Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court affirmed the order of the trial court denying Defendant's motion for DNA testing with respect to hair found at the residence of the victims whom Defendant was convicted of murdering, burglarizing, and robbing, holding that the trial court did not err.Defendant was convicted of murder and sentenced to death. This appeal concerned Defendant's motion seeking DNA testing of hair that was found in the victims' home. The trial court denied the motion. The Supreme Court affirmed after noting that Defendant's DNA arguments have been raised and rejected by both the Supreme Court and the federal courts, holding that no reasonable probability existed that the DNA testing and analysis would produce exculpatory evidence. View "Hodge v. Commonwealth" on Justia Law

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 judgment of the circuit court convicting Defendant of wanton murder and four counts of first-degree wanton endangerment, holding that the trial court did not err in denying Defendant's motion for a directed verdict.On appeal, Defendant argued that the trial court erroneously denied his motions for a directed verdict on the wanton murder and wanton endangerment charges because the evidence was insufficient to establish "aggravated wantonness" and to prove that his conduct caused the victim's death. The Supreme Court affirmed, holding that the Commonwealth met its burden of persuasion, and therefore, the trial court did not err by denying Defendant's motion for a directed verdict of acquittal on the charges. View "Taylor v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the circuit court's denial of Appellant's petition to declare his violent offender classification unconstitutional, holding that a defendant convicted of robbery in the first degree qualifies as a violent offender pursuant to Ky. Rev. Stat. 439.3401(1) regardless of whether the victim suffered serious physical injury or death and regardless of whether the trial court's judgment addresses the victim's status.Appellant was convicted of twelve counts of first-degree robbery and was classified as a violent offender. The circuit court did not state in its judgment that any of Appellant's victims suffered serious physical injury or death. Appellant filed a petition seeking to declare her violent offender classification unconstitutional. The lower courts denied the petition. The Supreme Court affirmed, holding (1) Benet v. Commonwealth, 253 S.W.3d 528 (Ky. 2008) correctly interprets the requirements of section 439.3401(1) for violent offender status; and (2) the portion of Pate v. Department of Corrections, 466 S.W.3d 480 (Ky. 2015), that is inconsistent with Benet is overruled. View "Lee v. Kentucky Department of Corrections" on Justia Law

The Supreme Court reversed Defendant's conviction of second-degree manslaughter by complicity, holding that the trial court committed reversible error when it allowed the Commonwealth to present a thirty-five-minute video of a police interview with Defendant in which Defendant was shown handcuffed and wearing an inmate's orange jumpsuit.After Defendant was arrested, an Assistant Commonwealth's Attorney and the lead homicide detective met Defendant and his attorney at the jail. They recorded their questioning of him, and throughout the interview, Defendant was handcuffed and wore an orange jumpsuit. During trial, the court allowed the Commonwealth to display the video version of the recording to the jury. The court of appeals affirmed Defendant's conviction, concluding that any error in admitting the video was harmless. The Supreme Court reversed, holding that, while the video was not "inherently prejudicial," the video prejudiced Defendant, and the Commonwealth did not satisfy its burden of demonstrating beyond a reasonable doubt that the video did not impact the verdict. View "Deal v. Commonwealth" 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 affirmed the judgment of the circuit court convicting Defendant of attempted murder and theft by unlawful taking of a firearm, holding that the trial court did not err in instructing the jury and denying Defendant's motion for directed verdict.A jury found Defendant guilty of attempted murder and theft by unlawful taking of a firearm. Consistent with the jury's recommendation, the trial court sentenced Defendant to a total sentence of twenty years. The Supreme Court affirmed, holding (1) the trial court did not err by declining Defendant's request for a renunciation instruction; and (2) the trial court did not err by denying Defendant's motion for directed verdict on the charge of theft by unlawful taking of a firearm. View "Bowen v. Commonwealth" 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 vacated the judgment of the circuit court sentencing Defendant to life in prison plus fifty years, holding that the violent offender statute is not applicable to youthful offenders for purposes of consideration of probation, even if they are sentenced after they have reached the age of majority.Defendant committed the crimes for which he was convicted when he was seventeen years old. The district court transferred the charges to circuit court for Defendant's prosecution as a youthful offender. Defendant was nineteen years old when he pleaded guilty pursuant to plea agreements to murder, first-degree robbery, and other crimes. Under the assumption that Defendant was ineligible for probation, the trial court imposed a life sentence with a fifty-year sentence to run consecutively. The Supreme Court vacated the judgment, holding (1) Kentucky's Juvenile Code and relevant caselaw support the conclusion that the violent offender statute is not applicable to youthful offenders for purposes of consideration of probation, even if they are sentenced after they reach the age of eighteen years and five months; and (2) the trial court erred in failing to consider probation or other forms of conditional discharge as possible alternatives. View "Thomas v. Commonwealth" 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