Montana Code Annotated

Mont. Code Ann. § 41-3-604 (2026)

When Petition To Terminate Parental Rights Required

✓ current as of May 2026
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TITLE 41. MINORS

CHAPTER 3. CHILD ABUSE AND NEGLECT

Part 6. Parent-Child LegalRelationship Termination -- Reinstatement

When Petition To Terminate Parental Rights Required

41-3-604. When petition to terminate parental rights required. (1) If a child has been in foster care under the physical custody of the state for 15 months of the most recent 22 months, the best interests of the child must be presumed to be served by termination of parental rights. If a child has been in foster care for 15 months of the most recent 22 months or if the court has found that reasonable efforts to preserve or reunify a child with the child's parent or guardian are not required pursuant to 41-3-423, a petition to terminate parental rights must be filed unless:

(a) the child is being cared for by a relative;

(b) the department has not provided the services considered necessary for the safe return of the child to the child's home; or

(c) the department has documented a compelling reason, available for court review, for determining that filing a petition to terminate parental rights would not be in the best interests of the child.

(2) Compelling reasons for not filing a petition to terminate parental rights include but are not limited to the following:

(a) There are insufficient grounds for filing a petition.

(b) There is adequate documentation that termination of parental rights is not the appropriate plan and not in the best interests of the child.

(3) If a child has been in foster care for 15 months of the most recent 22 months and a petition to terminate parental rights regarding that child has not been filed with the court, the department shall file a report to the court or review panel at least 3 days prior to the next hearing or review detailing the reasons that the petition was not filed.

(4) If a hearing results in a finding of abandonment or that the parent has subjected the child to any of the circumstances listed in 41-3-423(2)(a) through (2)(e) and that reasonable efforts to provide preservation or reunification are not necessary, unless there is an exception made pursuant to subsections (1)(a) through (1)(c) of this section, a petition to terminate parental rights must be filed within 60 days of the finding.

(5) If an exception in subsections (1)(a) through (1)(c) of this section applies, a petition for an extension of temporary legal custody pursuant to 41-3-438, a petition for long-term custody pursuant to 41-3-445, or a petition to dismiss must be filed.

(6) A hearing on a petition for termination of parental rights must be held no later than 45 days from the date the petition was served on the parent or parents, except for good cause shown.

History: En. Sec. 14, Ch. 566, L. 1999; amd. Sec. 16, Ch. 311, L. 2001; amd. Sec. 15, Ch. 504, L. 2003; amd. Sec. 2, Ch. 131, L. 2017.

