Justia Kentucky Supreme Court Opinion Summaries

In 1998, Robert Keith Woodall was sentenced to death for the kidnapping, rape, and murder of a teenage girl. In 2015, Woodall filed a Motion to Vacate the Death Sentence Due to Intellectual Disability, arguing that he is intellectually disabled and thus the imposition of the death penalty would violate his constitutional rights. The trial court denied his motion without a hearing. On appeal, the Supreme Court of Kentucky reversed and remanded the case for an evidentiary hearing.On remand, the trial court held an evidentiary hearing and again denied Woodall’s motion. The court found that Woodall had not proven by the preponderance of the evidence that he is intellectually disabled. Woodall appealed this decision to the Supreme Court of Kentucky.The Supreme Court of Kentucky affirmed the decision of the trial court. The court found that the trial court's factual findings were supported by substantial evidence and that Woodall had not proven that he is intellectually disabled by a preponderance of the evidence. The court also rejected Woodall's arguments that the trial court violated his due process rights and Confrontation Clause rights by admitting and relying on a report without requiring the report's author to testify at the hearing. View "WOODALL V. COMMONWEALTH OF KENTUCKY" on Justia Law

Ricky Ullman was convicted on three counts of distribution of a matter portraying a sexual performance by a minor and of being a second-degree persistent felony offender. He was sentenced to twelve years, probated for five years, with several conditions including completion of a community-based sex offender treatment program (SOTP). The court later revoked his probation due to his failure to complete the SOTP, among other violations. Nearly two years after his probation was revoked, Ullman filed a motion challenging the revocation order, arguing that he could not be legally required to complete the SOTP. The circuit court granted him relief and vacated its revocation order, a decision affirmed by the Court of Appeals.The Supreme Court of Kentucky reversed the lower courts' decisions, holding that Ullman’s challenge to the condition that he complete the SOTP was untimely and reinstated the circuit court’s revocation order. The court also held that a sentencing court may impose SOTP as a condition of probation for defendants who have not been convicted of a “sex crime” as defined by KRS 17.500. The court declined to address Ullman’s argument that the circuit court’s revocation order failed to comply with KRS 439.3106, as it was not properly preserved for review. However, the court agreed to remand the case for consideration of Ullman’s claim of ineffective assistance of counsel. View "COMMONWEALTH OF KENTUCKY V. ULLMAN" on Justia Law

The case involves Demetrius Roberson, who was convicted by a Logan County jury for murder, first-degree robbery, nine counts of first-degree wanton endangerment, and attempted murder. The case arose from an incident where two men, one of whom was identified as Roberson, entered an apartment and fired shots, killing Lexus Bell and endangering several others present. The prosecution's theory was that Roberson and another individual, Reba Kirk, planned to rob the apartment as a form of retaliation against Bell's boyfriend, who had allegedly stolen from Kirk's drug dealing business. Roberson was sentenced to life without parole for twenty-five years.Roberson appealed his conviction to the Supreme Court of Kentucky, raising several issues. He argued that the trial court erred in excluding evidence that another man admitted to the shooting, in admitting deposition testimony of a deceased witness, in excluding testimony regarding why he broke up with his child’s mother, in allowing the prosecution to accuse his mother of lying and committing perjury, in excluding evidence that his family attempted to provide police with exculpatory evidence, in failing to sequester the jury during its guilt phase deliberations, in allowing the jury to review only a portion of a witness’s testimony, and in imposing the longer of two inconsistent sentences recommended by the jury.The Supreme Court of Kentucky affirmed the judgment of the Logan Circuit Court, finding no reversible error in the trial court's rulings and actions. The court held that the trial court did not abuse its discretion in its evidentiary rulings, that the jury was properly instructed, and that the sentence imposed was within the trial court's discretion. View "ROBERSON V. COMMONWEALTH OF KENTUCKY" on Justia Law

