Justia Kentucky Supreme Court Opinion Summaries

The appellant, a Marine Corps veteran with significant psychiatric disabilities, lived in Knox County, Kentucky, with his children and sister’s family. After separating from his wife, they began to reconcile, and he arranged to lease a second trailer, allegedly through an oral agreement with his landlord. An acquaintance, Deborah Powers, stayed in the trailer, but she claimed to have leased it with her boyfriend, Matthew Welsh. One night, after a party at the trailer, the appellant’s wife alleged she was raped by three men present. Instead of contacting police, the appellant, accompanied by two others, returned to the trailer armed, forcibly entered, and subjected the alleged assailants to threats, violence, and torture. During the confrontation, Welsh stabbed the appellant, who then fatally stabbed Welsh. The appellant was charged with murder, first-degree burglary, and four counts of unlawful imprisonment.The Knox Circuit Court conducted the trial. The appellant’s requests for self-defense and imperfect self-defense jury instructions were denied. The court admitted hearsay testimony regarding a rape kit and allowed a copy of a lease to be introduced over objections concerning the best evidence rule and authenticity. The appellant’s motion for his counsel to withdraw was also denied. The jury convicted him on all charges, and he was sentenced to thirty-five years in prison.The Supreme Court of Kentucky reviewed the case. It held that the trial court did not abuse its discretion in refusing self-defense instructions, as the appellant’s own actions created the deadly situation. The court found no palpable error in the admission of the rape kit testimony, as the error did not substantially affect the defense. However, it concluded that admitting the copy of the lease without proper foundation was an abuse of discretion, requiring reversal of the burglary conviction. The court affirmed the murder and unlawful imprisonment convictions and the overall sentence, remanding for amendment of the judgment to reflect the reversal of the burglary conviction. View "MASTERS V. COMMONWEALTH OF KENTUCKY" on Justia Law

Two individuals, Brandon Waddles and his three-year-old daughter, were killed in their home. The prosecution alleged that the defendant orchestrated the crime by having his girlfriend lure Waddles to the door, after which the defendant, driven to the scene by another accomplice, shot both victims. The defendant was indicted on two counts of murder, first-degree burglary, and being a felon in possession of a handgun. The prosecution’s case relied heavily on the testimony of the accomplices, both of whom had entered plea agreements in exchange for their cooperation.The case was tried in the Jefferson Circuit Court. During the trial, after one accomplice testified, the trial judge, outside the jury’s presence but in front of the media, ordered the witness taken into custody for perjury, stating that the witness had lied under oath. This event was reported by the media, and a juror saw the report, subsequently informing the rest of the jury. During deliberations, a juror reported being unable to decide the case truthfully after learning of the arrest. The defense moved for a mistrial, but the trial court denied the motion, instead excusing one juror and instructing the remaining jurors to disregard the information. The jury ultimately convicted the defendant of both murders and burglary, and he was sentenced to life without parole.On appeal, the Supreme Court of Kentucky held that the trial court erred by not granting a mistrial after the jury became aware that a key prosecution witness had been arrested for perjury at the judge’s direction. The court found that this extrajudicial information tainted the jury and constituted a structural error, depriving the defendant of a fair and impartial trial. The court vacated the convictions and remanded the case for further proceedings. View "LAWLESS V. COMMONWEALTH OF KENTUCKY" on Justia Law

