Montana Code Annotated

Mont. Code Ann. § 45-5-301 (2026)

Unlawful Restraint

✓ current as of May 2026
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TITLE 45. CRIMES

CHAPTER 5. OFFENSES AGAINST THE PERSON

Part 3. Kidnapping

Unlawful Restraint

45-5-301. Unlawful restraint. (1) A person commits the offense of unlawful restraint if the person knowingly or purposely and without lawful authority restrains another so as to interfere substantially with the other person's liberty.

(2) A person convicted of the offense of unlawful restraint shall be fined not to exceed $500 or be imprisoned in the county jail for any term not to exceed 6 months, or both.

History: En. 94-5-301 by Sec. 1, Ch. 513, L. 1973; R.C.M. 1947, 94-5-301; amd. Sec. 1657, Ch. 56, L. 2009.

Notes of Decisions
Cited in 21 cases (6 in the last 5 years), 1984–2025 · leading case: State v. Vern Kills on Top, 793 P.2d 1273 (Mont. 1990).
State v. Vern Kills on Top, 793 P.2d 1273 (Mont. 1990). · cites it 6× “Kidnapping is committed when unlawful restraint is effected "by either secreting or holding [the victim] in a place of isolation or by using or threatening to use physical force." Section 45-5-302(1), MCA. Defendant was charged with aggravated kidnapping, committed with a…”
State v. Lester Kills on Top, 787 P.2d 336 (Mont. 1990). · cites it 6× “" Section 45-5-301(1), MCA. Kidnapping is committed when unlawful restraint is effected "by either secreting or holding [the victim] in a place of isolation or by using or threatening to use physical force.”
State v. Lambert, 929 P.2d 846 (Mont. 1996). · cites it 4× “For example, the crime of unlawful restraint, § 45-5-301, MCA, defines the offense as follows: (1) A person commits the offense of unlawful restraint if he knowingly or purposely and without lawful authority restrains another so as to interfere substantially with his liberty.”
State v. Hauer, 2012 MT 120 (Mont. 2012). · cites it 4× “Was Hauer prejudiced by ineffective assistance of counsel when counsel agreed not to introduce evidence of the victim’s intentional cutting? Factual and Procedural Background ¶5 Hauer was charged by Information with two misdemeanor counts of Partner or Family Member Assault…”
United States v. Gonzalez-Ramirez, 477 F.3d 310 (5th Cir. 2007). “Code Ann. § 2905.03 (West 1997); Tex. Penal Code Ann.”
State v. Scheffer, 2010 MT 73 (Mont. 2010). · cites it 2× “The State subsequently charged him on September 11, 2007, with sexual intercourse without consent, a felony, in violation of § 45-5-503, MCA (Count I); tampering with or fabricating physical evidence, a felony, in violation of § 45-7-207, MCA (Count II); and unlawful restraint,…”
State v. Meyer, 2005 MT 215 (Mont. 2005). · cites it 2× “’’The offense of unlawful restraint, a misdemeanor, is defined by §45-5-301, MCA: “A person commits the offense of unlawful restraint if he knowingly or purposely *251 and without lawful authority restrains another so as to interfere substantially with his liberty.”
State v. Norquay, 2010 MT 85 (Mont. 2010). · cites it 4× “¶ 1 Curry James Norquay (Norquay) appeals from the judgment of conviction and sentencing order of the Eighth Judicial District Court, Cascade County, for aggravated burglary, a felony, in violation of § 45-6-204(2)(b), MCA, and unlawful restraint, a *769 misdemeanor, in…”
State v. Ortega, 679 P.2d 793 (Mont. 1984). · cites it 3× “” Section 45-5-301(l)(a), MCA. The defendant admits that there is a possibility the jury may have convicted the defendant on the theory that he inflicted bodily injury on Bob Lutzenhiser in the course of stealing his wallet.”
State v. Torres, 2013 MT 101 (Mont. 2013). · cites it 3× “” Section 45-5-301, MCA. ¶34 Torres argues that there was no evidence that he committed either assault or unlawful restraint, or that he intended to do so after breaking down the door to Marina’s home.”
State v. Gustafson, 2000 MT 364 (Mont. 2000). · cites it 2× “¶11 The Cascade County Attorney charged Gustafson with felony assault pursuant to § 45-5-202(2)(b), MCA (1997), partner/family member assault pursuant to § 45-5-206(l)(a), MCA (1997), and unlawful restraint pursuant to § 45-5-301, MCA (1997). Gustafson pled not guilty to the…”
State v. Donald P. Rogers, 2013 MT 221 (Mont. 2013). · cites it 2× “¶11 On May 3, 2011, the Missoula County Attorney filed an information with the District Court charging Rogers with sexual intercourse without consent, a felony, in violation of §45-5-503, MCA; two counts of partner or family member assault, third or subsequent offense, a felony,…”
— Mont. Code Ann. § 45-5-301(1) — 3 cases
State v. Vern Kills on Top, 793 P.2d 1273 (Mont. 1990). “Kidnapping is committed when unlawful restraint is effected "by either secreting or holding [the victim] in a place of isolation or by using or threatening to use physical force." Section 45-5-302(1), MCA. Defendant was charged with aggravated kidnapping, committed with a…”
State v. Lester Kills on Top, 787 P.2d 336 (Mont. 1990). “" Section 45-5-301(1), MCA. Kidnapping is committed when unlawful restraint is effected "by either secreting or holding [the victim] in a place of isolation or by using or threatening to use physical force.”
State v. C. Spangler, 2025 MT 244N (Mont. 2025).
— Mont. Code Ann. § 45-5-301(1)(a) — 1 case
State v. Dickson, 377 Mont. 33 (Mont. 2014).
— Mont. Code Ann. § 45-5-301(2) — 1 case
— Mont. Code Ann. § 45-5-301(l)(a) — 1 case
State v. Ortega, 679 P.2d 793 (Mont. 1984). “” Section 45-5-301(l)(a), MCA. The defendant admits that there is a possibility the jury may have convicted the defendant on the theory that he inflicted bodily injury on Bob Lutzenhiser in the course of stealing his wallet.”
— Mont. Code Ann. § 45-5-301(lXa) — 1 case
State v. Dickson, 377 Mont. 33 (Mont. 2014).
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