
Montana tacks a letter onto the end of some case citations. Miss it and you'll quote an opinion the court has told you not to quote.
Since January 1, 1998 the Montana Supreme Court has assigned every opinion a public domain citation made of the year, the letters MT, and a number that restarts at 1 each January. So 1998 MT 1 was the first opinion of that year. A trailing N means the opinion is not to be cited as precedent in any brief, motion or document. A trailing W means it was withdrawn or vacated. A trailing A means it was amended by a later order.
One character. Three very different instructions.
Case cites point at paragraphs, not pages
The same 1997 order that created the format also told the court to number every paragraph of every opinion, consecutively, right through the concurrences and dissents.
That makes the paragraph the pin cite. And when an opinion gets amended, the amended paragraph keeps its old number, new paragraphs slot in as 13a and 13b behind paragraph 13, and a deleted paragraph's number is skipped with a note left at the gap.
Statute numbers carry a level you can't see
A Montana statute cite looks like three numbers with hyphens. It's carrying four.
27-2-204 title 27, chapter 2, part 2, section 04
1-1-501 title 1, chapter 1, part 5, section 1
The part is folded into the front of the last group. The State Law Library's own research guide spells the format out as title, chapter, part, section and uses 1-1-501 as the worked example. So 27-2-204 sits in title 27, Civil Liability, Remedies, and Limitations, then chapter 2, Statutes of Limitations, then part 2, Time Limits on Specific Kinds of Actions. It's the three year period for a general tort action.
Once a chapter has more than nine parts the last group grows. 61-8-1002 is title 61, chapter 8, part 10, section 02, the driving under the influence offense. Nothing in the punctuation warns you that the group got longer.
Why care? Because parts are how Montana groups related sections, and if you are pulling neighbors of a section you want the part boundary, not the chapter. Chapter 8 of title 61 is all of traffic regulation. Part 10 of it is one subject.
Montana writes its own cites the other way round
Inside Montana, the section number comes first and the code name follows after a comma. The code writes itself that way. Montana's rule about what happens when the code and a bill disagree is printed as 1-11-103, MCA. Out of state briefs write the same section as Mont. Code Ann. § 1-11-103.
Both are correct and both point at one section. If you are matching cites across a pile of documents, treat them as one string in two outfits.
Rules work the same way in a different alphabet. ARM 24.29.207 is title 24, chapter 29, subchapter 2, rule 07. Subchapter is folded into the last group exactly the way part is folded into a statute number, so 38.3.3602 reads as title 38, chapter 3, subchapter 36, section 2.
Who publishes what, and on what clock
The Montana Legislature meets in regular session every two years, in odd-numbered years. A new edition of the code follows each session, published in the fall of the odd year.
But the code moves between editions. Under 1-11-204, MCA the code commissioner keeps recodifying continuously and must report every change made other than punctuation, spelling and capitalization. And 1-11-103, MCA settles the conflict case. Where an inconsistency in meaning arises between the Montana Code Annotated and the corresponding portion of the official enrolled bill on file with the secretary of state, the enrolled bill wins.
The online code also prints text that isn't in force yet. A section can appear twice on one page, one copy tagged Temporary and another tagged with a future effective date. Read the tag before you quote the subsection.
Rules run through a different office. The Secretary of State publishes the Administrative Rules of Montana, updated quarterly. Notices of proposed, amended and repealed rules are compiled into the Montana Administrative Register, issued every two weeks, and the Register is what tells you a rule's current status. The rule text mostly doesn't.
A third of Montana's dead rules didn't die
Counted on 2026-09-18, Montana holds 28,217 regulation sections. 12,151 carry an in force marker. The other 16,066 don't, which is 57 percent of the set.
Look at how that 16,066 splits. 10,640 repealed. 5,426 transferred.
Transferred comes straight out of how Montana numbers rules. ARM titles are assigned by department, not by subject. Move a program from one department to another and every rule it carries needs a new number under the new department's title.
When professional and occupational licensing left the Department of Commerce for the Department of Labor and Industry, the rules followed board by board over several years rather than all at once. The Board of Outfitters rules were amended and transferred out of ARM title 8 in 2005. The outfitter license application rule that used to be ARM 8.39.501 is ARM 24.171.501 today.
So a transferred cite is not a wrong cite. It is an old address for text that is usually still law. Repealed means stop reading. Transferred means find the forwarding number, then read the text there rather than the text in the brief you were handed, because Montana tends to amend rules in the same notice that moves them.
A lookup you can repeat
You have a 2003 brief citing ARM 8.39.501 and the number doesn't resolve.
