Five delegates to the 1972 Montana Constitutional Convention sued to block Lawrence VanDyke’s (“VanDyke”) name from appearing on the ballot as a candidate for the Montana Supreme Court, arguing he did not meet the minimum eligibility requirements. The Court, in a 4–3 vote, found VanDyke eligible because Article VII, Section 9(1) of the Montana Constitution only requires one be “admitted” to the Montana Bar and not “admitted” and on “Active Status” per the Montana Bar ByLaws.
Tyler Stockton, Case Note, Cross v. VanDyke: Admitted Only Means Admitted, 75 Mont. L. Rev. Online 88, https://scholarship.law.umt.edu/mlr_online/vol75/iss1/17.