Ava Creech, a 62-year-old woman with severe scoliosis, was found dead in her Lexington apartment in October 2020, bound and gagged in a closet. The investigation revealed that William P. Brown, who had been staying with Creech, was the last person seen with her. Evidence linked Brown to Creech’s stolen car and necklace, both of which he possessed or pawned after her disappearance. Brown’s fingerprints and DNA were found on items in the apartment, and he was later arrested in possession of Creech’s pill bottles. At trial, Brown testified, offering alternative explanations for his possession of Creech’s property and his presence in her apartment.The Fayette Circuit Court conducted a jury trial, where Brown was convicted of murder, receiving stolen property, being a felon in possession of a handgun, and being a second-degree persistent felony offender. The jury recommended a life sentence, which the trial court imposed. Brown appealed as a matter of right to the Supreme Court of Kentucky, raising several issues including prosecutorial misconduct, discovery violations, and Confrontation Clause errors.The Supreme Court of Kentucky found that the Commonwealth’s failure to disclose recorded jail phone calls between Brown and his sister constituted a discovery violation. The Court held that this nondisclosure may have substantially impacted Brown’s defense strategy and presentation, warranting reversal. Additionally, the Court identified errors in the prosecutor’s comments regarding Brown’s decision to testify and the admission of hearsay testimony about a Post-It note’s authorship, which violated Brown’s Confrontation Clause rights. The Supreme Court of Kentucky reversed the judgment and sentence of the Fayette Circuit Court and remanded the case for a new trial. View "BROWN V. COMMONWEALTH OF KENTUCKY" on Justia Law

The appellant was convicted of multiple offenses, including first-degree rape, first-degree sodomy, distribution of obscene material to a minor, use of a minor in a sexual performance, first-degree sexual abuse, and sixty-eight counts of possession of matter portraying a sexual performance by a minor. The charges arose from incidents in which the appellant, while babysitting two children, sexually abused an eight-year-old girl and, over a period of time, also abused a boy who lived with him. The investigation began after the girl disclosed the abuse to her mother, leading to police involvement, the seizure of the appellant’s cellphone, and the discovery of child pornography, including images of the boy.The Madison Circuit Court denied the appellant’s motion to suppress evidence obtained from his cellphone, finding that the warrantless seizure was justified by probable cause and exigent circumstances, and that the delay in obtaining a search warrant was reasonable. At trial, the court admitted images of child pornography extracted from the cellphone, over the appellant’s objections regarding authentication and Confrontation Clause rights. The jury convicted the appellant on all counts, and he was sentenced to life imprisonment.On appeal, the Supreme Court of Kentucky affirmed the convictions. The Court held that raw, machine-extracted data from the Cellebrite forensic tool is not testimonial hearsay and does not implicate a defendant’s Confrontation Clause rights, as such data is not a statement by a person. The Court also found that the photographs were properly authenticated, no prosecutorial misconduct occurred, and there was no double jeopardy violation in convicting the appellant for both use of a minor in a sexual performance and possession of the same image. The Court further held that the evidence was sufficient to support the rape conviction and found no cumulative error. View "BALDWIN V. COMMONWEALTH OF KENTUCKY" on Justia Law

The case concerns a man who was convicted of two counts of murder following the deaths of his aunt and cousin, who were found shot in the aunt’s home. The investigation revealed that the defendant had previously lived at the home, and evidence such as spent shell casings, a magazine, and drug paraphernalia was found at the scene and in his apartment. The defendant was located in California days after the murders, having left Kentucky and nearly emptied his bank account. He was apprehended and questioned by law enforcement, during which he made statements about the case.The Trigg Circuit Court conducted an eight-day trial, during which the defendant raised several objections. He challenged the inclusion of certain jurors for cause, the admission of evidence regarding prior drug use and related activities under Kentucky Rule of Evidence 404(b), and the admission of statements made after he referenced wanting a lawyer during police questioning. He also objected to the conduct of a law enforcement officer at trial, alleging that the officer’s nonverbal reactions could have influenced the jury. After the jury found him guilty and recommended life without parole, the trial court denied his motion for a new trial.On appeal, the Supreme Court of Kentucky reviewed each of the defendant’s claims. The court held that the trial court did not abuse its discretion in refusing to strike the challenged jurors for cause, admitting the contested 404(b) evidence, or admitting the defendant’s statements made before an unequivocal request for counsel. The court also found no abuse of discretion in denying a new trial based on the officer’s conduct, as there was insufficient proof of jury influence. The court further held that the cumulative error doctrine did not apply, as no individual errors were found. The judgment of the Trigg Circuit Court was affirmed. View "STINSON V. COMMONWEALTH OF KENTUCKY" on Justia Law