A man, convicted of murder, tampering with physical evidence, and possession of a handgun by a felon, appealed his convictions and sentence to the Supreme Court of Kentucky. The case centered around the shooting death of a bar owner. The defendant argued that he shot in self-defense during a struggle, but the prosecution argued that the defendant was the initial aggressor, pointing to high-quality security camera footage that captured the events leading up to and following the shooting.The Supreme Court affirmed the lower court's decision. The Court found that the defendant was not in custody when initially questioned at the hospital, so his Miranda rights were not violated. The Court also ruled that the trial court did not err in issuing an "initial aggressor" limitation to the jury's self-defense instructions, as the defendant’s act of pointing a gun at the victim constituted "physical force" under Kentucky law. Finally, while the trial court erred in the manner it polled the jury, the Supreme Court found the error was not "palpable" and would not have changed the result of the case. View "BOWMAN V. COMMONWEALTH OF KENTUCKY" on Justia Law

In this case, Bennett D. Couch was convicted by the Kenton Circuit Court for possession and transfer of child pornography in violation of Kentucky Revised Statutes (KRS) 531.335 and 531.340. The conviction was based on evidence procured through search warrants for Couch's Tumblr account, apartment, cell phones, and computers. The investigation was initiated after the National Center for Missing and Exploited Children (NCMEC) reported that three pornographic images of children were being circulated online, which were traced back to Couch's IP address. Couch challenged the constitutionality of KRS 531.330’s presumption as to minority and the legality of the search of her apartment.The Supreme Court of Kentucky, in an opinion delivered by Chief Justice VanMeter, affirmed the lower court's decision. The court held that Couch's constitutional challenge was not considered as she failed to provide the required notice to the Attorney General. Regarding the legality of the search, the court determined that the search warrant affidavits provided substantial basis for the issuing judge to conclude that probable cause existed to issue the original search warrant, despite Couch's claims that the affidavits lacked probable cause, failed to identify the criminal statutes violated, and did not establish a nexus between the criminal activity and her apartment. The court also dismissed Couch's claims of prosecutorial misconduct and failure of the trial court to properly consider the Presentence Investigation Report due to lack of procedural compliance. View "Couch v. Commonwealth" on Justia Law

In 2024, the Supreme Court of Kentucky reviewed the case of Kory E. Helmick who was convicted by a Greenup County jury of two counts of sodomy in the third degree, one count of sodomy in the first degree, one count of sexual abuse in the first degree, and one count of unlawful use of an electronic communication system to procure a minor to engage in sexual or other prohibited activity. The victim, J.K., was a minor in foster care who lived with Helmick and Helmick’s husband intermittently from the age of 13 to 15. Helmick appealed his conviction, arguing three points of error: the trial court's denial of his request to postpone the trial, insufficient proof supporting the sodomy in the first degree conviction, and violation of his right to be free from double jeopardy due to convictions for both sodomy in the first degree and in the third degree.The Supreme Court of Kentucky rejected all three allegations. First, the court found no abuse of discretion by the trial court in denying Helmick's request to postpone the trial. The request was based on the desire to conduct a forensic analysis of the victim's cell phone, but the court found Helmick had ample time to conduct this analysis before the trial and did not provide an affidavit showing the materiality of the evidence expected to be obtained from the phone, which was required for such a request.Second, regarding the sufficiency of the proof for the sodomy in the first degree conviction, the court found that there was more than a mere scintilla of evidence supporting the conviction. The victim's testimony that he was "incapacitated" and "incapable of moving" due to alcohol intoxication was seen as evidence that he was physically helpless during the sexual abuse, a requirement for a conviction of sodomy in the first degree.Finally, the court rejected Helmick's double jeopardy claim, finding that his convictions for sodomy in the first and third degrees were based on separate criminal acts and thus did not violate his right to be free from being tried twice for the same offense.The Supreme Court of Kentucky therefore affirmed the judgment of the Greenup Circuit Court. View "Helmick v. Commonwealth" on Justia Law