Notes of Decisions
Cited in 130 cases (21 in the last 5 years), 2001–2026 · leading case: In re D.B., 2007 MT 246 (Mont. 2007).
In re D.B., 2007 MT 246 (Mont. 2007). · cites it 18× “¶22 Section 41-3-604, MCA, provides that when a child has been in foster care for fifteen of the last twenty-two months, “the best interests of the child must be presumed to be served by termination of parental rights.”
In re R.J.F., 443 P.3d 387 (Mont. 2019). · cites it 7× “The Department asserts, pursuant to § 41-3-604(1), MCA, termination of Mother's parental rights is presumed to be in Child's best interest.”
In re C.W.E., 2016 MT 2 (Mont. 2016). · cites it 15× “Did the District Court improperly rely on the statutory presumption contained in § 41-3-604(1), MCA, to conclude that termination of Mother’s parental rights was in her children’s best interests? 3.”
In Re the Custody & Parental Rights of D.A., 2008 MT 247 (Mont. 2008). · cites it 6× “Section 41-3-604(1), MCA. ¶22 Complete compliance by the parents with a treatment plan is required; partial or even substantial compliance is insufficient under § 41-3-609(1)(f)(i), MCA.”
Matter of D.B. & D.B. YINC., 2007 MT 246 (Mont. 2007). · cites it 18× “¶22 Section 41-3-604, MCA, provides that when a child has been in foster care for fifteen of the last twenty-two months, “the best interests of the child must be presumed to be served by termination of parental rights.”
Matter of J.B. Jr. YINC, 2016 MT 68 (Mont. 2016). · cites it 4× “2 It is insignificant here that the District Court articulated this finding to follow the language in § 41-3-609(1)(f)(ii), MCA, and not § 41-3-609(1)(f)(i), MCA. The District Court could have satisfied both subsections by finding “the treatment plan was unsuccessful because of…”
Matter of A.B., YINC, 2020 MT 64 (Mont. 2020). · cites it 4× “was in out-of-home placement with Grandmother for almost all of the most recent twenty-two months when the Department filed its Termination Petition. ¶33 The District Court found that Mother did not overcome the presumption that termination of her parental rights was in A.”
In re B.M., 2010 MT 114 (Mont. 2010). · cites it 6× “¶19 Section 41-3-604(1), MCA, provides that the best interests of the child must be presumed to be served by termination of parental rights if a child has been “under the physical custody of the state” for 15 months of the most recent 22 months.”
In re E.K., 2001 MT 279 (Mont. 2001). · cites it 3× “Section 41-3-604(1), MCA. These children began living with their foster family on May 7, 1999, and had lived with them continuously for ninbteen months as of the hearing to terminate parental rights.”
In re A.S., 2006 MT 281 (Mont. 2006). · cites it 10× “Section 41-3-604(1), MCA, entitled “[w]hen petition to terminate parental rights required” presumes that if a child has been in foster care for 15 of the most recent 22 months, it is in the best interests of the child to terminate parental rights. A.N. W., ¶ 54.”
In re T.N.-S., 2015 MT 117 (Mont. 2015). · cites it 6× “¶27 Even if we assume for the sake of argument that failing to require a chemical dependency evaluation and treatment violated Mother’s rights, the children’s best interests outweigh Mother’s right to parent. Mother does not argue that the District Court’s conclusion that…”
In re A.N.W., 2006 MT 42 (Mont. 2006). · cites it 7× “” ¶54 Section 41-3-604(1), MCA, entitled “[w]hen petition to terminate parental rights required” presumes that if a child has been in foster *220 care for 15 of the most recent 22 months, it is in the best interests of the child to terminate parental rights.”
— Mont. Code Ann. § 41-3-604(1) — 105 cases
In re C.W.E., 2016 MT 2 (Mont. 2016). “Did the District Court improperly rely on the statutory presumption contained in § 41-3-604(1), MCA, to conclude that termination of Mother’s parental rights was in her children’s best interests? 3.”
In re R.J.F., 443 P.3d 387 (Mont. 2019). “The Department asserts, pursuant to § 41-3-604(1), MCA, termination of Mother's parental rights is presumed to be in Child's best interest.”
In Re the Custody & Parental Rights of D.A., 2008 MT 247 (Mont. 2008). “Section 41-3-604(1), MCA. ¶22 Complete compliance by the parents with a treatment plan is required; partial or even substantial compliance is insufficient under § 41-3-609(1)(f)(i), MCA.”
In re D.B., 2007 MT 246 (Mont. 2007). “¶22 Section 41-3-604, MCA, provides that when a child has been in foster care for fifteen of the last twenty-two months, “the best interests of the child must be presumed to be served by termination of parental rights.”
Matter of J.B. Jr. YINC, 2016 MT 68 (Mont. 2016). “2 It is insignificant here that the District Court articulated this finding to follow the language in § 41-3-609(1)(f)(ii), MCA, and not § 41-3-609(1)(f)(i), MCA. The District Court could have satisfied both subsections by finding “the treatment plan was unsuccessful because of…”
— Mont. Code Ann. § 41-3-604(1)(a) — 4 cases
Matter of A.B., YINC, 2020 MT 64 (Mont. 2020). “was in out-of-home placement with Grandmother for almost all of the most recent twenty-two months when the Department filed its Termination Petition. ¶33 The District Court found that Mother did not overcome the presumption that termination of her parental rights was in A.”
Matter of C.L. J.L. H.L. L.L., 2008 MT 196N (Mont. 2008).
Matter of C.L. J.L. H.L. L.L., 2008 MT 196N (Mont. 2008).
Matter of C.L. J.L. H.L. L.L., 2008 MT 196N (Mont. 2008).
— Mont. Code Ann. § 41-3-604(1)(b) — 3 cases
In re R.J.F., 443 P.3d 387 (Mont. 2019). “The Department asserts, pursuant to § 41-3-604(1), MCA, termination of Mother's parental rights is presumed to be in Child's best interest.”
In re T.H., 2005 MT 237 (Mont. 2005).
In Re Th, 2005 MT 237 (Mont. 2005).
— Mont. Code Ann. § 41-3-604(1)(c) — 2 cases
Matter of B.N.Y., 2006 MT 34 (Mont. 2006).
Matter of J.H. J.H. & T.D.H., 2015 MT 244 (Mont. 2015).
— Mont. Code Ann. § 41-3-604(1)(d) — 1 case
Matter of W.B.A., YINC, 2025 MT 300N (Mont. 2025).
— Mont. Code Ann. § 41-3-604(3) — 2 cases
In re D.B., 2008 MT 272 (Mont. 2008).
In Re Db, 2008 MT 272 (Mont. 2008).
— Mont. Code Ann. § 41-3-604(5) — 1 case
Matter of L.M. N.M., 2003 MT 323N (Mont. 2003).
— Mont. Code Ann. § 41-3-604(l)(b) — 2 cases
In re K.L., 2014 MT 28 (Mont. 2014).
In re T.H., 2005 MT 237 (Mont. 2005).
— Mont. Code Ann. § 41-3-604(l)(c) — 2 cases
In re T.D.H., 2015 MT 244 (Mont. 2015).
In re B.N.Y., 2006 MT 34 (Mont. 2006).
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.