State v. J. Knowles

2025 MT 107, 569 P.3d 184
CourtMontana Supreme Court
DecidedMay 20, 2025
DocketDA 22-0363
StatusPublished
Cited by1 cases

This text of 2025 MT 107 (State v. J. Knowles) is published on Counsel Stack Legal Research, covering Montana Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. J. Knowles, 2025 MT 107, 569 P.3d 184 (Mo. 2025).

Opinion

05/20/2025

DA 22-0363 Case Number: DA 22-0363

IN THE SUPREME COURT OF THE STATE OF MONTANA

2025 MT 107

STATE OF MONTANA,

Plaintiff and Appellee,

v.

JOSEPH EDWARD KNOWLES,

Defendant and Appellant.

APPEAL FROM: District Court of the Eighth Judicial District, In and For the County of Cascade, Cause No. ADC-16-534 Honorable John W. Larson, Presiding Judge

COUNSEL OF RECORD:

For Appellant:

Tammy A. Hinderman, Appellate Defender Division Administrator, Kristina L. Neal, Assistant Appellate Defender, Helena, Montana

For Appellee:

Austin Knudsen, Montana Attorney General, Brad Fjeldheim, Assistant Attorney General, Helena, Montana

Joshua A. Racki, Cascade County Attorney, Great Falls, Montana

Submitted on Briefs: January 30, 2025

Decided: May 20, 2025

Filed: ir,-6‘A•-if __________________________________________ Clerk Justice Ingrid Gustafson delivered the Opinion of the Court.

¶1 Defendant and Appellant Joseph Edward Knowles appeals from the May 19, 2022

Order Denying Motion for Sentence Reduction issued by the Eighth Judicial District Court,

Cascade County.

¶2 We address the following restated issue on appeal:

Whether the District Court abused its discretion by reimposing Knowles’s original adult sentence following a Criminally Convicted Youth Act sentence review hearing which occurred after the Act was not followed for over four years after Knowles’s original sentence.

¶3 We reverse and remand for application of the Criminally Convicted Youth Act

provisions prior to a CCYA sentence review hearing should Knowles request one within

two years of the date of this Opinion.

FACTUAL AND PROCEDURAL BACKGROUND

¶4 On the night of September 23, 2016, Knowles, then 16 years old, and his 18-year-

old girlfriend, Brianna Coombs, made a plan to steal marijuana from Megan Meriwether,

also 18, in Great Falls. Knowles and Coombs, along with Westin and Corey Piner, met up

with Meriwether in an alley under the pretense of buying drugs from her. Coombs grabbed

the bag of marijuana and ran away. Meriwether chased Coombs back to the car where

Knowles had remained with the Piners. Coombs and Meriwether got into a fight over the

drugs, during which Meriwether pulled a knife on Coombs. Knowles got out of the car

while the two were fighting and joined the fight to assist Coombs. Coombs was able to

take the knife from Meriwether while Knowles interceded. Ultimately, Knowles ended up

with the knife and stabbed Meriwether in the neck. Knowles and Coombs got back into

2 the car with the knife and a bag of marijuana and drove away. Meriwether died from the

knife wound.

¶5 On October 3, 2016, the State exercised its discretion under § 41-5-206(1), MCA,

to charge Knowles as an adult with deliberate homicide, tampering with or fabricating

physical evidence, and accountability to robbery. After Knowles moved to substitute the

presiding district court judge and all Cascade County district court judges declined to take

the case, Missoula County district court judge John Larson accepted jurisdiction.

Following a § 41-5-206(3), MCA, transfer hearing, the District Court denied a transfer of

the case to Youth Court. The State filed an amended information on March 31, 2017,

charging Knowles with deliberate homicide pursuant to the felony murder rule under

§ 45-5-102(1)(b), MCA, and tampering with or fabricating physical evidence under

§ 45-7-207, MCA.

¶6 On October 3, 2017, pursuant to a plea agreement providing for the dismissal of the

tampering with evidence charge, Knowles pled guilty to the deliberate homicide of

Meriwether as charged in the amended information. The plea agreement called for the

State to recommend a 60-year sentence at the Montana State Prison (MSP) with no

restriction on parole eligibility, while Knowles was free to argue for any legal sentence.

At the December 19, 2017 sentencing hearing, Knowles argued for a 60-year MSP

commitment, with 30 years suspended. During the sentencing hearing, Knowles also

presented the testimony of Dr. Theresa Reed, an expert in juvenile development who

conducted an examination of Knowles. Dr. Reed testified that Knowles belonged to the

3 adolescent class of offenders, which are “less mature, less culpable, and [have] a greater

potential for rehabilitation than an adult offender class.” Dr. Reed concluded Knowles

should not receive the same sentence as an adult offender would, but should nevertheless

receive severe consequences for the deliberate homicide. The District Court orally

imposed a 60-year sentence to MSP. The court also told Knowles he would “have a chance

to take advantage of lots of situations in the prison, lots of educational opportunities, lots

of vocational opportunities, lots of counseling opportunities” before becoming parole-

eligible. The District Court issued its written judgment, reflecting the 60-year MSP

commitment, on December 28, 2017. The court’s judgment did not reflect that Knowles

was a criminally convicted youth under the Criminally Convicted Youth Act (CCYA),

§ 41-5-2501, MCA, et seq., or contain any of the relevant provisions applicable to Knowles

as a criminally convicted youth under the Act.

¶7 Knowles appealed his original judgment to this Court. The appeal was ultimately

dismissed after the parties reached a stipulation regarding an amended judgment which

would add statutory provisions related to Knowles being a criminally convicted youth

under the CCYA. Over six years ago, on April 2, 2019, this Court issued an Order in

accordance with the parties’ stipulation which dismissed the appeal and ordered the “matter

be remanded to the District Court with instructions to amend the written judgment to reflect

the District Court’s continuing jurisdiction over Mr. Knowles until age 21; that the

Department of Corrections submit status reports every 6 months to the District Court until

Mr. Knowles reaches the age of 21; that the District Court review Mr. Knowles’s sentence

4 prior to turning age 21 pursuant to the CCYA; and that Mr. Knowles [will] have the right

to counsel at his CCYA sentence review hearing.” State v. Knowles, No. DA 18-0105,

Order (Mont. Apr. 2, 2019). This Court’s Order directed the Clerk of the Supreme Court

“to provide copies of this Order to all counsel of record and to the Clerk of Court for

Cascade County. Additionally, the Clerk of the District Court is to send a certified copy

of the amended judgment to the Records Department of the Department of Corrections

(DOC).”

¶8 Despite the Cascade County Clerk of Court filing a copy of this Court’s Order in

Knowles’s file on April 3, 2019, nothing happened in the case for over two years.1

Knowles filed an unopposed Motion for the Court to Follow Supreme Court Instructions

and Set Status Hearing on December 21, 2021. The District Court issued an Order for

Department of Corrections Status Report on Defendant and Order Setting Status Hearing

on December 28, 2021, and an Order Amending Judgment on December 29, 2021. In both

orders, the court noted it had not been provided notice of this Court’s April 2, 2019 order

and was unaware of it until receiving an emailed copy attached to Knowles’s December

21, 2021 motion.2 The District Court’s Amended Judgment included the relevant language

from our April 2, 2019 Order—that the District Court had continuing jurisdiction over

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Cite This Page — Counsel Stack

Bluebook (online)
2025 MT 107, 569 P.3d 184, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-j-knowles-mont-2025.