The 23rd century equivalent of keeping a spare set of keys inside the jail cell.
He’s more in a room with a locked door than specifically a jail cell.
Forcefield brigs were available on NX series ships. This would appear to be more of a “confinement to quarters, under guard” situation. Use of the brig might need to be accounted for to some third party, restricted to holding criminal suspects or enemy combatants. Kidnapping Truong seemed to be merely the captain exercising her (misconstrued) “scope of command and control”.
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