Montana Code Annotated

Mont. Code Ann. § 46-8-101 (2026)

Right To Counsel

✓ current as of May 2026
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TITLE 46. CRIMINAL PROCEDURE

CHAPTER 8. RIGHT TO COUNSEL

Part 1. Extent of Right -- Indigency Repayment of Costs

Right To Counsel

46-8-101. Right to counsel. (1) During the initial appearance before the court, every defendant must be informed of the right to have counsel and must be asked if the aid of counsel is desired.

(2) Except as provided in subsection (3), if the defendant desires assigned counsel because of financial inability to retain private counsel and the offense charged is a felony or the offense is a misdemeanor and incarceration is a sentencing option if the defendant is convicted, the court shall order the office of state public defender, provided for in 2-15-1029, to assign counsel to represent the defendant without unnecessary delay pending a determination of eligibility under the provisions of 47-1-111.

(3) If the defendant desires assigned counsel because of financial inability to retain private counsel and the offense charged is a misdemeanor and incarceration is a sentencing option if the defendant is convicted, during the initial appearance the court may order that incarceration not be exercised as a sentencing option if the defendant is convicted. If the court so orders, the court shall inform the defendant that the assistance of counsel at public expense through the office of state public defender is not available and that time will be given to consult with an attorney before a plea is entered. If incarceration is waived as a sentencing option, a public defender may not be assigned.

History: En. 95-1001 by Sec. 1, Ch. 196, L. 1967; R.C.M. 1947, 95-1001; amd. Sec. 1, Ch. 415, L. 1981; amd. Sec. 63, Ch. 800, L. 1991; amd. Sec. 40, Ch. 449, L. 2005; amd. Sec. 2, Ch. 344, L. 2011; amd. Sec. 14, Ch. 358, L. 2017.

