Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals reversing Defendant's conviction for being a convicted felon in possession of a handgun on the grounds that the trial court erred in denying Defendant's motion to suppress, holding that the court of appeals erred in concluding that the Commonwealth's reasonable suspicion argument was precluded.In his motion to suppress, Defendant argued that the traffic stop in the case was impermissibly prolonged beyond its original purpose and violated his Fourth Amendment rights. The trial court denied the motion without addressing whether the officers had independent reasonable suspicion to extend the stop. The court of appeals reversed, concluding (1) the officers deferred completion of the stop beyond its original purpose for a purpose totally unrelated to the original stop; and (2) the Commonwealth was precluded from arguing reasonable suspicion of criminal activity as a justification for the extension. The Supreme Court reversed in part, holding that the court of appeals (1) correctly held that Defendant's stop was impermissibly extended; but (2) erred in concluding that the Commonwealth's reasonable suspicion argument was precluded. The Court remanded the case to the trial court for additional factual findings and conclusions of law as to the officers' reasonable suspicion. View "Commonwealth v. Mitchell" on Justia Law

The Supreme Court affirmed the court of appeals' opinion affirming the decision of the Workers' Compensation Board, holding that Karen Woodall, the surviving spouse of an employee who died as a result of a workplace accident, was entitled to a statutory income benefit and that the time limitation as to the lump-sum benefit does not violate the United States and Kentucky constitutional guarantees of equal protection or Kentucky's prohibition against special legislation.Ten years after a workplace injury, Steven Spillman died as a result of a surgery required by that injury. Woodall, Spillman's surviving spouse, sought income benefits under Ky. Rev. Stat. 342.750(1)(a), and Spillman's estate sought a lump-sum benefit under Ky. Rev. Stat. 342.750(6). The Board found that Woodall was eligible for the surviving spouse income benefits but that the Estate was not entitled to the lump-sum death benefit. The court of appeals affirmed. The Supreme Court affirmed, holding (1) section 342.750(1)(a) contains no temporal limitation on Woodall's receipt of income benefits; and (2) the time limitation as to the lump-sum benefit is constitutional. View "Calloway County Sheriff's Department v. Woodall" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder and sentence of life imprisonment, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held that the trial court (1) did not err by refusing to remove six jurors for cause; (2) did not abuse its discretion in refusing a change of venue; (3) did not abuse its discretion in allowing testimony regarding Defendant's lack of remorse; (4) did not abuse its discretion in disallowing two defense exhibits; (5) did not err in limiting the evidence of Defendant's drug use; (6) did not err in allowing victim impact testimony; (7) did not abuse its discretion in admitting a certain witness's testimony; and (8) did not err in declaring another witness unavailable and allowing her prior trial testimony to be played for the jury. View "Hubers v. Commonwealth" on Justia Law

The Supreme Court held that Ky. Rev. Stat. 189.390 subsections (3)-(5) do not violate the due process provisions of the United States and Kentucky Constitutions on the grounds that the speed limit statutes are unconstitutionally vague, holding that sections 189.390(3)-(5) are not unconstitutionally vague.Defendant was charged with speeding. Defendant moved the district court to find that section 189.390 was void for vagueness because a reasonable person could not read the statute and understand which speed limit applied on any given road in Kentucky. The district court found section 189.390(3)-(5) to be facially unconstitutional by failing to provide citizens with sufficiently definite notice of the applicable speed limits on Kentucky roads. The Commonwealth requested certification of the law regarding the constitutionality of section 189.390(3)-(5). The Supreme Court granted the request and held that the provisions of the statute are not void for vagueness and do not violate the state or federal Constitutions because section 189.390(3)-(5) provides citizens with fair notice of the proscribed conduct and does not encourage arbitrary enforcement. View "Commonwealth v. Curry" on Justia Law

The Supreme Court affirmed Conrai Kaballah's conviction of criminal attempt-murder, first-degree assault, and other crimes and Ricardo Taylor's conviction of criminal attempt-murder, first-degree assault, and other crimes and both defendant's sentences of life imprisonment, holding that any errors were harmless.Specifically, the Supreme Court held (1) both defendants should have been Mirandized prior to being interrogated shortly after the assault occurred; (2) the trial court erred by allowing a transcript commissioned by the Commonwealth of a phone call Taylor made from jail to be shown during closing arguments; and (3) both errors were harmless as a matter of law due to the overwhelming evidence against the defendants and the inconsequential nature of the evidence produced from the errors. View "Taylor v. Commonwealth" on Justia Law