- Don't record it as repealed. Check whether the old chapter was transferred somewhere.
- Find the Register notice that did the move. Montana numbers its rulemaking notices after the board and the old title, so a transfer out of title 8 by the Board of Outfitters carries a notice number beginning 8-39.
- Read the rule at the new number. Compare it to the old text, because the transfer notice probably amended it too.
- For the statute behind the rule, work out the part before you hunt for related sections.
What bites
The invisible part number in the middle of a statute cite, and the four digit last group when a chapter runs past nine parts.
Two correct forms for the same statute, one local and one national.
A code edition year that matters. Cite the edition when the section has changed.
Transferred read as repealed. That is the expensive one, and 5,426 sections sit in that category.
The rest of the corpus
Montana comes to 62,816 sections counted on 2026-09-18. Statutes are 30,515 of them, with 30,360 in force, 143 reserved and 12 repealed. The statute book is stable. The rule book is not.
Then 3,527 attorney general opinions, a deep set for a state this size, published in the Register alongside rule notices. After that, 238 court rule sections, 170 constitution sections and 149 agency guidance documents.
When a Montana rule number comes back empty, the useful next question is not whether the rule died. It is which department owns it now.
Facts used
All Montana corpus counts below are from Vaquill AI's US primary law data, measured 2026-09-18.
| Claim | Value | Where from |
|---|---|---|
| Total Montana sections held | 62,816 | Corpus counts, measured 2026-09-18 |
| Regulation sections | 28,217 (12,151 in force, 10,640 repealed, 5,426 transferred) | Corpus status counts, measured 2026-09-18 |
| Share of regulation sections not in force | 57 percent | 16,066 of 28,217, corpus status counts |
| Statute sections | 30,515 (30,360 in force, 143 reserved, 12 repealed) | Corpus status counts, measured 2026-09-18 |
| Attorney general opinions held | 3,527 | Corpus counts, measured 2026-09-18 |
| Court rule sections | 238 | Corpus counts, measured 2026-09-18 |
| Constitution sections | 170 | Corpus counts, measured 2026-09-18 |
| Agency guidance documents held | 149 | Corpus counts, measured 2026-09-18 |
| Public domain case citation from January 1, 1998, year plus MT plus a number restarting each year | Verified | Montana Supreme Court citation order, December 1997 |
| N suffix means not citable as precedent, W means withdrawn or vacated, A means amended | Verified | Montana Supreme Court citation order |
| Every paragraph numbered consecutively through concurrences and dissents | Verified | Montana Supreme Court citation order |
| Amended paragraphs keep their number, added paragraphs take 13a and 13b, deleted numbers are skipped with a note | Verified | Montana Supreme Court citation order |
| MCA format is title, chapter, part, section, as in 1-1-501 | Verified | State Law Library research guide |
| 27-2-204 is title 27, chapter 2, part 2, and sets a three year tort limitation period | Verified | Published section text |
| 61-8-1002 is title 61, chapter 8, part 10, the driving under the influence offense | Verified | Published section text |
| Montana writes statute cites as 1-11-103, MCA rather than Mont. Code Ann. § 1-11-103 | Verified | Code commissioner report and published section text |
| ARM format is title, chapter, subchapter, section, as in 38.3.3602 | Verified | State Law Library research guide |
| ARM 24.29.207 is title 24, chapter 29, subchapter 2 | Verified | Published rule listing |
| Regular legislative sessions every two years in odd-numbered years | Verified | State Law Library research guide |
| MCA republished in the fall of every odd-numbered year | Verified | State Law Library quick guide |
| Code commissioner recodifies continuously and reports every change beyond punctuation, spelling and capitalization | 1-11-204, MCA | Code commissioner report |
| The official enrolled bill prevails over the code where their meaning differs | 1-11-103, MCA | Code commissioner report |
| Sections can appear twice on one page, tagged Temporary or with a future effective date | Verified | Published section page, 2025 edition |
| ARM published by the Secretary of State and updated quarterly | Verified | State Law Library research guide and the Secretary of State's ARM pages |
| Montana Administrative Register issued every two weeks and used to determine current rule status | Verified | State Law Library research guide |
| Board of Outfitters rules amended and transferred out of ARM title 8 in 2005 | Verified | Montana Administrative Register, 2005 issue 16, notice 8-39-24 |
| ARM 8.39.501 is now ARM 24.171.501 | Verified | Register transfer notice and the current rule listing |
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Co-Founder & CTO
Priyansh leads engineering and AI at Vaquill, from the matter workbench to drafting, document comparison, document matrix, and citation-verified research.