Notes of Decisions
Cited in 20 cases (5 in the last 5 years), 1981–2025 · leading case: State v. Gatlin, 2009 MT 348 (Mont. 2009).
State v. Gatlin, 2009 MT 348 (Mont. 2009). · cites it 12× “¶ 20 Section 46-8-101(1), MCA, requires that, at an initial appearance, every defendant must be informed of the right to have counsel and must be asked if the aid of counsel is desired.”
State v. Shirlene Walker, 2008 MT 244 (Mont. 2008). · cites it 7× “Section 46-8-101, MCA (1997) (emphasis added).”
Rothgery v. Gillespie Cnty., 554 U.S. 191 (2008). “048 (2000); (23) Montana: see Mont. Code Ann. §46-8-101 (2007); (24) Nebraska: see Neb.”
State v. Skurdal, 767 P.2d 304 (Mont. 1988). · cites it 3× “Section 46-8-101(3), MCA (1985), provides that appointment of counsel for misdemeanor charges such as these is discretionary with the trial judge.”
State v. Lange, 733 P.2d 846 (Mont. 1987). · cites it 3× “Section 46-8-101, MCA, specifies that counsel will be appointed for indigent parties in felony cases and may be appointed in misdemeanor cases.”
City of Billings v. Layzell, 789 P.2d 221 (Mont. 1990). · cites it 3× “While we soundly condemn the court’s actions, we will not *153 find a constitutional violation when the appellant intentionally created and prolonged the incident.”
State v. Dillard, 2006 MT 328 (Mont. 2006). · cites it 2× “Specifically, Dillard cites § 46-8-101, MCA. This statute, effective July 1, 2006, provides: Right to counsel.”
State v. Adams, 2002 MT 202 (Mont. 2002). · cites it 3× “Section 46-8-101(3)(c), MCA, provides that a “defendant, if unable to employ counsel, is entitled to have counsel assigned if the interests of justice would be served by assignment.”
EDWARD C. v. Collings, 632 P.2d 325 (Mont. 1981). · cites it 3× “Regarding the right to counsel in justice or municipal court, section 46-8-101, MCA, provides: *429 “(1) Every defendant brought before the court must be informed by the court that it is his right to have counsel before proceeding and must be asked if he desires the aid of…”
Off. of State Pub. Def. v. Fagenstrom, 439 P.3d 1285 (Mont. 2019). · cites it 18× “The Justice Court further asserts that "any legislation," such as § 46-8-101, MCA, "enacted for the purpose of taking away a [d]efendant's right to [counsel] and thus save money is unconstitutional.”
Christopher Kenton Dyer v. Mahoney, 2008 MT 117 (Mont. 2008). · cites it 4× “¶3 Pursuant to § 46-8-101(2), MCA, a defendant who is charged with a felony or a misdemeanor offense for which incarceration upon conviction is a sentencing option, and who desires assigned counsel because of financial inability to retain private counsel, is entitled to the…”
State v. Stringer, 868 P.2d 588 (Mont. 1994). · cites it 5× “Section 46-8-101, MCA, which governs the right to counsel in criminal trials, provides in pertinent part: (2) If the defendant desires counsel, is unable to employ counsel, and is entitled to have counsel assigned, the court shall assign counsel to the defendant without…”
— Mont. Code Ann. § 46-8-101(1) — 4 cases
State v. Gatlin, 2009 MT 348 (Mont. 2009). “¶ 20 Section 46-8-101(1), MCA, requires that, at an initial appearance, every defendant must be informed of the right to have counsel and must be asked if the aid of counsel is desired.”
Ramirez v. Lt. Valdez (Mont. 2022).
McKeen v. Valdez (Mont. 2022).
Ramirez v. Lt. Valdez (Mont. 2022).
— Mont. Code Ann. § 46-8-101(2) — 5 cases
State v. Gatlin, 2009 MT 348 (Mont. 2009). “¶ 20 Section 46-8-101(1), MCA, requires that, at an initial appearance, every defendant must be informed of the right to have counsel and must be asked if the aid of counsel is desired.”
Christopher Kenton Dyer v. Mahoney, 2008 MT 117 (Mont. 2008). “¶3 Pursuant to § 46-8-101(2), MCA, a defendant who is charged with a felony or a misdemeanor offense for which incarceration upon conviction is a sentencing option, and who desires assigned counsel because of financial inability to retain private counsel, is entitled to the…”
Off. of State Pub. Def. v. Fagenstrom, 439 P.3d 1285 (Mont. 2019). “The Justice Court further asserts that "any legislation," such as § 46-8-101, MCA, "enacted for the purpose of taking away a [d]efendant's right to [counsel] and thus save money is unconstitutional.”
Ramirez v. Lt. Valdez (Mont. 2022).
State v. C. Post, 2025 MT 215 (Mont. 2025).
— Mont. Code Ann. § 46-8-101(3) — 4 cases
State v. Skurdal, 767 P.2d 304 (Mont. 1988). “Section 46-8-101(3), MCA (1985), provides that appointment of counsel for misdemeanor charges such as these is discretionary with the trial judge.”
City of Billings v. Layzell, 789 P.2d 221 (Mont. 1990). “While we soundly condemn the court’s actions, we will not *153 find a constitutional violation when the appellant intentionally created and prolonged the incident.”
Off. of State Pub. Def. v. Fagenstrom, 439 P.3d 1285 (Mont. 2019). “The Justice Court further asserts that "any legislation," such as § 46-8-101, MCA, "enacted for the purpose of taking away a [d]efendant's right to [counsel] and thus save money is unconstitutional.”
State v. Cole (Mont. 1996).
— Mont. Code Ann. § 46-8-101(3)(b) — 1 case
State v. Morigeau, 2000 MT 177N (Mont. 2000).
— Mont. Code Ann. § 46-8-101(3)(c) — 1 case
State v. Adams, 2002 MT 202 (Mont. 2002). “Section 46-8-101(3)(c), MCA, provides that a “defendant, if unable to employ counsel, is entitled to have counsel assigned if the interests of justice would be served by assignment.”
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