Background

• Madsen, a Gallatin County Sheriff’s Deputy, was involved in an incident with K.J., a juvenile detainee, at the Gallatin County Law & Justice Center in 2011.
• K.J. was detained in a small interview room, handcuffed to a waist belt and leg shackles during the encounter.
• Madsen ordered K.J. to sit with lights on and warned of harm if she did not comply; he then abruptly entered the room and grabbed her by the neck, pushing her against a wall while another officer intervened.
• In 2012 the State charged Madsen with mistreating prisoners under §45-5-204, MCA, which the defense moved to dismiss on the ground that K.J. was not a “prisoner.”
• The District Court dismissed the charge, holding that a “prisoner” means someone serving a sentence, and thus K.J. was not covered; the State appealed the dismissal.
• The Montana Supreme Court reviews de novo the district court’s interpretation of the statute and the sufficiency of the charging information under §45-5-204(1).

Issues

Key Cases Cited

• United States v. Bass, 404 U.S. 336 (U.S. 1971) (ambiguity resolved in favor of lenity in criminal statutes)
• State v. Heath, 2004 MT 126 (Mont. 2004) (holistic statutory construction; legislative intent governs when plain meaning uncertain)
• State v. Hicks, 2013 MT 50 (Mont. 2013) (statutory interpretation to pursue legislative intent if possible)
• Langemo v. Mont. Rail Link, 2001 MT 273 (Mont. 2001) (de novo review of statutory interpretation; ascertain legislative intent)
• State v. Ankeny, 2010 MT 224 (Mont. 2010) (apply plain meaning; situational context in interpreting terms)
• State v. Trull, 2006 MT 119 (Mont. 2006) (common usage of terms; notice and clarity of criminal statutes)
• Gulbrandson v. Cary, 272 Mont. 494 (Mont. 1995) (interpretation of statutory terms; common understanding)