Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of murder and tampering with physical evidence and sentencing him to forty-three years' imprisonment, holding that the trial court erred in admitting two items of tangible evidence but that this error was not enough to warrant reversal.Specifically, the Supreme Court held (1) the trial court did not err in admitting evidence of Defendant's time fraud as motivation to murder; (2) admitting into evidence a red knife and latex gloves found in Defendant's truck was error, but those errors were harmless; (3) the trial court did not commit reversible error by denying a missing-evidence instruction; and (4) Defendant was not entitled to a new trial for cumulative error. View "Dooley v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, first-degree assault, and first-degree wanton endangerment of a child, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion in denying requested instructions on extreme emotional disturbance and voluntary intoxication; (2) the prosecutor did not improperly reenact Defendant's theory of the shooting during the direct examination of the medical examiner; and (3) the trial court properly applied the law in denying Defendant's motion to suppress. View "Hargroves v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of four counts of first-degree assault and other crimes and sentencing him as a first-degree persistent felony offender (PFO) to forty years' imprisonment, holding that any error was harmless.Specifically, the Supreme Court held that the trial court (1) did not err when it allowed into evidence a Facebook video from an anonymous tipster allegedly depicting the shooting; (2) did not commit palpable error when it allowed the testimony of Detective O'Daniel, who narrated surveillance video footage; (3) properly allowed Aleisha Courtney's prior identification of Defendant; (4) properly allowed another detective's prior identification of Defendant; (5) improperly excluded evidence of a civil suit by the victims against Defendant, but the error did not likely affect the outcome of the trial; (6) properly allowed Defendant's prior felony convictions at trial and at sentencing; and (7) properly allowed a summary sheet of Defendant's prior convictions that was prepared with certified records. Further, there was sufficient evidence of Defendant's prior felony convictions to support his conviction for possession of a handgun. View "Mattingly v. Commonwealth" on Justia Law

The Supreme Court reversed Defendant's conviction of first-degree and second-degree arson and six counts of attempted murder, of which four were charged as hate crimes, holding that Defendant was denied a fair trial when the Commonwealth, aware of Defendant's intoxication during her arrest, opposed the intoxication defense instructions and implied to the jury that Defendant was not intoxicated.On appeal, Defendant argued that six trial errors required reversal, either individually or cumulatively. The Supreme Court held that the prosecutorial misconduct was flagrant enough to render the trial fundamentally unfair, simultaneously leading the jury to conclude facts contrary to the known facts and depriving Defendant of an ability to present her defense. The Court held that this one error was enough to require reversal but also addressed Defendant's remaining allegations of error, concluding that there were multiple errors in this case. View "Brafman v. Commonwealth" on Justia Law

The Supreme Court reversed the opinion of the court of appeals vacating and remanding the circuit court's denial of Defendant's motion to modify the terms of his probation to remove a restriction prohibiting him from having access to the internet during his probationary period, holding that Defendant's failure to challenge the probation restriction prohibiting all access to the internet at the time the restriction was imposed was fatal to Defendant's request to relief.In vacating the probation restriction, the court of appeals concluded that the complete ban on internet access under the facts of this case was impermissibly vague and overly burdensome on Defendant's right to free speech. The Supreme Court reversed, holding that because Defendant did not object to the restriction, the court of appeals should not have entertained this challenge, and its decision on the merits was in error. View "Commonwealth v. Jennings" on Justia Law

The Supreme Court affirmed Defendant's sentence of twenty years' imprisonment and convictions of not guilty by reason of insanity for first-degree murder, not guilty by reason of insanity for first-degree burglary, guilty but mentally ill of two counts of second-degree assault and guilty but mentally ill of fourth-degree assault, holding that any error was not prejudicial.Specifically, the Supreme Court held (1) the jury’s verdicts were not impermissibly inconsistent; (2) the trial court did not err by failing to grant Defendant's motions for directed verdict; (3) the trial court did not abuse its discretion by failing to provide lesser-included offense instructions to the jury; (4) the trial court's failure to provide the jury with the definition of "dangerous instrument" was harmless error; (5) the trial court did not abuse its discretion by denying Defendant's motion to strike two jurors for cause; and (6) the trial court erred by not making the requisite statutory findings under Ky. Rev. Stat. 703 before admitting prior bad act evidence, but the error was harmless. View "Exantus v. Commonwealth" on Justia Law

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

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's drug-related convictions, holding that the circuit court did not err in denying Defendant's motion to suppress.After he was arrested and indicted, Defendant moved to suppress the evidence seized during a traffic stop, arguing that the law enforcement officer impermissibly prolonged the stop to facilitate a dog sniff search. The trial court denied the request. The court of appeals affirmed. The Supreme Court affirmed, holding that the actions taken to facilitate the arrest of Defendant's passenger did not impermissibly extend his traffic stop, and therefore, the trial court correctly denied Defendant's motion to suppress the evidence resulting from the subsequent use of the narcotics dog. View "Rhoton v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the ruling of the trial court denying Defendant's motion to classify him as a domestic violence victim pursuant to Ky. Rev. Stat. 439.3401(5), holding that the evidence was sufficient to satisfy Defendant's burden of proving by a preponderance of the evidence that he was a victim of domestic violence.Defendant pleaded guilty to manslaughter in the first degree for the death of his wife. Defendant moved the trial court to classify him as a domestic violence victim, which would reduce his parole eligibility from eighty-five percent of his sentence to twenty percent of his sentence. The trial court denied the motion, but the court of appeals reversed, concluding that Defendant successfully connected the physical and verbal domestic violence he experienced to the crime he committed. The Supreme Court affirmed, holding that Defendant proved that he was a victim of domestic violence in regard to the manslaughter of his wife. View "Commonwealth v. Crowe" on Justia Law

The Supreme Court affirmed Defendant's conviction and sixty-five-year sentence for attempted murder, first-degree robbery, and other crimes, holding that the trial court did to err by denying two of Defendant's directed verdict motions and that there was no error in Defendant's sentencing phase.On appeal, Defendant argued that the trial court committed reversible error when it denied his directed verdict motions for first-degree robbery and first-degree wanton endangerment and that his sentencing phase was unfairly tainted by incorrect information regarding parole eligibility. The Supreme Court affirmed, holding (1) this Court overrules precedent requiring defendants to comply with the "second rule" of preservation; (2) in order to preserve an alleged directed verdict issue for appeal, criminal defendants must move for a directed verdict at the close of the Commonwealth's evidence and renew the directed verdict motion at the close of all evidence; (3) the trial court did not err by denying Defendant's motions for directed verdict; (4) even though testimony by the Commonwealth's sole witness in the sentencing phase regarding first-degree wanton endangerment was clearly false, the error was not palpable; and (5) the Commonwealth's misstatement of parole eligibility during its closing argument did not constitute manifest injustice resulting in palpable error. View "Ray v. Commonwealth" on Justia Law