State v. J. McKnight

2025 MT 288
CourtMontana Supreme Court
DecidedDecember 16, 2025
DocketDA 24-0360
StatusPublished

This text of 2025 MT 288 (State v. J. McKnight) 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. McKnight, 2025 MT 288 (Mo. 2025).

Opinion

12/16/2025

DA 24-0360 Case Number: DA 24-0360

IN THE SUPREME COURT OF THE STATE OF MONTANA

2025 MT 288

STATE OF MONTANA,

Plaintiff and Appellee,

v.

JOSHUA MCKNIGHT,

Defendant and Appellant.

APPEAL FROM: District Court of the Twentieth Judicial District, In and For the County of Sanders, Cause No. DC-21-21 Honorable Molly Owen, Presiding Judge

COUNSEL OF RECORD:

For Appellant:

Tammy A. Hinderman, Appellate Defender Division Administrator, Jeavon Lang, Managing Appellate Attorney, Helena, Montana

For Appellee:

Austin Knudsen, Montana Attorney General, Thad Tudor, Assistant Attorney General, Helena, Montana

Jania Hatfield, Sanders County Attorney, Naomi Leisz, Deputy County Attorney, Thompson Falls, Montana

Submitted on Briefs: October 15, 2025

Decided: December 16, 2025 Filed:

__________________________________________ Clerk Justice Laurie McKinnon delivered the Opinion of the Court.

¶1 On September 12, 2022, Joshua Alan McKnight (McKnight) was convicted of

Criminal Possession of Dangerous Drugs, a felony, in violation of § 45-9-102, MCA,

following a jury trial in the Twentieth Judicial District Court, Sanders County. McKnight

appeared for trial but did not return from the lunch break. McKnight now appeals to this

Court, claiming that the District Court erroneously resumed trial and permitted the jury to

return the verdict in his absence. McKnight also claims his trial counsel was ineffective

by failing to move to suppress evidence. We affirm.

¶2 We restate the issues on appeal as follows:

Issue One: Whether the District Court erred by continuing with trial in McKnight’s absence.

Issue Two: Whether McKnight’s ineffective assistance of counsel claim is properly before us on direct appeal.

FACTUAL AND PROCEDURAL BACKGROUND

¶3 On May 8, 2021, at approximately 6:00 p.m., Montana Highway Patrol Trooper

Jourdon Gulick (Trooper Gulick) was advised of a single vehicle crash on Highway 200 in

Trout Creek, Montana. It was reported that a male was trapped in the vehicle, a baby was

seriously injured, and another male had left the scene. The reporting party stated that the

driver appeared to be the male who left the scene. McKnight was identified as a passenger.

McKnight was transported to the Clark Fork Valley Hospital in nearby Plains, Montana.

Officer Jared Hutchings (Officer Hutchings), of the Plains Police Department, met the

ambulance at Clark Fork Valley Hospital to identify the passenger from the crash.

2 ¶4 At the hospital, Officer Hutchings confirmed McKnight’s identity. Hospital staff

cut McKnight’s clothes off in preparation for x-rays. The on-duty nurse requested help

from Officer Hutchings because live ammunition fell out of McKnight’s pocket. A pipe

and baggie containing suspected methamphetamine were found in McKnight’s clothing.

The substance weighed five grams and tested positive for methamphetamine.

¶5 The subsequent investigation of the crash scene revealed drugs and paraphernalia in

plain view. Law enforcement seized approximately ten grams of suspected heroin, various

firearms, a scale, baggies, a loaded syringe with suspected heroin, magazines, and

ammunition. On June 30, 2021, McKnight was charged with Criminal Possession of

Dangerous Drugs,1 a felony, in violation of § 45-9-102, MCA.

¶6 The parties appeared for jury trial on September 12, 2022. McKnight moved to

substitute his attorney prior to voir dire. The District Court denied the motion after

conducting a hearing with McKnight and his attorney. After voir dire, the State made its

opening statement and called its first witness. McKnight’s attorney cross-examined the

State’s first witness prior to lunch. The parties recessed for lunch at 11:46 a.m. and were

to be back at 12:50 p.m.

¶7 The court reconvened on the record at 1:06 p.m. McKnight was not present. The

parties discussed whether trial could continue in McKnight’s absence. The court cited

1 McKnight was also charged with Criminal Possession of Dangerous Drugs with the Intent to Distribute, a felony, in violation of § 45-9-103, MCA; Criminal Endangerment, a felony, in violation of § 45-5-207, MCA; Unlawful Possession of a Firearm by a Convicted Person, a felony, in violation of § 45-8-313, MCA; and four counts of Unlawful Use/Possession of Property Subject to Criminal Forfeiture, a felony, in violation of § 45-9-206(1), MCA. These charges were dismissed without prejudice prior to trial. 3 § 46-16-122(3)(b), MCA, which addresses the absence of a defendant after trial has

commenced in their presence. On McKnight’s behalf, his attorney objected to resuming

trial. The District Court, relying on § 46-16-122(3)(b), MCA, overruled the objection and

proceeded with trial. The District Court reasoned that the absence of the defendant does

not prevent the trial from continuing if the defendant is voluntarily absent and the offense

is not one that is punishable by death.

¶8 Trial resumed and the jury returned with a verdict at 3:24 p.m. The District Court

noted on the record that neither McKnight nor his trial counsel were present and proceeded

to the verdict.2 The jury found McKnight guilty. Prior to adjourning, the State requested

a warrant for McKnight because the State “believe[d] the defendant . . . absconded.” The

District Court issued the warrant. McKnight was arrested on the warrant on September 15,

2022, and was released on his own recognizance. McKnight failed to appear for the

sentencing hearing set for December 13, 2022. The State requested another warrant that

was issued by the District Court. On June 25, 2023, McKnight was arrested and thereafter

appeared on the arrest warrant on June 28, 2023. At the time of his appearance,

McKnight’s trial counsel notified the District Court of a conflict and requested new counsel

be appointed. The District Court ordered new counsel to be appointed as soon as possible.

Sentencing was held on April 9, 2024, after multiple continuances. McKnight was

sentenced to five years to the Montana State Prison, with no time suspended.

2 McKnight’s trial counsel had informed the District Court that “as long as it was okay with the State, he was going to leave because he would not need to do anything further, because he had to travel back to Polson.” 4 ¶9 On appeal McKnight argues that the District Court erred by resuming trial in his

absence. McKnight contends that the parties failed to exercise due diligence to secure his

presence prior to the verdict. McKnight also argues that his counsel was ineffective when

he failed to challenge the warrantless search of his clothing. McKnight contends that a

successful suppression motion would have prevented the State from meeting its burden of

proof at trial. He seeks a reversal of his conviction and a remand for a new trial.

STANDARDS OF REVIEW ¶10 “We exercise plenary review over constitutional questions, including alleged

violations of a criminal defendant’s right to be present at critical stages of the proceedings

against him.” State v. Wilson, 2013 MT 70, ¶ 9, 369 Mont. 282, 297 P.3d 1208 (citing

State v. Charlie, 2010 MT 195, ¶ 21, 357 Mont. 355, 239 P.3d 93).

¶11 “We review a district court’s statutory interpretation and construction de novo for

correctness.” State v. Clinkenbeard, 2025 MT 54, ¶ 5, 421 Mont. 137, 565 P.3d 1259

(citations omitted). Where the plain meaning of words used in a statute can be determined,

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2025 MT 288, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-j-mcknight-mont-2025.