The Supreme Court held that Plaintiffs, eight members of the Kentucky Retirement System's (KRS) defined-benefit retirement plan, did not have standing to bring claims for alleged funding losses sustained by the KRS plan against former KRS trustees and officers and private-investment advisors and hedge funds and their principals.Plaintiffs alleged that KRS trustees and officers attempted to gamble their way out of an actuarial shortfall by investing $1.5 billion of KRS plan assets in high-risk products offered by the defendant hedge-fund sellers, resulting in a multimillion dollar loss that contributed to what was a $25 billion funding shortfall in the KRS general pool of assets. Defendants moved to dismiss the claims for lack of constitutional standing. The circuit court denied the motion. The Supreme Court reversed, holding that Plaintiffs did not have an injury in fact that was concrete or particularized and therefore did not have standing to bring their claims. View "Overstreet v. Mayberry" on Justia Law

The Supreme Court reversed Defendant's conviction for first-degree manslaughter, tampering with physical evidence, possession of a handgun by a convicted felon, and second-degree persistent felony offender and twenty-five-year sentence, holding that Defendant was deprived of his right to counsel at a critical stage of the proceedings.On appeal, Defendant asserted that he was denied the right to conflict-free counsel during an in-chambers hearing that the trial court conducted on the fitness and ability of Defendant's private attorney to try the case. Defendant argued that the in-chambers hearing on his attorney's fitness was a critical stage of the proceedings and that he was prejudiced by not having conflict-free counsel represent him. The Supreme Court agreed, holding that the trial court's decision not to inform Defendant of the concerns raised about his counsel's fitness to try the case and not to offer Defendant the opportunity to retain independent counsel to represent his interests was an error of constitutional magnitude mandating reversal. View "Downs v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of three counts of first-degree trafficking in a controlled substance, holding that the trial court did not err in refusing to suppress evidence that was found on Defendant's person during a warrantless search.On appeal, Defendant argued that the trial court erred in denying his motion to suppress because (1) the officer illegally extended the traffic stop beyond its original purpose, (2) the continued detention of Defendant after the traffic stop constituted an illegal seizure, and (3) the officers did not have probable cause to search his person. The Supreme Court affirmed, holding (1) the lawful traffic stop had not concluded at the time consent was obtained to search the vehicle, and the officer did not inquire into matters unrelated to the stop's mission; (2) Defendant's detention during the search of the vehicle was reasonable; and (3) a search of Defendant's person was warranted under the circumstances. View "Carlisle v. Commonwealth" on Justia Law

The Supreme Court reversed Defendant's convictions for first-degree fleeing or evading, first-degree wanton endangerment, reckless driving, and being a first-degree persistent felony offender, holding that the trial court erred by depriving Defendant of the right to be represented during a critical stage of the trial.On appeal, Defendant argued, among other things, that he was denied representation at a critical stage of his trial through the trial court's ex parte discussion with a juror who had been offered a bribe. The trial court's interview with the juror was conducted outside of Defendant's presence. The Supreme Court reversed Defendant's convictions, vacated the sentences, and remanded this matter to the trial court for further proceedings, holding that the trial court's failure to take action to include counsel during the bench conference and the failure to admonish the juror to disregard her encounter and not to discuss the attempted bribe with fellow jurors violated Defendant's right to a fair trial as guaranteed by his rights to representation and right to be present at all critical stages of trial. View "Eversole v. Commonwealth" on Justia Law

The Supreme Court vacated the interlocutory orders of the trial court concluding that Defendants' individual psychological assessments provided further support for the exclusion of the death penalty as to Defendants individually, holding that the constitutional issue in this case was not a "justiciable cause" before the circuit court and was not properly before the Supreme Court.At issue in these consolidated cases was whether evolving standards of decency require that the Eighth Amendment prohibit imposition of the death penalty as to a defendant under twenty-one years old at the time of his offense. Defendants argued before the circuit court that the current national consensus and scientific research supported raising the age for death-penalty eligible from age eighteen to twenty-one. At this stage in the proceedings, none of the defendants had been convicted or sentenced. The circuit court declared Kentucky's death penalty statute unconstitutional under the Eighth Amendment insofar as it permits capital punishment for offenders under twenty-one years old at the time of their offense and that two of the defendants should not receive the death penalty. The Supreme Court vacated the interlocutory orders, holding that none of the defendants had standing to raise an Eighth Amendment challenge to the death penalty. View "Commonwealth v. Bredhold" on Justia Law