Montana: Will we see a recall effort against Montana Judge in controversial rape sentencing ruling?

There's been a lot of coverage recently of the Montana State Judge G. Todd Baugh, who sentenced a teacher to a month a jail (and 15 years suspended sentence) for raping a 14 year old student (the student later committed suicide).

The coverage hasn't mentioned a recall, and it seems like a decent question as to why that hasn't come up. Montana does have a recall law (the mayor of Troy, Montana was kicked out last year). However, the state's recall law is one that uses a "malfeasance standard" -- meaning the official has to be accused of certain crime, malfeasance or incompetence for the recall to go forward. This is a high hurdle -- it is unclear if there is any claim that Baugh actually violated any rules. Interestingly enough, in 2006, there was an attempt to pass Constitutional Initiative 98 in Montana, which would have specifically allowed recalls against judges for any reason (though not against other officials). I wrote an article on the subject for Montana Lawyer, but that specific issue seems offline. I believe the attempt was thrown out by a judge and never got to the ballot.

That being said, Baugh would seem to be one of the rare candidates for a judicial recall. It is extremely rare for a judge to face a real recall vote. The most famous alleged to judicial recall, against California Supreme Court Chief Justice Rose Bird and Justices Cruz Reynoso and Joseph Grodin, were not recalls. They were actually mandatory retention elections.

However, in 1977 and 1982, two recalls against Wisconsin Judges over ultra-lenient treatment/abuse comments about victims of sex offenders got to the ballot. One of these judges was removed and  the other survived the vote. Baugh's sentencing failure make him an obvious candidate for a similar treatment, that is if petitioners could get the recall past the judicial review stage.