Mont. Code Ann. » TITLE 45. CRIMES · CHAPTER 2. GENERAL PRINCIPLES OF LIABILITY · Part 2. Other Factors Affecting Individual Liability
Montana Code Annotated

Mont. Code Ann. § 45-2-201 (2026)

Causal Relationship Between Conduct And Result

✓ current as of May 2026
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  1. MCA Contents
  2. TITLE 45
  3. CHAPTER 2
  4. Part 2
  5. 45-2-201 Causal relationship between conduct and result

TITLE 45. CRIMES

CHAPTER 2. GENERAL PRINCIPLES OF LIABILITY

Part 2. Other Factors Affecting Individual Liability

Causal Relationship Between Conduct And Result

45-2-201. Causal relationship between conduct and result. (1) Conduct is the cause of a result if:

(a) without the conduct the result would not have occurred; and

(b) any additional causal requirements imposed by the specific statute defining the offense are satisfied.

(2) If purposely or knowingly causing a result is an element of an offense and the result is not within the contemplation or purpose of the offender, either element can nevertheless be established if:

(a) the result differs from that contemplated only in the respect that a different person or different property is affected or that the injury or harm caused is less than contemplated; or

(b) the result involves the same kind of harm or injury as contemplated but the precise harm or injury was different or occurred in a different way, unless the actual result is too remote or accidental to have a bearing on the offender's liability or on the gravity of the offense.

(3) If negligently causing a particular result is an element of an offense and the result is not within the risk of which the offender is aware or should be aware, either element can nevertheless be established if:

(a) the actual result differs from the probable result only in the respect that a different person or different property is affected or that the actual injury or harm is less; or

(b) the actual result involves the same kind of injury or harm as the probable result, unless the actual result is too remote or accidental to have a bearing on the offender's liability or on the gravity of the offense.

History: En. 94-2-105 by Sec. 1, Ch. 513, L. 1973; R.C.M. 1947, 94-2-105.

