Montana Code Annotated

Mont. Code Ann. § 46-18-116 (2026)

Judgment -- Conflict Between Written Judgment And Oral Pronouncement -- Correction Of Factually Erroneous Sentence Or Judgment

✓ current as of May 2026
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TITLE 46. CRIMINAL PROCEDURE

CHAPTER 18. SENTENCE AND JUDGMENT

Part 1. Policy and Preliminary Procedure

Judgment -- Conflict Between Written Judgment And Oral Pronouncement -- Correction Of Factually Erroneous Sentence Or Judgment

46-18-116. Judgment -- conflict between written judgment and oral pronouncement -- correction of factually erroneous sentence or judgment. (1) The judgment must set forth the plea, the verdict or finding, and the adjudication. If the defendant is convicted, it must set forth the sentence or other disposition. The written judgment must be signed and must be entered on the record within 30 days after the oral pronouncement of the disposition of the case. At the time that the judgment is filed, the prosecutor of the county in which the sentence was imposed shall serve a copy of the judgment on the defendant. The written judgment must include a statement of the rights set forth in subsection (2).

(2) If a written judgment and an oral pronouncement of sentence or other disposition conflict, the defendant or the prosecutor in the county in which the sentence was imposed may, within 120 days after filing of the written judgment, request that the court modify the written judgment to conform to the oral pronouncement. The court shall modify the written judgment to conform to the oral pronouncement at a hearing, and the defendant must be present at the hearing unless the defendant waives the right to be present or elects to proceed pursuant to 46-18-115. The defendant and the prosecutor waive the right to request modification of the written judgment if a request for modification of the written judgment is not filed within 120 days after the filing of the written judgment in the sentencing court.

(3) The court may correct a factually erroneous sentence or judgment at any time. Illegal sentences must be addressed in the manner provided by law for appeal and postconviction relief.

History: En. Sec. 222, Ch. 800, L. 1991; amd. Sec. 1, Ch. 74, L. 2001; amd. Sec. 1, Ch. 141, L. 2003.

