, none of whom did so in this case.”
Adoption of A.W.S. & K.R.S., 2014 MT 322 (Mont. 2014). “Thus, Montana’s statutes create two similarly situated classes: indigent parents facing involuntary termination of parental rights on a petition by the state under § 41-3-422, MCA, and indigent parents facing involuntary termination of parental rights in an adoption proceeding…”
Bergsing v. Cardona, 2014 MT 327 (Mont. 2014).
J.C. v. Eleventh Jud. Dist. Court, 2008 MT 358 (Mont. 2008).
Matter of K.M. Jr., 2003 MT 57N (Mont. 2003).
— Mont. Code Ann. § 41-3-422(3) — 2 cases
In re A.N.W., 2006 MT 42 (Mont. 2006). “Consequently, I join in the Court’s refusal to address the substantive merits of Issue Three, adding a fervent hope that the enactment of § 41-3-425, MCA (providing for the right to counsel in all proceedings involving any petition filed pursuant to § 41-3-422, MCA), and the…”
In Re Anw, 2006 MT 42 (Mont. 2006).
— Mont. Code Ann. § 41-3-422(4) — 10 cases
In re M.N., 2011 MT 245 (Mont. 2011). “Section 41-3-422(4), MCA; M. R. Evid. 402.”
In re S.C.L., 437 P.3d 122 (Mont. 2019).
In re O.A.W., 2007 MT 13 (Mont. 2007).
In re S.C., 2005 MT 241 (Mont. 2005).
In Re L.m.a.t, 2002 MT 163 (Mont. 2002).
— Mont. Code Ann. § 41-3-422(5) — 1 case
Matters of I.D., T.D., & L.D., YINC, 2025 MT 299 (Mont. 2025).
— Mont. Code Ann. § 41-3-422(5)(a) — 1 case
In re B.J.J., 443 P.3d 488 (Mont. 2019). “The district court, as the fact finder, evaluates if the Department has met its burden of presenting clear and convincing evidence regarding *494 all required elements for termination of a parent's rights.”
— Mont. Code Ann. § 41-3-422(5)(a)(i) — 3 cases
In re D.B., 2004 MT 371 (Mont. 2004). “Section 41-3-422(5)(a)(i), MCA (2001). Subsequent discovery that the initial probable cause determination was based on faulty information does not change the fact that the district court initially had probable cause based upon information available at the time of the…”
Matter of D.B., 2004 MT 371 (Mont. 2004).
Matter of L.H., YINC, 2021 MT 199 (Mont. 2021). “§§ 1912 (e) and 1922; §§ 41-3-422(5)(a)(i),(b), -427(1)(b)-(c), and (2), MCA.”
— Mont. Code Ann. § 41-3-422(5)(a)(ii) — 4 cases
In re D.B., 2004 MT 371 (Mont. 2004). “Section 41-3-422(5)(a)(i), MCA (2001). Subsequent discovery that the initial probable cause determination was based on faulty information does not change the fact that the district court initially had probable cause based upon information available at the time of the…”
In re K.H., 2012 MT 175 (Mont. 2012).
Matter of L.H., YINC, 2021 MT 199 (Mont. 2021). “§§ 1912 (e) and 1922; §§ 41-3-422(5)(a)(i),(b), -427(1)(b)-(c), and (2), MCA.”
Matter of K.H. K.M. YINCs, 2012 MT 175 (Mont. 2012).
— Mont. Code Ann. § 41-3-422(5)(a)(iv) — 9 cases
In re A.T., 2006 MT 35 (Mont. 2006).
In re M.V.R., 2016 MT 309 (Mont. 2016).
In re K.H., 2012 MT 175 (Mont. 2012).
Matter of K.H. K.M. YINCs, 2012 MT 175 (Mont. 2012).
In Re At, 2006 MT 35 (Mont. 2006).
— Mont. Code Ann. § 41-3-422(5)(b) — 9 cases
In re G.S., 2002 MT 245 (Mont. 2002). “” Section 41-3-422(5)(b), MCA. Moreover, this Court has recognized the importance of preserving Indian culture, noting that the reasonable doubt standard of proof applied in ICWA “was intended *120 by Congress to stop the all-too-common removal of Indian children from their…”
Matter of L.H., YINC, 2021 MT 199 (Mont. 2021). “§§ 1912 (e) and 1922; §§ 41-3-422(5)(a)(i),(b), -427(1)(b)-(c), and (2), MCA.”
In re A.N., 2005 MT 19 (Mont. 2005).
In re L.A.G., 429 P.3d 629 (Mont. 2018).
