## Facts

- Montana enacted the Extended Jurisdiction Prosecution Act (EJPA), a “blended sentencing” scheme authorizing youth courts to impose both a juvenile disposition and a stayed adult criminal sentence for certain juveniles.
- If a youth later violated disposition conditions or committed a new offense, the youth court could revoke the stay and order execution of the adult sentence.
- Five separate youth-court cases (including S.L.M., S.T., J.L.C., J.A.T., and L.D.) were consolidated on appeal because they raised the same constitutional challenges to the EJPA.
- In the S.L.M. matter, the State sought extended jurisdiction for felony-level charges; the youth court granted extended jurisdiction for a qualifying drug charge, imposed a juvenile commitment until age 19, and entered a stayed 10-year adult sentence.
- Each appellant argued the EJPA violated constitutional protections, and the youth courts rejected those challenges and sentenced under the EJPA framework.

## Issues

1. Whether the EJPA violates the Montana Constitution’s equal protection guarantee (Mont. Const. art. II, § 4) by creating unjustified disparate treatment among similarly situated juveniles.
2. Whether the EJPA violates the Montana Constitution’s protections for the rights of minors (Mont. Const. art. II, § 15) by subjecting juveniles to threatened and potentially executed adult punishment within youth-court proceedings.
3. Whether the Court must reach additional challenges under due process and double jeopardy provisions after deciding the case on state constitutional grounds.

## Decision

- The Montana Supreme Court held the EJPA unconstitutional.
- The Court ruled the EJPA violates Mont. Const. art. II, § 4 (equal protection) and art. II, § 15 (rights of minors).
- Because those state constitutional violations resolved the appeals, the Court declined to address due process and double jeopardy claims.
- The judgments and dispositions dependent on the EJPA’s extended-jurisdiction sentencing structure were reversed or remanded for proceedings consistent with the constitutional holding.

## Legal Principles

- A statutory scheme that creates a special class of juveniles exposed to both a juvenile disposition and a stayed adult sentence must satisfy Montana constitutional equal protection requirements; a classification lacking adequate justification is invalid.
- Montana’s constitutional protection of minors limits the State’s ability to impose or threaten adult criminal sanctions through youth-court mechanisms that dilute the distinct treatment and protections owed to juveniles.
- When a case can be resolved on independent state constitutional grounds, the court may decline to decide additional federal or other constitutional questions.

## Conclusion

The court invalidated Montana’s EJPA because its blended juvenile–adult sentencing framework imposed materially harsher potential consequences on a subset of juveniles without constitutionally sufficient justification under state equal protection principles and conflicted with the Montana Constitution’s protections for minors; the court therefore set aside EJPA-based dispositions without reaching due process or double jeopardy challenges.


In re S.L.M., 951 P.2d 1365 (Mont. 1997)