Notes of Decisions
Cited in 70 cases (21 in the last 5 years), 1996–2026 · leading case: State v. Ferguson, 2005 MT 343 (Mont. 2005).
State v. Ferguson, 2005 MT 343 (Mont. 2005). · cites it 18× “Did the District Court err in not granting Ferguson’s Motion to Dismiss for failure to enter a written judgment on the record within the time period established at § 46-18-116(1), MCA? ¶9 7. Did the proceedings contain cumulative error sufficient to warrant a new trial? FACTUAL…”
State v. Kroll, 2004 MT 203 (Mont. 2004). · cites it 21× “In response, the State submits that Kroll waived his right to complain about the imposition of these conditions because he failed to seek modification of the written judgment within the time provided by § 46-18-116, MCA. For the reasons set forth below, we conclude the District…”
State v. Legg, 2004 MT 26 (Mont. 2004). · cites it 8× “Although Legg made his motion pursuant to § 46-18-116, MCA, Legg failed to establish, or even discuss, the existence of a conflict between the oral pronouncement of sentence and the written judgment.”
State v. Petersen, 2011 MT 22 (Mont. 2011). · cites it 8× “¶11 Petersen further claims that while § 46-18-116(3), MCA, “empowers district courts to ‘correct a factually erroneous sentence or *204 judgment at any time,’ ” the sentence imposed here was not a factually erroneous sentence capable of correction under this statute. Petersen…”
State v. Damon, 2025 MT 12 (Mont. 2025). · cites it 12× “¶10 Section 46-18-116, MCA, does not apply to Damon’s situation.”
State v. Megard, 2006 MT 84 (Mont. 2006). · cites it 8× “¶18 The oral pronouncement from the bench, while confusing, does not conflict with the written judgments.”
State v. Tweedy, 922 P.2d 1134 (Mont. 1996). · cites it 6× “We note that, in 1991, the legislature enacted § 46-18-116, MCA, which provides as follows: The judgment must set forth the plea, verdict or finding, and the adjudication.”
State v. Lane, 1998 MT 76 (Mont. 1998). · cites it 4× “¶ 60 In this regard, I note that the last sentence of § 46-18-116, MCA, states that "[t]he judgment must be signed and entered on the record.”
State v. Malloy, 2004 MT 377 (Mont. 2004). · cites it 4× “This Court has further held, nothing in the 2001 legislative amendments to § 46-18-116, MCA, “supercedes or modifies this Court’s holding in Lane , which established the oral pronouncement of sentence as the legally effective and valid final judgment .”
State v. Liefert, 2002 MT 48 (Mont. 2002). · cites it 4× “2d 1134 , we were confronted with the question of whether the provisions of § 46-18-116, MCA (dealing with the requirement of a signed judgment), should apply to proceedings in justice court, which were prescribed by the provisions of Chapter 17 of Title 46.”
State v. Lucero, 2004 MT 248 (Mont. 2004). · cites it 15× “¶ 21 Did the District Court err by imposing conditions in the written judgment that it did not impose at the oral pronouncement of sentence? ¶ 22 Section 46-18-116, MCA, pertains to correction of the written judgment and provides in relevant part: (2) If a written judgment and…”
State v. Duong, 2015 MT 70 (Mont. 2015). · cites it 3× “Section 46-18-116, MCA, provides that a written judgment must comport with the court’s oral pronouncement of sentence.”
Mont. Code Ann. § 46-18-116(1): 4 cases
State v. Ferguson, 2005 MT 343 (Mont. 2005). “Did the District Court err in not granting Ferguson’s Motion to Dismiss for failure to enter a written judgment on the record within the time period established at § 46-18-116(1), MCA? ¶9 7. Did the proceedings contain cumulative error sufficient to warrant a new trial? FACTUAL…”
State v. McDanold, 2004 MT 167 (Mont. 2004).
Clifford v. State, 2007 MT 55N (Mont. 2007).
State v. McDonald, 2004 MT 167 (Mont. 2004).
Mont. Code Ann. § 46-18-116(2): 15 cases
State v. Legg, 2004 MT 26 (Mont. 2004). “Although Legg made his motion pursuant to § 46-18-116, MCA, Legg failed to establish, or even discuss, the existence of a conflict between the oral pronouncement of sentence and the written judgment.”
State v. Malloy, 2004 MT 377 (Mont. 2004). “This Court has further held, nothing in the 2001 legislative amendments to § 46-18-116, MCA, “supercedes or modifies this Court’s holding in Lane , which established the oral pronouncement of sentence as the legally effective and valid final judgment .”
State v. Lucero, 2004 MT 248 (Mont. 2004). “¶ 21 Did the District Court err by imposing conditions in the written judgment that it did not impose at the oral pronouncement of sentence? ¶ 22 Section 46-18-116, MCA, pertains to correction of the written judgment and provides in relevant part: (2) If a written judgment and…”
State v. Andress, 2013 MT 12 (Mont. 2013).
State v. Damon, 2025 MT 12 (Mont. 2025). “¶10 Section 46-18-116, MCA, does not apply to Damon’s situation.”
Mont. Code Ann. § 46-18-116(3): 25 cases
State v. Petersen, 2011 MT 22 (Mont. 2011). “¶11 Petersen further claims that while § 46-18-116(3), MCA, “empowers district courts to ‘correct a factually erroneous sentence or *204 judgment at any time,’ ” the sentence imposed here was not a factually erroneous sentence capable of correction under this statute. Petersen…”
State v. Damon, 2025 MT 12 (Mont. 2025). “¶10 Section 46-18-116, MCA, does not apply to Damon’s situation.”
State v. Megard, 2006 MT 84 (Mont. 2006). “¶18 The oral pronouncement from the bench, while confusing, does not conflict with the written judgments.”
State v. McDanold, 2004 MT 167 (Mont. 2004).
State v. Fisher, 2003 MT 33 (Mont. 2003).
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.