In re I.B., 2011 MT 82 (Mont. 2011).
— Mont. Code Ann. § 41-3-422(5Xa)(iv) — 1 case
Bergsing v. Cardona, 2014 MT 327 (Mont. 2014).
— Mont. Code Ann. § 41-3-422(6) — 6 cases
In re A.D.B., 2013 MT 167 (Mont. 2013).
In Re L.m.a.t, 2002 MT 163 (Mont. 2002).
Matter of R.J.F., YINC, 2026 MT 125 (Mont. 2026).
Matter of R.J.F., YINC, 2026 MT 125 (Mont. 2026).
Matter of A.D.B. YINC., 2013 MT 167 (Mont. 2013).
— Mont. Code Ann. § 41-3-422(7) — 1 case
Bergsing v. Cardona, 2014 MT 327 (Mont. 2014).
— Mont. Code Ann. § 41-3-422(9) — 2 cases
Matter of R.J.F., YINC, 2026 MT 125 (Mont. 2026).
Matter of R.J.F., YINC, 2026 MT 125 (Mont. 2026).
— Mont. Code Ann. § 41-3-422(9)(a) — 8 cases
In re J.B., 2015 MT 342 (Mont. 2015).
Matter of J.B. YINC, 2015 MT 342 (Mont. 2015).
In re K.H., 2012 MT 175 (Mont. 2012).
Matter of R.J.F., YINC, 2026 MT 125 (Mont. 2026).
Matter of K.H. K.M. YINCs, 2012 MT 175 (Mont. 2012).
— Mont. Code Ann. § 41-3-422(9)(b) — 7 cases
In re J.B., 2015 MT 342 (Mont. 2015).
Matter of R.J.F., YINC, 2026 MT 125 (Mont. 2026).
Matter of J.B. YINC, 2015 MT 342 (Mont. 2015).
Matter of I.R.S. & M.w.a.h., Yincs, 2025 MT 139 (Mont. 2025).
Matter of R.J.F., YINC, 2026 MT 125 (Mont. 2026).
— Mont. Code Ann. § 41-3-422(l)(a) — 2 cases
In re B.S., 2009 MT 98 (Mont. 2009). “¶19 The relief sought in a petition filed under § 41-3-422, MCA, may include immediate protection and emergency protective services, TLA, temporary legal custody, long-term custody, termination of the parent-child legal relationship, appointment of a guardian, a determination…”
In re L.N., 2014 MT 187 (Mont. 2014). “Section 41-3-422(l)(a), MCA. A petition for termination of parental rights may be the initial petition filed if the petition also requests a determination that reunification services are not required.”
— Mont. Code Ann. § 41-3-422(l)(a)(v) — 3 cases
In re T.S.B., 2008 MT 23 (Mont. 2008). “” Section 41-3-422, MCA, provides that a petitioner may request the termination of the parent-child relationship in the abuse and neglect petition.”
In re L.V.-B., 2014 MT 13 (Mont. 2014).
In re R.M.T., 2011 MT 164 (Mont. 2011).
— Mont. Code Ann. § 41-3-422(l)(a)(viii) — 1 case
In re J.J.L., 2010 MT 4 (Mont. 2010).
— Mont. Code Ann. § 41-3-422(l)(b) — 1 case
In re B.S., 2009 MT 98 (Mont. 2009). “¶19 The relief sought in a petition filed under § 41-3-422, MCA, may include immediate protection and emergency protective services, TLA, temporary legal custody, long-term custody, termination of the parent-child legal relationship, appointment of a guardian, a determination…”
— Mont. Code Ann. § 41-3-422(l)(c) — 1 case
In re A.N.W., 2006 MT 42 (Mont. 2006). “Consequently, I join in the Court’s refusal to address the substantive merits of Issue Three, adding a fervent hope that the enactment of § 41-3-425, MCA (providing for the right to counsel in all proceedings involving any petition filed pursuant to § 41-3-422, MCA), and the…”
— Mont. Code Ann. § 41-3-422(l)(d) — 3 cases
In re L.N., 2014 MT 187 (Mont. 2014). “Section 41-3-422(l)(a), MCA. A petition for termination of parental rights may be the initial petition filed if the petition also requests a determination that reunification services are not required.”
In re T.S.B., 2008 MT 23 (Mont. 2008). “” Section 41-3-422, MCA, provides that a petitioner may request the termination of the parent-child relationship in the abuse and neglect petition.”
In re M.N., 2011 MT 245 (Mont. 2011). “Section 41-3-422(4), MCA; M. R. Evid. 402.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.