Justia Kentucky Supreme Court Opinion Summaries

Blake Jeffreys was arrested during a sting operation after unknowingly communicating with an undercover police officer and arranging to meet at a hotel for sex in exchange for $120. On May 14, 2021, Jeffreys pled guilty to promoting human trafficking. The Jefferson Circuit Court sentenced him to one year in prison, probated for five years, and ordered him to pay a $10,000 fee under KRS 529.130. Jeffreys requested the trial court waive the payment under KRS 534.030(4), but the court declined. Jeffreys appealed, arguing the fee was an unconstitutional excessive fine and should be waived.The Court of Appeals rejected Jeffreys' arguments and affirmed the trial court's decision. Jeffreys sought discretionary review from the Kentucky Supreme Court, focusing solely on the argument that the fee should be waived. The Kentucky Supreme Court granted the motion for review.The Kentucky Supreme Court affirmed the Court of Appeals' decision. The court held that KRS 529.130 imposes a human trafficking victims service fee, not a fine, and is not subject to waiver under KRS 534.030(4). The court also found that KRS 453.190, which defines a "poor person" for the purpose of waiving court costs, does not apply to the fee imposed under KRS 529.130. However, the court noted that Jeffreys could seek a show cause hearing under KRS 534.020(3)(a)1 to potentially reduce or waive the payment based on his ability to pay. The court emphasized that the trial court should consider various factors, including the defendant's financial status and dependents, when determining the ability to pay. View "JEFFREYS V. COMMONWEALTH OF KENTUCKY" on Justia Law

Tyler Story was charged with first-offense DUI after being observed driving at high speed with one headlight and failing field sobriety tests. He admitted to drinking and had a breathalyzer result of 0.178. Story requested an independent blood test, which was drawn but not tested immediately. The sample was stored by the police. Story was charged and sought to preserve the sample for independent testing. The District Court suppressed the breathalyzer results due to an error in administration, leaving the Commonwealth without evidence. The Commonwealth obtained a warrant to test the independent blood sample, which Story opposed.The Campbell District Court denied Story's motion to return the blood sample for independent testing, finding he had abandoned it. The Campbell Circuit Court denied Story's petition for a writ of prohibition against the search warrant. The District Court allowed the Commonwealth to test the sample, which showed a blood alcohol level above the legal limit. Story entered a conditional guilty plea and appealed. The Circuit Court and the Court of Appeals affirmed the District Court's decisions, with the Court of Appeals disagreeing on the abandonment but upholding the testing as evidence.The Supreme Court of Kentucky reviewed the case and found that Story's statutory right to an independent blood test was infringed, but the error was harmless since the breathalyzer test was suppressed. However, the Court concluded that the Commonwealth's testing of the blood sample was conducted under an invalid warrant and without Story's consent, violating his Fourth Amendment rights. The Court reversed the District Court's denial of Story's motion to suppress the test results, vacated his conviction, and remanded for further proceedings. View "STORY V. COMMONWEALTH OF KENTUCKY" on Justia Law

James Javonte Crite appealed the Daviess Circuit Court's denial of his motion to suppress evidence obtained during a search of his apartment. Crite was convicted of possession of a firearm by a convicted felon, resulting in a two-year sentence and shock probation. He argued that his landlord had no right to enter his apartment without an emergency and lacked authority to grant police entry, making the search and seizure of the firearm illegal.The Daviess Circuit Court denied Crite's motion to suppress, finding that the landlord had the right to enter the apartment under the "emergency entry" clause of the lease due to significant electrical damage that posed a danger to the tenants. The court also concluded that the police entry was reasonable to ensure the safety of the landlord and the electrician, given the information that Crite was a schizophrenic off his medication, had acted irrationally, and there was a firearm in the apartment.The Kentucky Court of Appeals affirmed the trial court's decision, agreeing that the landlord's entry was justified by the emergency and that the police entry did not violate the Fourth Amendment as they were facilitating the landlord's legitimate interest in addressing the emergency.The Supreme Court of Kentucky reviewed the case and affirmed the lower courts' decisions. The Court held that the landlord's entry was justified under the lease's emergency entry clause due to the electrical damage posing a risk to the tenants. The police entry was deemed reasonable and necessary to ensure the safety of the landlord and the electrician. The Court also held that the seizure of the AR-15 rifle was lawful under the plain view doctrine, as the officers were lawfully present and the incriminating nature of the firearm was immediately apparent. View "CRITE V. COMMONWEALTH OF KENTUCKY" on Justia Law

