State v. Madsen

Summary

The Montana Supreme Court reversed the dismissal of a felony charge for mistreating prisoners under § 45-5-204, MCA. The Court held that the term “prisoner” includes a person detained by law enforcement, including a juvenile confined and shackled in a law enforcement facility, and remanded for further proceedings.

Holdings

1. The term "prisoner" is not limited to a person serving a sentence in a state prison or other state facility after conviction; it includes a person detained, confined, or held in custody by law enforcement.
2. The charging information adequately stated an offense because K.J., a juvenile detained by law enforcement and restrained in an interview room, qualified as a prisoner under § 45-5-204(1), MCA.

Questions Presented

1. Whether the district court correctly construed the term "prisoner" in § 45-5-204, MCA, to include only a person serving a sentence in a state prison or other state facility following a conviction.
2. Whether the charging information adequately stated an offense under § 45-5-204, MCA, where the alleged victim was a detained juvenile who had not been convicted and was not held in a state facility.

Disposition

reversed_and_remanded