Matter of: W.D.

Summary

The Montana Supreme Court held that a Youth Court exceeds its authority under § 41-5-208, MCA, when, at the conclusion of a transfer hearing, it imposes a new disposition — here a DOC commitment until age 25, an extended supervision period, and a Tier II sex-offender registration requirement. Section 41-5-208 authorizes only transfer of jurisdiction and supervisory responsibility; adjudicating a dispositional violation and imposing a new custodial disposition requires the petition, notice, and procedural protections of § 41-5-1431, MCA, and § 41-5-208(4) places post-transfer violation adjudication with the district court. Because the State filed no revocation petition, W.D. was not fairly put on notice, and the error was not harmless. The Court reversed and remanded to strike the added commitment, extended supervision, and registration requirement.