In the early morning of October 13, 2020, Calvin Taylor was found dead in his home in Hopkinsville, Kentucky, with duct tape on his mouth and arm, and three gunshot wounds. A neighbor, Treesha Shelton, heard gunshots and saw a light-colored vehicle outside Taylor’s home. Surveillance footage showed a silver minivan and a silver Saturn near Taylor’s home around the time of the murder. Larayna Manning and her son, Anthony, were known to frequent Taylor’s home, where Taylor sold crack cocaine. Manning was interviewed by police but provided limited information. A search of a minivan at Manning’s home revealed a large amount of crack cocaine. DNA evidence linked Manning to duct tape found at the crime scene.The Christian Circuit Court convicted Manning of complicity to murder and complicity to first-degree robbery, sentencing her to life imprisonment. Manning appealed, arguing that her right to a speedy trial was violated, that evidence of a prior home invasion was improperly admitted, that the Commonwealth improperly used her son’s Alford plea as substantive evidence of her guilt, and that her right to remain silent was infringed upon.The Supreme Court of Kentucky reviewed the case. It found that the delay in Manning’s trial was largely due to valid reasons, such as the need for DNA evidence, and that her right to a speedy trial was not violated. The court also held that the Commonwealth provided reasonable notice of its intent to introduce prior bad acts evidence and that any error in admitting this evidence was not palpable. The court acknowledged that the Commonwealth improperly used Anthony’s Alford plea as substantive evidence of Manning’s guilt but concluded that this did not result in a substantial possibility of a different outcome. Finally, the court found no improper comment on Manning’s right to remain silent.The Supreme Court of Kentucky affirmed Manning’s convictions and sentence. View "MANNING V. COMMONWEALTH" on Justia Law

The appellant was convicted of murder, abuse of a corpse, and being a first-degree persistent felony offender, resulting in a fifty-year prison sentence. The case involved the death of Amanda Berry, who had moved in with the appellant after meeting him through a pen pal program while she was incarcerated. Amanda struggled with substance use disorder and was living in a dilapidated house with the appellant. Neighbors testified about the couple's tumultuous relationship, frequent arguments, and instances of physical abuse by the appellant. Amanda was last seen in January 2020, and her body was found weeks later in the basement of the house she shared with the appellant.The Jefferson Circuit Court handled the initial trial. The appellant was absent from the trial and sentencing phases, having refused to attend despite being informed of his right to be present and the consequences of his absence. The trial court proceeded in his absence, finding that he had waived his right to be present. The appellant's defense included arguments that there was no direct evidence linking him to the murder and that the body found was not definitively identified as Amanda's. The jury found him guilty, and he was sentenced accordingly.The Supreme Court of Kentucky reviewed the case. The court affirmed the lower court's decision, holding that the appellant had waived his right to be present at trial through his conduct. The court also found no error in the trial court's denial of the appellant's motions for a mistrial and directed verdict, the admission of prior bad acts evidence, and hearsay statements under the state of mind exception. The court concluded that no cumulative error occurred, and the appellant's conviction and sentence were upheld. View "SLOSS V. COMMONWEALTH OF KENTUCKY" on Justia Law

On December 5, 2020, Covington Police Officer Kevin Igo received a letter alleging that Scott Bitter, a convicted felon, was involved in drug trafficking and had assaulted someone. Officer Igo and other officers went to Bitter's residence to investigate. They conducted a "knock and talk" without announcing themselves as police officers. When Bitter's companion, Susan Hornsby, opened the door, Officer Igo observed drug paraphernalia in plain view, including a scale, baggies, and pills. The officers then conducted a protective sweep of the apartment and later obtained a search warrant, which led to the discovery of drugs and a firearm.The Kenton Circuit Court denied Bitter's motion to suppress the evidence, which argued that the initial entry and subsequent search were unconstitutional. The court found that the officers' actions were lawful, as the drug paraphernalia was in plain view and the protective sweep was justified for officer safety. Bitter was convicted by a jury of two counts of trafficking in controlled substances and being a persistent felony offender, and he was sentenced to twenty years in prison.The Supreme Court of Kentucky reviewed the case and affirmed the lower court's decision. The court held that the trial court's findings were supported by substantial evidence and were not clearly erroneous. The court concluded that Officer Igo's observation of the drug paraphernalia from the doorway was lawful and that the protective sweep was reasonable under the circumstances. The search warrant obtained based on these observations was valid, and the evidence collected was admissible. The court affirmed Bitter's conviction and sentence. View "BITTER V. COMMONWEALTH OF KENTUCKY" on Justia Law

