Justia Kentucky Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to twenty years' imprisonment for his convictions of two counts of manslaughter in the second degree, driving under the influence of controlled substances first offense, and persistent felony offender first degree, holding that Defendant's claims of error did not warrant reversal.Specifically, the Supreme Court held (1) the trial court was correct in declining to suppress Defendant's statements statements he made at the accident scene, and suppression of Defendant's blood test was not required in this case; (2) the trial court did not err in excusing a prospective juror for cause; and (3) while certain statements were not properly admissible during the Commonwealth's examination of detective Brandon McPherson, they did not rise to the level of palpable error resulting in manifest injustice. View "Simpson v. Commonwealth" on Justia Law

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The Supreme Court affirmed in part and vacated in part the judgment of the circuit court in this criminal case, holding that the case must be remanded for the trial court to consider whether Defendant's consent to a blood draw was voluntary under the totality of the circumstances.Defendant entered a conditional plea to one count of manslaughter in the first degree and one count of manslaughter in the second degree. The Supreme Court affirmed in part and vacated in part, holding that the trial court (1) did not err by failing to suppress Defendant's statements obtained without a Miranda warning; (2) erred in suppressing the results of Defendant's blood draw without determining whether her consent was voluntary where she received a warning that if she refused the blood test and were convicted of DUI, her mandatory minimum jail sentence would be doubled; and (3) did not err by failing to dismiss the case due to alleged abuse of the grand jury process. View "Haney v. Commonwealth" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court denying Defendant's motion to suppress location data obtained from the police's search of his real-time cell-site location information (CSLI) and the evidence obtained from the search, holding that suppression was required.Defendant entered a conditional guilty plea to one count of first-degree robbery, one count of possession of a handgun by a convicted felon, and one count of receiving stolen property. The court of appeals reversed, concluding that the trial court erred in denying Defendant's motion to suppress because the police's acquisition of Defendant's real-time CSLI constituted a warrantless, unreasonable search. The Supreme Court affirmed, holding that the officers illegally obtained Defendant's real-time CSLI and that the evidence obtained therefrom should be excluded from evidence. View "Commonwealth v. Reed" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court denying Appellant's Ky. R. Crim. P. 11.42, Ky R. Crim. P. 10.02, Ky. R. Civ. P. 60.02, and Ky. R. Civ. P. 60.03 motion for relief, holding that the circuit court did not err.Appellant was convicted of two counts of complicity to murder and other crimes and sentenced to death. In the instant motion, Appellant argued that McCoy v. Louisiana, 138 S.Ct. 1500 (2018), governed his claim that his defense counsel provided ineffective assistance. The circuit court denied the motion, determining that the claim was both substantively and procedurally improper. The Supreme Court affirmed, holding that there was no error in the circuit court's denial of relief. View "Epperson v. Commonwealth" on Justia Law

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The Supreme Court dismissed Appellants' claims in this case raising questions regarding a challenge to a constitutional ballot initiative, holding that Appellants lacked standing to bring their claims.In 2018, Kentucky voters ratified the constitutional amendment known as Marsy's Law, but the Supreme Court invalidated the amendment on procedural grounds. In 2020, after the General Assembly again proposed the Marsy's Law constitutional amendment, Appellants brought a complaint seeing declaratory and injunctive relief either prohibiting Marsy's Law from appearing on the ballot or preventing tabulation of votes on ratification of the amendment. The trial court ruled against Plaintiffs on their procedural claims but concluded that Appellants' facial challenges to Marsy's Law were not ripe. After the parties appealed, Kentucky voters ratified that Marsy's Law constitutional amendment. The Supreme Court dismissed this appeal, holding that Appellants lacked constitutional standing to bring their claims because they failed to allege a concrete and particularized injury in fact on the record. View "Ward v. Westerfield" on Justia Law

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The Supreme Court affirmed the judgment of the circuit court finding Defendant guilty of two counts of murder and four counts of wanton endangerment in the first degree and sentencing him to life in prison without the possibility of parole, holding that there was no error or abuse of discretion.In 2012, a jury found Defendant guilty but mentally ill of murder and wanton endangerment. The Supreme Court reversed the conviction and remanded the case for a new trial. On remand, the main issue at trial was Defendant's affirmative defense of insanity or, in the alternative, extreme emotional disturbance. A jury found Defendant guilty of the crimes and sentenced to life in prison without the possibility of parole. The Supreme Court affirmed, holding Defendant's claims on appeal were without merit. View "Hall v. Commonwealth" on Justia Law

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The Supreme Court reversed the judgment of the circuit court opining on the constitutionality of the Governor's 2021 COVID-19 legislation and enjoining the Governor from interfering with Plaintiffs' business operations, holding that Plaintiff lacked standing to bring this action.In its 2021 regular session, the General Assembly passed three bills amending the Governor's emergency powers under Ky. Rev. Stat. 39A. Plaintiff, a business, sought to enjoin the Governor from any action contrary to the 2021 legislation. The circuit court entered an amended judgment declaring the constitutionality of the 2021 COVID-19 legislation, holding any orders to the contrary imposed by the Governor unconstitutional, and prohibiting the three named defendants from enforcing any emergency order, decree or regulation in conflict with the 2021 legislation. The Supreme Court reversed, holding that Plaintiff plainly had no standing to bring this action, and the circuit court had no jurisdiction. View "Beshear v. Ridgeway Properties, LLC" on Justia Law

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The Supreme Court granted a writ of mandamus sought by The Cincinnati Enquirer, a Division of Gannett GP Media, Inc., and directed at two judges of the Kentucky Court of Appeals who presided over separate trials in which the Enquirer was denied leave to intervene, holding that the Court of Appeals erred.These matters concerned constitutional challenges to Casey's Law, Ky. Rev. Stat. 222.430. Because all proceedings in such actions are confidential and not open to the general public the Court of Appeals entered orders in each action directing the record to remain confidential and restricting access to the Court. The Enquirer moved to intervene in each action to obtain access in order to court records. Intervention was denied. The Supreme Court reversed, holding that the Court of Appeals erroneously denied access to the record. View "Cincinnati Enquirer v. Honorable Dixon" on Justia Law

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The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress evidence of cocaine discovered after a dog sniff of the vehicle in which Defendant was a passenger, holding that the stop was extended, and that extension was not justified by reasonable, articulable suspicion.Defendant was charged with first-degree possession of cocaine. He pled not guilty and filed a motion to dismiss, claiming that he was illegally detained and that the police did not have reasonable, articulable suspicion to call the dog. The trial court determined that it was a valid stop and that the evidence should not be suppressed. The Supreme Court affirmed, holding (1) the traffic stop was extended; (2) the Commonwealth failed to establish simultaneous missions that permitted the seizure; and (3) the Commonwealth did not meet its burden of establishing reasonable, articulable suspicion. View "Commonwealth v. Clayborne" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing the trial court's denial of Defendant's motion to suppress evidence found in a drug dog sniff search during a traffic stop of the vehicle in which Defendant was a passenger, holding that the trial court erred by denying the motion to suppress.In reversing the denial of Defendant's motion to suppress, the court of appeals concluded that the investigating officer unconstitutionally extended the duration of the traffic stop to accommodate the dog-sniff search. The Supreme Court affirmed, holding that the Commonwealth failed to establish that the extension of the traffic stop was supported by reasonable, articulable suspicion. View "Commonwealth v. Conner" on Justia Law