The case involved a violent confrontation between two former friends, Raiantez Shackles and Marvin Yarbrough, which escalated after a series of personal disputes, including threats and a romantic entanglement. On January 5, 2021, after a prior shooting incident involving their vehicles, Marvin and his wife Cassandra returned home from a funeral to find their residence under threat. Upon arrival, they were confronted by two armed men, and Shackles emerged from behind a tree, pointing a gun at them. A shootout ensued, resulting in both Marvin and Cassandra being shot, while their four children and Marvin’s brother were inside the home. The scene was chaotic, with multiple bullet holes found throughout the residence and a neighbor’s home.A jury in the Jefferson Circuit Court convicted Shackles of two counts of first-degree assault, six counts of first-degree wanton endangerment, possession of a handgun by a felon, and being a first-degree persistent felony offender. The jury recommended a sixty-year sentence, which the trial court reduced to forty-five years under Kentucky law. Shackles appealed, raising several claims of error regarding jury instructions, evidentiary rulings, and the conduct of the sentencing phase.The Supreme Court of Kentucky reviewed the case and affirmed the trial court’s judgment. The Court held that the trial court did not abuse its discretion in declining to give a self-defense instruction, as there was no evidence that Marvin used unlawful force. The Court found that while the admission of certain hearsay evidence was erroneous, it was harmless given the other evidence presented. The Court also upheld the admission of body camera footage and crime scene photographs, denied the directed verdict motions on the wanton endangerment charges, and found no manifest injustice in the jury polling or the admission of victim impact testimony. The judgment of conviction and sentence was affirmed. View "SHACKLES V. COMMONWEALTH OF KENTUCKY" on Justia Law

A police officer observed an individual walking in the middle of a street at night near a location known for drug activity. The officer, believing this to be a violation of Kentucky’s jaywalking statute, attempted to stop the individual by asking him to approach the patrol car. The individual ignored the officer’s verbal commands, turned away, and increased his pace. The officer then physically seized the individual by grabbing his arms and escorted him back to the patrol car. During this process, the officer observed the individual discard drugs, which led to his arrest. Additional drugs were found in the individual’s possession after the arrest.The Nelson Circuit Court held a suppression hearing, during which the officer and the defendant’s mother testified. The court found that the officer had probable cause to believe a jaywalking violation had occurred and concluded that the officer’s actions were justified. The court denied the motion to suppress the drug evidence. The defendant subsequently entered a conditional guilty plea to amended charges, reserving the right to appeal the suppression ruling. The Kentucky Court of Appeals affirmed the circuit court’s decision, reasoning that an officer may detain a pedestrian for a traffic law violation to issue a citation, and distinguished the case from prior precedent involving different circumstances.The Supreme Court of Kentucky reviewed the case and affirmed the lower courts’ decisions. The court held that the Fourth Amendment is not violated when police physically seize a person for an observed violation, such as jaywalking, for the purpose of issuing a citation if the person fails to comply with verbal commands. The court found the officer’s use of minimal force to be objectively reasonable under the circumstances and concluded that the subsequent discovery of contraband was not the result of an unreasonable search or seizure. The denial of the motion to suppress and the convictions were affirmed. View "BUECHELE V. COMMONWEALTH OF KENTUCKY" on Justia Law