Darrie Rushin was indicted on multiple charges, including first-degree burglary and first-degree sodomy. He pled guilty to amended charges and was sentenced to seven years in prison, followed by a five-year period of postincarceration supervision. After completing his initial sentence, Rushin was released but later reincarcerated for violating the terms of his supervision.Rushin requested the Department of Corrections (DOC) to review his sentence calculation, arguing he was wrongfully denied sentence credits that would reduce his reincarceration period. The DOC denied his request, and his subsequent administrative appeal was also denied. Rushin then filed a motion in his underlying criminal case seeking declaratory and injunctive relief. The trial court dismissed his claim on separation-of-powers grounds. On appeal, the Court of Appeals concluded the trial court improperly dismissed the petition but affirmed on other grounds, holding Rushin was not entitled to relief as a matter of law.The Supreme Court of Kentucky reviewed the case and held that inmates reincarcerated for violating postincarceration supervision terms are entitled to earn statutory sentence credits under KRS 197.045 during their reincarceration. The court reasoned that the initial term of imprisonment and the subsequent period of postincarceration supervision are parts of a single sentence. The court emphasized that statutory sentence credits apply to all inmates unless explicitly excluded by statute. Consequently, the decision of the Court of Appeals was reversed. View "RUSHIN V. COMMONWEALTH OF KENTUCKY" on Justia Law

Dennis Keith Sims was convicted by a Casey County jury of two counts of first-degree sexual abuse involving his granddaughters, nine-year-old D.C. and seven-year-old Z.C. The incidents occurred while the girls stayed with Sims during their mother’s illness. Upon their return, D.C. exhibited behavioral changes and later disclosed inappropriate touching by Sims. Both girls provided testimony, with D.C. detailing multiple instances of abuse and Z.C. confirming inappropriate touching.The Casey Circuit Court sentenced Sims to twenty years in prison, following the jury's recommendation. Sims appealed, raising several issues. He argued that the trial court erred by not administering an oath to the prospective jurors before voir dire, violating his Sixth Amendment rights by allowing the girls to testify outside his presence, and admitting late-disclosed evidence. He also contended that the court improperly excluded certain testimony and that there was insufficient evidence to convict him regarding Z.C.The Supreme Court of Kentucky reviewed the case and affirmed the lower court's decisions. The court found no error in the trial court's failure to administer an oath to the venire, as no rule required it. The court also upheld the decision to allow the girls to testify outside Sims’s presence, citing sufficient evidence of their emotional distress. The court ruled that Sims was not deprived of effective counsel despite being separated from his attorney during the girls' testimony, as he had opportunities to consult with his lawyer. The court found no abuse of discretion in admitting the late-disclosed evidence and excluding hearsay testimony. Finally, the court held that there was sufficient evidence to support the conviction related to Z.C., given the testimonies and Sims’s own statements. View "SIMS V. COMMONWEALTH OF KENTUCKY" on Justia Law

The case involves Daquan N. Lampkins, who was convicted of two counts of murder, possession of a handgun by a convicted felon, and violation of a protective order. Lampkins had a tumultuous relationship with Delivia Carron, who he had assaulted multiple times. Carron obtained an emergency protective order against Lampkins, which he violated. On April 13, 2017, Lampkins shot Carron and her new boyfriend, Ricky Jones, resulting in their deaths.The case was tried in the Jefferson Circuit Court, where Lampkins was convicted and sentenced to life imprisonment without the possibility of parole. Lampkins appealed his conviction, arguing that the trial court erred in several ways, including excluding the victims’ toxicology reports, failing to strike two jurors for cause, improperly admitting evidence of prior bad acts, and permitting the Commonwealth to dramatize one of the murders.The Supreme Court of Kentucky reviewed the case and affirmed the lower court's decision. The court found no reversible error in the trial court's decisions. It held that the trial court properly excluded the victims’ toxicology reports, did not err in failing to strike two jurors for cause, and correctly admitted evidence of prior bad acts. The court also found that while the trial court erred in allowing the Commonwealth to dramatize one of the murders, this error was harmless and did not substantially influence the outcome of the case. View "Lampkins v. Commonwealth" on Justia Law

The case involves John Ellis, who was convicted of first-degree rape, second-degree burglary, and kidnapping, and sentenced to fifty years in prison. Ellis appealed his conviction, arguing that the trial court erred in not suppressing his incriminating statements. He claimed that these statements were made during a custodial interrogation without proper Miranda warnings, and that his girlfriend, to whom he made the statements, was acting as an agent of the state.The Simpson Circuit Court had allowed the statements Ellis made to his girlfriend when they were alone, but suppressed those statements made when a police officer was in the room with them. The court held that Ellis' girlfriend was not an agent of the Commonwealth when she was brought into the interview room and allowed to converse with Ellis because there was no agreement between her and the troopers that she would help them.The Supreme Court of Kentucky reversed the lower court's decision, agreeing with Ellis that he was in custody and not properly informed of his rights according to Miranda. The court also held that the police failed to adhere to Ellis' invocation of counsel. The court found that the admission of Ellis' statements was not harmless beyond a reasonable doubt, given the circumstantial nature of the case against him and the lack of physical proof presented at trial. Therefore, the court reversed Ellis' convictions and remanded the case to the Simpson Circuit Court for further proceedings. View "Ellis v. Commonwealth" on Justia Law