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This undated photo provided by the Montana Department of Corrections shows Michael Keith Spell. A defense attorney says Spell, a mentally-disabled Colorado man serving a 100-year prison term in a Montana teacher's murder, should be transferred to the custody of state mental health officials. Attorney Wendy Holton said in an appeal brief filed Tuesday, Nov. 29, 2016 that Spell needs treatment that he won't receive in prison. Spell's 2012 killing of Sherry Arnold in the once-quiet town of Sidney highlighted a significant spike in crime following an oil boom that's swept the Northern Plains. (Montana Department of Corrections via AP)

This undated photo provided by the Montana Department of Corrections shows Michael Keith Spell. A defense attorney says Spell, a mentally-disabled Colorado man serving a 100-year prison term in a Montana teacher's murder, should be transferred to the custody of state mental health officials. Attorney Wendy Holton said in an appeal brief filed Tuesday, Nov. 29, 2016 that Spell needs treatment that he won't receive in prison. Spell's 2012 killing of Sherry Arnold in the once-quiet town of Sidney highlighted a significant spike in crime following an oil boom that's swept the Northern Plains. (Montana Department of Corrections via AP)

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