The case concerns Isaiah Brown, who, along with Rayshawn Tucker and Fatima Alabusalim, was implicated in the murder and first-degree robbery of DaMani Dulaney in Louisville, Kentucky. Alabusalim, who had relationships with both Tucker and Dulaney, testified that Tucker was upset about her relationship with Dulaney and devised a plan to rob him, enlisting her and Brown’s help. On the night of the incident, Alabusalim lured Dulaney to a park, where Tucker and Brown confronted him. Brown broke the driver’s side window with a gun, and after Alabusalim was pulled from the car, a single gunshot was fired, resulting in Dulaney’s death. The trio fled to Florida after the crime. Evidence included text messages, cell site data, and testimony from Alabusalim, who initially gave false statements to police but later admitted her involvement.The Jefferson Circuit Court tried Brown alone after his co-defendants entered plea agreements. The jury found Brown guilty of murder (complicity) and first-degree robbery (complicity), recommending concurrent sentences of twenty-two years for murder and ten years for robbery. The court sentenced Brown accordingly. Brown appealed, raising issues about the admission of certain evidence, including hearsay regarding phone number attribution, the foundation for text messages, improper opinion testimony by a detective, the admission of co-conspirator statements, and cumulative error.The Supreme Court of Kentucky reviewed the case and affirmed the convictions. The court held that while the trial court erred in admitting hearsay evidence identifying Brown’s phone number and in allowing improper opinion testimony about a witness’s credibility, these errors were harmless or did not result in manifest injustice. The court found that the text messages were properly authenticated and that the co-conspirator exception to the hearsay rule was satisfied. The cumulative effect of the errors did not render the trial fundamentally unfair. View "BROWN V. COMMONWEALTH OF KENTUCKY" on Justia Law

Darrell Strunk participated in two robberies on the same day in December 2011: first, a home invasion, and then a business robbery. He was indicted for the business robbery, and later, with his consent, additional charges from the home robbery were added. Strunk entered a plea agreement, pleading guilty to two counts of second-degree robbery, each enhanced by his status as a second-degree persistent felony offender. The agreement called for consecutive sentences of 20 years and 10 years, totaling 30 years’ imprisonment.The Fayette Circuit Court accepted the plea and imposed the 30-year sentence, despite Strunk’s counsel raising concerns that this exceeded the statutory maximum under KRS 532.110(1)(c), which limits the aggregate sentence for Class C felonies to 20 years. Strunk later filed a motion under CR 60.02 to correct his sentence, arguing it was illegal. The trial court denied the motion, reasoning that the plea agreement treated the two robberies as separate cases and that Strunk had knowingly accepted the deal. On appeal, the Kentucky Court of Appeals reversed, holding that the 30-year sentence violated the statutory cap and that the statutory limit could not be waived, remanding for resentencing within the legal maximum.The Supreme Court of Kentucky reviewed the case and affirmed the Court of Appeals. The Court held that Strunk’s aggregate sentence of 30 years was illegal under KRS 532.110(1)(c), as the statutory maximum for his offenses was 20 years. The Court further held that, because Strunk sought only correction of his sentence and not withdrawal of his guilty plea, the proper remedy was to remand for resentencing with instructions to impose the highest legal sentence—20 years’ imprisonment. View "COMMONWEALTH OF KENTUCKY V. STRUNK" on Justia Law

On the night of June 23, 2019, a group of minors, including the defendant, traveled around Louisville discussing a planned burglary. Later that evening, two minors, J.M. and R.O., were shot and killed, while a third, S.H., survived her wounds. S.H. testified that the defendant shot her and R.O. after the group had driven to various locations and after an incident involving J.M. in an alley. The defendant was indicted for the murders of J.M. and R.O. and for the first-degree assault of S.H. He did not testify at trial.The Jefferson Circuit Court conducted a jury trial in which the defendant was convicted of the murder of R.O. and the first-degree assault of S.H., but acquitted of the murder of J.M. The jury recommended a life sentence for the murder conviction and a consecutive twenty-year sentence for the assault conviction, which the trial court reduced to life in prison. The defendant appealed, raising several claims, including challenges to the admission of cell phone location evidence, the handling of prospective and seated jurors, and the admission of a recorded jail call.The Supreme Court of Kentucky reviewed the case as a matter of right. The Court held that the trial court did not err in permitting a detective to testify about cell phone location data, finding that the detective’s testimony, though based on specialized training, was sufficiently disclosed and did not require exclusion or a Daubert hearing since the defense did not challenge the methodology’s reliability. The Court also found no abuse of discretion in the trial court’s decisions regarding juror challenges and the admission of the jail call, concluding that there was no evidence of juror bias or prejudice and that the recorded call was properly admitted for the jury’s consideration. The Supreme Court of Kentucky affirmed the convictions and sentence. View "HOLLINGSWORTH V. COMMONWEALTH OF KENTUCKY" on Justia Law