In November 2013, Ahmad Rashad Davis was indicted for Medicaid fraud and theft by deception for defrauding Medicaid of $14,505.36 by falsifying timesheets over two years. In May 2014, the Commonwealth of Kentucky and Davis entered into a plea agreement in which Davis agreed to plead guilty to Medicaid fraud, and in exchange, the Commonwealth recommended to the trial court that Davis's theft by deception charge be dismissed. The trial court accepted Davis's guilty plea and sentenced him to one year of imprisonment, probated for three years or until restitution was paid in full, and dismissed the theft by deception charge. In December 2021, Davis filed a petition to expunge the theft by deception charge. The Commonwealth objected, arguing that the charge was dismissed in exchange for Davis's guilty plea to Medicaid fraud, making it ineligible for expungement under Kentucky Revised Statute (KRS) 431.076(1)(b). The circuit court granted Davis's petition without holding a hearing, and the Court of Appeals affirmed the decision. The Supreme Court of Kentucky granted discretionary review and reversed the decisions of the lower courts.The Supreme Court of Kentucky held that a circuit court can look beyond the sentencing court's final judgment to determine whether a dismissal was granted in exchange for a guilty plea to another charge. The court ruled that the circuit court erred in failing to do so in Davis's case. As a result, the Supreme Court reversed the Court of Appeals and vacated the circuit court's order granting expungement. View "COMMONWEALTH OF KENTUCKY V. DAVIS" on Justia Law

In a case involving Steven Roark who was convicted of manufacturing methamphetamine, possession of methamphetamine, and tampering with physical evidence, the Supreme Court of Kentucky reversed the decision of the Court of Appeals, which had held that the jury instruction for manufacturing methamphetamine violated Roark's right to a unanimous verdict. In the case, the police had found Roark in a trailer with an active methamphetamine lab, along with multiple items used in the manufacture of methamphetamine. The jury instructions allowed for a conviction based on either of two theories under Kentucky Revised Statute (KRS) 218A.1432 - either that Roark knowingly manufactured methamphetamine, or that he knowingly possessed two or more items of equipment or chemicals with the intent to manufacture methamphetamine. Roark argued that such instruction violated his right to a unanimous verdict. However, the Supreme Court of Kentucky found no error in the jury instruction, concluding that both theories were supported by the evidence presented at trial, and thus did not violate Roark's right to a unanimous verdict. The court thereby affirmed the judgment and sentence of the trial court as to Roark’s manufacturing conviction. View "Commonwealth v. Roark" on Justia Law

In the case at hand, Jose Sanchez was convicted of five counts of first-degree rape and four counts of third-degree rape. The Supreme Court of Kentucky affirmed these convictions, holding that the text messages and videos were properly authenticated. The court also found that Sanchez was not entitled to a missing evidence instruction regarding his cellphone, as the data extracted from it was preserved, and the phone itself contained no evidence. However, the court reversed and vacated the trial court's imposition of public defender fees against Sanchez, ruling that the imposition of public defender fees was an error as the trial court failed to hold a hearing and determine that Sanchez should not continue to be considered an indigent person. The court also held that the cumulative error did not occur in this case. View "SANCHEZ V. COMMONWEALTH" on Justia Law

In the case before the Supreme Court of Kentucky, the defendant, Gregory Stephens, was convicted of first-degree rape and being a persistent felony offender in the second-degree. The conviction was based on the testimony of the child victim, Amy, and was supported by the testimony of additional witnesses who recounted Amy's prior hearsay statements and vouched for her credibility. Stephens appealed, arguing that the inclusion of these hearsay statements and credibility endorsements rendered his trial fundamentally unfair. The Supreme Court of Kentucky agreed, reversing and remanding the case.The court found that the evidence against Stephens consisted entirely of Amy's statements. There was no physical evidence, and the only other possible witness, Amy's mother, did not testify. The court held that the prosecution was erroneously allowed to elicit testimony from additional witnesses to bolster Amy's testimony, amounting to palpable error. Furthermore, the court found that multiple witnesses were improperly allowed to vouch for Amy's credibility.The court also noted that the deputy jailer's testimony about the impact of the rape on Amy during the guilt phase was improperly admitted. The court stated that such victim impact evidence is not permissible during the guilt phase of the trial.The court concluded that the combined errors of hearsay bolstering, vouching testimony, and victim impact testimony rendered the trial fundamentally unfair and demanded a reversal of the conviction. The case was remanded for a new trial. View "STEPHENS V. COMMONWEALTH" on Justia Law