Justia Kentucky Supreme Court Opinion Summaries

Appellant appealed convictions of complicity to manufacture methamphetamine, first-degree possession of methamphetamine, possession of marijuana, possession of drug paraphernalia, and first-degree persistent felony offender. At issue was whether the trial court erred by refusing to suppress all evidence discovered via a warrantless hotel room search and by failing to enter a directed verdict. The court affirmed the conviction and held that appellant did not have a reasonable privacy expectation in the hotel room where the search was conducted after the checkout time elapsed. The court also held that the trial court did not err by failing to enter a directed verdict because appellant was convicted of two previous felonies and the "concurrent sentence break" did not apply to appellant.

Appellant appealed from his convictions of first-degree sodomy and first-degree sexual abuse for which he received a total sentence of life imprisonment. Appellant raised numerous assignments of error, most of which were not preserved by trial counsel, for which appellant requested palpable error review under RCr 10.26. The court held that the admission of an egregious amount of inadmissible hearsay required appellant's convictions to be reversed and remanded for a new trial.

Appellant was convicted of multiple sex crimes against his daughter which occurred over the course of fifteen years. Appellant raised numerous issues on appeal. The court held that appellant's conviction on Count 6 was reversed where the Commonwealth conceded that there was insufficient evidence to convict him of the rape described due to the absence of testimony that sexual intercourse had begun by that point. The court also held that all other convictions were affirmed and the case was remanded for modification and re-entry of judgment.

Appellant Prince Wilbert Woolfolk was convicted of first-degree rape. On the jury's recommendation, he was sentenced to twenty years' imprisonment. In 1984, the victim was seventeen years old and an active member in her church's choir. On the date of the crime, the victim learned from her mother that Appellant, the pastor of the church, had called to say he would pick her up from school and take her to church, presumably for a choir activity. According to the victim, Appellant took her to his office and raped her. Twenty-three years later, the victim attempted suicide. Believing that the rape may have played a part in the attempt, the victim's mother contacted police about the 1984 incident. On investigation, Appellant admitted to police that a sexual encounter with the victim occurred. In 2008, Appellant was indicted for first-degree rape. During a lunch break at trial, Appellant's defense counsel conferred to discuss how to best cross-examine the victim about her claim; to counsel's surprise, and contrary to all prior statements Appellant had made on the subject, Appellant told his counsel he raped the victim. Counsel became concerned on his ethical duty to the court should Appellant take the stand and deny the rape. Counsel contacted the Kentucky Bar Association and requested an ex parte in camera conference with the court. Counsel moved the court to order a competence examination of Appellant, and to delay proceedings pending such an examination. The court denied both requests. On appeal, Appellant claims: that the trial court erred by discouraging Appellant from exercising his constitutional right to testify; that the trial court erred by failing to order a competency evaluation; and that there was a violation of his right to a speedy trial because of the twenty-four year lapse of time between the crime and the bringing of the indictment. Upon review, the Supreme Court concluded that the lower court did not abuse its discretion in failing to order a competency hearing; and though constitutional error occurred in the trial court's effort to discourage Appellant from testifying falsely, the error was harmless beyond a reasonable doubt. The Court affirmed the lower court's conviction and sentence.