Wilson v. State, 249 P.3d 28

Background

Wilson pleaded guilty to felony assault with a weapon and received a six-year deferred sentence at age 18.
The court conditioned the deferred sentence on completing boot camp at Treasure State Correctional Training Center and warning of possible MSP imprisonment for noncompliance.
Wilson has a long history of psychiatric diagnoses (bipolar disorder, ADHD, depression, substance dependencies) and has relied on medications prescribed by doctors (e.g., Vyvanse, Abilify, Lamictal).
MSP policies barred Vyvanse due to security and abuse concerns, requiring alternative medications that differed from Wilson’s prior prescriptions.
Wilson’s medications were disrupted at boot camp and during pre-booter programs, leading to program terminations and a revocation hearing.
Wilson petitioned for postconviction relief alleging cruel and unusual punishment and dignity violations due to medicational denial; the district court denied relief and this appeal followed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does MSP medication denial violate the Eighth Amendment or dignity guarantees?	Wilson argues lack of Vyvanse and other meds worsened his condition and caused confinement harms.	The State contends MSP provided alternatives, medical monitoring, and did not consciously disregard substantial risk.	No constitutional violation; no deliberate indifference proven; therapies differ but adequately treat Wilson.
Was Wilson's postconviction relief petition procedurally appropriate to challenge confinement conditions?	Wilson sought relief based on confinement conditions and medical care from MSP.	The petition's substance mirrors prior revocation hearings; court may address it within postconviction framework or believe it procedurally improper.	Petition properly within scope; district court’s findings stand.
Did Walker v. State guide the district court’s analysis on deliberate indifference to medical care for a mental-health inmate?	Walker requires appointment of counsel and remedy for confinement conditions to prevent dignity infringements.	Wilson had counsel; no additional remedy necessary beyond normal postconviction review; no entitlement to Walker-style relief.	Walker framework not required to be replicated; no error in proceeding.
Did the district court misapprehend substantial evidence supporting the decision to commit Wilson to MSP?	Disagreement with Dr. Stratosfied medication track and benefits of prior regimen.	MSP’s treatment plan and physician assessments show no substantial risk that treatment deprived Wilson of basic needs.	Substantial evidence supports MSP placement and ruling; no misapprehension found.

Key Cases Cited

Walker v. State, 316 Mont. 103, 68 P.3d 872 (2003 MT) (standard for deliberate indifference and dignity in Montana)
Quigg v. Slaughter, 336 Mont. 474, 154 P.3d 1217 (2007 MT) (two-part Eighth Amendment test for medical deprivation)
Kafka v. Mont. Dept. of Fish, Wildlife & Parks, 348 Mont. 80, 201 P.3d 8 (2008 MT) (uses federal analogy for constitutional interpretation)
Baze v. Rees, 553 U.S. 35 (2008) (two-part Eighth Amendment framework for cruel punishment)
Thibodeau v. Bechtold, 347 Mont. 277, 198 P.3d 785 (2008 MT) (method for reviewing factual findings in postconviction relief)
Worthan v. State, 356 Mont. 206, 232 P.3d 380 (2010 MT) (standards for review of postconviction relief findings)