Notes of Decisions
Cited in 34 cases (4 in the last 5 years), 1982–2025 · leading case: State v. Sigler, 688 P.2d 749 (Mont. 1984).
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State v. Sigler, 688 P.2d 749 (Mont. 1984). · cites it 25× “Section 45-2-201, MCA. Conduct is the cause of a result, as applicable to this case, if (a) without the conduct the result would not have occurred; and, (b) if the result was not within the contemplation or purpose of the offender, but the same kind of harm or injury was…”
State v. Riley, 649 P.2d 1273 (Mont. 1982). · cites it 14× “*1279 Appellant argues that, in addition to the requirement that there must be some evidence showing a "conduct" on the part of the defendant to cause the death, under the provisions of section 45-2-201, MCA, there must be some "causal relationship" between the conduct and the…”
State v. Rothacher, 901 P.2d 82 (Mont. 1995). · cites it 16× “However, the statutory meaning of both states of mind must be read in combination with § 45-2-201, MCA, which provides in relevant part that: *85 (2) If purposely or knowingly causing a result is an element of an offense and the result is not within the contemplation or purpose…”
State v. Pierce, 647 P.2d 847 (Mont. 1982). · cites it 19× “Section 45-2-201, MCA, defines “causation” in terms of the act and the mental state to be proved.”
State v. Doyle, 2007 MT 125 (Mont. 2007). · cites it 16× “We deemed the court’s error harmless, however, in light of the fact that the court properly instructed the jury based on the statutory provisions of § 45-2-201(2)(b), MCA. Rothacher, 272 Mont.”
State v. Rusty Russell, 2008 MT 417 (Mont. 2008). · cites it 10× “We have also relied on § 45-2-201, MCA, in articulating the “causal relationship” that must be shown in order to prove felony homicide.”
State v. Weinberger, 671 P.2d 567 (Mont. 1983). · cites it 12× “Our statutes define causal relationship in section 45-2-201, MCA. Conduct, under that statute, is the cause of a result if without the conduct the result would not have occurred.”
State v. C. Christensen, 2020 MT 237 (Mont. 2020). · cites it 4× “¶188 Section 45-2-201(1)(a), MCA, defines the causal relationship between the conduct and result: “Conduct is the cause of a result if .”
State v. Lantis, 1998 MT 172 (Mont. 1998). · cites it 10× “In reaching our holding, we relied on § 45-2-201(2)(b), MCA, which provides: Causal relationship between conduct and result.”
People v. Ryan N., 2001 Cal. Daily Op. Serv. 9104 (Cal. Ct. App. 2001). · cites it 3× “08 ; Mont. Code Ann. §§ 45-2-201 , 45-2-302, 45-5-102, 45-5-103; N.”
State v. Luchau, 1999 MT 336 (Mont. 1999). · cites it 15× “Whether § 61-8-410, MCA, violates Equal Protection of the laws by imposing strict liability on persons under 21 years of age for driving with an alcohol concentration of 0.”
State v. Byers, 861 P.2d 860 (Mont. 1993). · cites it 6× “Section 45-2-201, MCA, describes the causal relation between conduct and result as follows: Causal relationship between conduct and result.”
Show all 34 citing cases →
— Mont. Code Ann. § 45-2-201(1) — 2 cases
State v. Pierce, 647 P.2d 847 (Mont. 1982). “Section 45-2-201, MCA, defines “causation” in terms of the act and the mental state to be proved.”
State v. Riley, 649 P.2d 1273 (Mont. 1982). “*1279 Appellant argues that, in addition to the requirement that there must be some evidence showing a "conduct" on the part of the defendant to cause the death, under the provisions of section 45-2-201, MCA, there must be some "causal relationship" between the conduct and the…”
— Mont. Code Ann. § 45-2-201(1)(a) — 7 cases
State v. C. Christensen, 2020 MT 237 (Mont. 2020). “¶188 Section 45-2-201(1)(a), MCA, defines the causal relationship between the conduct and result: “Conduct is the cause of a result if .”
State v. Rusty Russell, 2008 MT 417 (Mont. 2008). “We have also relied on § 45-2-201, MCA, in articulating the “causal relationship” that must be shown in order to prove felony homicide.”
State Ex Rel. Kuntz v. Montana Thirteenth Jud. Dist. Court, 2000 MT 22 (Mont. 2000).
State v. Main, 2011 MT 123 (Mont. 2011).
State v. Maier, 1999 MT 51 (Mont. 1999).
— Mont. Code Ann. § 45-2-201(2) — 7 cases
State v. Pierce, 647 P.2d 847 (Mont. 1982). “Section 45-2-201, MCA, defines “causation” in terms of the act and the mental state to be proved.”
State v. Houle, 1998 MT 235 (Mont. 1998).
State v. Olivieri, 797 P.2d 937 (Mont. 1990).
State v. N. St. Marks, 2020 MT 170 (Mont. 2020).
State v. D. Dineen, 2020 MT 193 (Mont. 2020).
— Mont. Code Ann. § 45-2-201(2)(a) — 1 case
State v. Pierce, 647 P.2d 847 (Mont. 1982). “Section 45-2-201, MCA, defines “causation” in terms of the act and the mental state to be proved.”
— Mont. Code Ann. § 45-2-201(2)(b) — 9 cases
State v. Doyle, 2007 MT 125 (Mont. 2007). “We deemed the court’s error harmless, however, in light of the fact that the court properly instructed the jury based on the statutory provisions of § 45-2-201(2)(b), MCA. Rothacher, 272 Mont.”
State v. Lantis, 1998 MT 172 (Mont. 1998). “In reaching our holding, we relied on § 45-2-201(2)(b), MCA, which provides: Causal relationship between conduct and result.”
State v. Reim, 2014 MT 108 (Mont. 2014).
State v. Pierce, 647 P.2d 847 (Mont. 1982). “Section 45-2-201, MCA, defines “causation” in terms of the act and the mental state to be proved.”
State v. Schaff, 1998 MT 104 (Mont. 1998).
— Mont. Code Ann. § 45-2-201(3)(b) — 1 case
State v. K. Mullendore, 2025 MT 282 (Mont. 2025).
— Mont. Code Ann. § 45-2-201(a) — 1 case
State v. Weinberger, 671 P.2d 567 (Mont. 1983). “Our statutes define causal relationship in section 45-2-201, MCA. Conduct, under that statute, is the cause of a result if without the conduct the result would not have occurred.”
— Mont. Code Ann. § 45-2-201(l)(a) — 2 cases
State v. Probert, 719 P.2d 783 (Mont. 1986).
State v. Maier, 1999 MT 51 (Mont. 1999).
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