Justia Kentucky Supreme Court Opinion Summaries

Appellant was convicted of incest, first-degree rape, first-degree sodomy, and other crimes. Appellant was sentenced to a total of sixty-five years in prison, the maximum sentence allowable in this case. On appeal, Appellant argued, inter alia, that he was entitled to relief because during voir dire the juror who ultimately became foreperson lied on her juror qualification form and also during voir dire proceedings concerning whether a member of her family had ever been prosecuted in a criminal matter. The Supreme Court reversed and remanded for a new trial, holding (1) the jury foreperson wrongfully failed to disclose the criminal prosecutions of her family, and the concealment of that information denied Appellant the opportunity to challenge the juror for cause or alternatively, use a peremptory strike to remove the juror; and (2) Appellant was deprived of a substantial right not subject to harmless error analysis. View "Gullett v. Commonwealth" on Justia Law

Appellants were charged with one count each of cultivation of marijuana five or more plants and other drug-related offenses. Appellants filed separate motions to suppress, arguing (1) police officers violated the curtilage of their apartment when they entered the back patio enclosure, thereby having no legal authority to view marijuana baggies, and (2) the officers lacked any exigencies to enter the apartment and conduct the search. The trial court denied Appellants’ motions to suppress. The court of appeals affirmed. The Supreme Court reversed, holding (1) officers breached the curtilage of Appellants’ apartment when viewing the marijuana baggies, in addition to conducting an illegal search of Appellants’ apartment; and (2) the evidence seized should be excluded as fruit of the poisonous tree. View "Pace v. Commonwealth" on Justia Law

Defendant entered a conditional guilty plea to one count of first-degree rape, one count of second-degree rape, and one count of second-degree sodomy. Defendant appealed, arguing that the trial court erred in denying his motion to suppress the evidence of his confession, arguing that the police obtained his confession in violation of Miranda v. Arizona because he did not knowingly and voluntarily waive his rights guaranteed under the Fifth Amendment. The Supreme Court affirmed, holding that Miranda did not apply because Defendant was not in custody at the time he made incriminating statements to the police. View "Wells v. Commonwealth" on Justia Law

Defendant was convicted of second-degree assault. A public defender from the local Department of Public advocacy (DPA) office was appointed to represent Defendant. Prior to trial, counsel advised the trial court that another attorney in the local DPA was representing the alleged victim in an unrelated matter. Defendant requested the appointment of new counsel. The trial court denied the request, concluding that there was not conflict of interest, and ordered the trial to proceed. Defendant appealed, arguing that the trial court’s refusal to appoint new counsel violated his right to conflict-free counsel under the Sixth Amendment. The court of appeals ultimately concluded that Defendant had not shown that his lawyer had an unconstitutional conflict of interest during her representation of him. The Supreme Court affirmed, holding (1) a public defender’s conflict of interest is not necessarily imputed to all other public defenders in the same Public Defender office; and (2) Defendant was not denied his Sixth Amendment right to conflict-free counsel in this case. View "Samuels v. Commonwealth" on Justia Law

Ray Ballou worked as an underground coal miner from 1982 until 2012 and was sixty-nine years old when last exposed to coal dust. An administrative law judge (ALJ) awarded Ballou retraining incentive benefits (RIB), finding that Ballou had category 1/1 coal workers’ pneumoconiosis. Due to Ballou’s advanced age, however, the ALJ determined that Ballou could only receive those benefits if he participated in an approved retraining or educational program. Ballou challenged the constitutionality of the RIB statute’s age classifications. The court of appeals concluded that those age classifications are constitutional. The Supreme Court affirmed, holding that the age classifications at issue did not violate Balou’s right to equal protection. View "Ballou v. Enterprise Mining Co., LLC" on Justia Law

Defendant entered a conditional guilty plea to violating Lexington-Fayette Urban County Government Ordinance 14-5, which prohibits all begging and soliciting from public streets or intersections within the urban-county area. On appeal, the circuit court affirmed the judgment of conviction and sentence, determining that Lexington’s Ordinance 14-5 is a content-neutral regulation of speech, thereby requiring a less exacting standard of scrutiny to remain constitutionally viable. The Supreme Court reversed, holding that Ordinance 14-5 is a content-based regulation of expression that unconstitutionally abridges freedom of speech under the First Amendment. Remanded to the district court for dismissal of the charge against Defendant. View "Champion v. Commonwealth" on Justia Law

Appellant entered a conditional guilty plea to possession a handgun as a convicted felon, possessing marijuana, and operating a motor vehicle on a suspended license. Appellant appealed the trial court’s order denying his motion to suppress evidence found in the vehicle he was driving at the time of his arrest. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the record contained substantial evidence supporting the trial court’s findings of fact; (2) warrantless searches are per se unreasonable, subject to a few well-established exceptions, such as inventory searches; and (3) under the circumstances of this case, the police acted reasonably in seizing Appellant’s vehicle and performing the subsequent inventory search of its contents. View "Cobb v. Commonwealth" on Justia Law

In 2015, the Louisville/Jefferson County Metro Government (Louisville Metro) enacted its own minimum wage ordinance for al employers within the Louisville Metro boundary. The ordinance required a higher wage than the statutory minimum. Appellants filed an action against Louisville Metro, arguing that the ordinance was void as being outside the authority of Louisville Metro to enact. The circuit court entered a ruling in favor of Louisville Metro. The Supreme Court reversed, holding that Louisville Metro exceeded its authority by enacting the ordinance because the ordinance conflicts with the comprehensive statutory scheme in Ky. Rev. Stat. 337 on the issue of wages. View "Kentucky Restaurant Ass’n v. Louisville/Jefferson County Metro Government" on Justia Law

After a jury trial, Defendant was convicted of first-degree robbery and of being a first-degree persistent felony offender. Defendant appealed, arguing that the trial court violated his right to a public trial when it cleared visitors from the courtroom during the victim’s testimony and when it denied his motion to suppress an out-of-court photo identification. The Supreme Court affirmed the trial court’s judgment on both issues, holding (1) because Defendant failed to object to the courtroom closure, he waived his argument that his right to a public trial was violated; and (2) the trial court did not abuse its discretion in concluding that the out-of-court identification was valid. View "Crutcher v. Commonwealth" on Justia Law

The juvenile Appellant in this case, "Bill," a fifteen-year-old eighth-grade boy, was charged with multiple public offenses based on his sexual conduct with his thirteen-year-old girlfriend "Carol", who was not charged. He entered an unconditional admission to amended charges, and the district court entered an adjudication finding that he committed the alleged conduct. After disposition of his case, he appealed to the circuit court, which affirmed. The Court of Appeals denied his motion for discretionary review, but the Supreme Court granted it initially to address constitutional challenges that Bill raised. After consideration of those challenges, the Supreme Court concluded that the appeal should have been dismissed by the circuit court, with no consideration of any of the substantive issues raised, because Bill entered an unconditional admission to the offenses and thereby waived an appeal in this case. View "B. H. v. Kentucky" on Justia Law