Justia Kentucky Supreme Court Opinion Summaries
Articles Posted in Criminal Law
Phon v. Commonwealth
Life without parole (LWOP) for juveniles does not always offend the federal or Kentucky Constitutions, so long as it comports with a discretionary scheme and the defendant has a meaningful opportunity for the jury to consider mitigating evidence.Appellant was under the age of eighteen when he participated in the murder of two people and the deadly assault of a twelve-year-old girl. The circuit court sentenced Appellant to LWOP. In this appeal from the denial of relief on Appellant’s third Ky. R. Criminal. P. 11.42 motion and his second Ky. R. Civ. P. 60.02 motion, the Supreme Court held (1) Appellant’s sentencing was constitutionally permissible; but (2) under this Court’s more recent rulings regarding penalties allowable under the juvenile code, Appellant’s sentence was statutorily prohibited. Consequently, the Court remanded this case for the trial court to impose the lawful sentence of LWOP for twenty-five years. View "Phon v. Commonwealth" on Justia Law
Posted in:
Criminal Law, Juvenile Law
Turner v. Commonwealth
The Supreme Court affirmed the judgment of the circuit court sentencing Appellant to thirty years’ imprisonment for murder and for being a first-degree persistent felony offender. The Court held that the trial court (1) did not err by permitting the Commonwealth to elicit testimony from the coroner about the victim’s estimated time of death; (2) did not err by denying Appellant’s motion to continue the trial; (3) did not err by disqualifying one of Appellant’s attorneys; (4) erred by admitting evidence about the victim’s state of mind prior to his murder, but the error was harmless; and (5) did not err by instructing the jury as to self-defense and extreme emotional disturbance. View "Turner v. Commonwealth" on Justia Law
Posted in:
Criminal Law
White v. Commonwealth
The Supreme Court affirmed the judgment of the circuit court convicting Defendant of raping and murdering Pamela Armstrong and sentencing Defendant to death. The Court held (1) the trial court did not commit reversible error when it allowed the Commonwealth to admit other bad acts evidence of Appellant as addressed by Ky. R. Evid. 404(b); (2) the trial court’s failure to define the terms “modus operandi” and “identity evidence” in the jury instructions did not violate Appellant’s due process rights; (3) there was no reversible error in the trial court’s refusal to suppress Defendant’s DNA sample; (4) there was no error in the trial judge’s refusal to disqualify himself from presiding over Appellant’s trial; (5) Appellant was not entitled to a new trial on the grounds that the trial court improperly admitted unreliable evidence; (6) any alleged prosecutorial misconduct did not require reversal; and (7) Appellant was not entitled to relief on his remaining claims of error. View "White v. Commonwealth" on Justia Law
Maupin v. Commonwealth
Section 115 of the Kentucky Constitution bars the Commonwealth from appealing a judgment of acquittal in a criminal case.Here, the Commonwealth appealed Defendant’s judgment of acquittal on the charge of failing to register a change of address with the Sex Offender Registry. The Commonwealth argued that its appeal was not barred by section 115 because Defendant’s judgment of acquittal was based not on the jury’s verdict but on the trial court’s issuance of a judgment of acquittal. The court of appeals allowed the appeal to proceed and reversed the trial court’s judgment of acquittal. The Supreme Court reversed, holding that section 115 prevents the Commonwealth from appealing a judgment of acquittal. The Court overruled any precedent stating that section 115 derives itself from section 13 of the Kentucky Constitution and that the Commonwealth may appeal a judgment non-obstante verdicto (n.o.v.). View "Maupin v. Commonwealth" on Justia Law
Posted in:
Constitutional Law, Criminal Law
Commonwealth v. Helm
The court of appeals misapplied the ineffective-assistance-of-counsel standard by failing to consider the totality of the circumstances of Defendant’s case from the perspective of an objectively reasonable trial attorney.The court of appeals reversed the trial court’s denial of Defendant’s Ky. R. Crim. P. 11.42 post-conviction motion for a new sentencing-phase trial based upon ineffective assistance of trial counsel. The court of appeals ruled that trial counsel provided ineffective assistance by advising Defendant to enter into a sentencing agreement with the Commonwealth to waive jury sentencing and accept a plea agreement under which he was sentenced to the maximum penalty to avoid potential risks to his parole eligibility and meritorious credit against his sentence. The Supreme Court reversed, holding that the court of appeals placed too much emphasis on Defendant’s agreeing to the maximum penalty. As to Defendant’s argument that the trial court erred by denying his motion for relief for ineffective assistance of appellate counsel, the argument was without merit. View "Commonwealth v. Helm" on Justia Law
Commonwealth v. Muchrison
In this case involving an alleged denial of Defendant’s Sixth Amendment right to conflict-free counsel, the Supreme Court held that the trial court correctly denied trial counsel’s motion to withdraw because, under the totality of the circumstances, Defendant failed to demonstrate that his lawyer was burdened by an actual conflict of interest during his representation of Defendant.Defendant was convicted of first-degree trafficking in a controlled substance and of being a first-degree persistent felony offender. Once Defendant’s attorney discovered that he had a potential conflict, he filed a motion to withdraw as Defendant’s attorney. The trial court denied the motion. The court of appeals ruled that the trial court erred by failing to grant counsel’s motion to withdraw and reversed Defendant’s conviction and sentence. The Supreme Court reversed the court of appeals and reinstated Defendant’s conviction and sentence, holding that Defendant was not denied his constitutional right to conflict-free counsel. View "Commonwealth v. Muchrison" on Justia Law
Hall v. Commonwealth
The Supreme Court reversed in part the final judgment of the trial court convicting Defendant of three misdemeanors and four felonies and sentencing Defendant to a sentence totaling twenty years’ imprisonment and imposing $50 in fines together with court costs and court facility fees. The Court held (1) the trial court erred by imposing a $50 fine but not by imposing court costs, court facilities fee, and bond; (2) the trial court erred when it denied Defendant’s motion for directed verdict on the charge of first-degree theft by unlawful taking, over $500 but less than $10,000; (3) the jury instructions relating to Defendant’s charge of resisting arrest were erroneous, and the only remedy is to reverse the judgment on this charge and remand for further proceedings; and (4) the remainder of the judgment was not in error. View "Hall v. Commonwealth" on Justia Law
Posted in:
Criminal Law
Commonwealth v. Smith
The Supreme Court affirmed the decision of the court of appeals upholding the trial court’s suppression of evidence discovered as a result of a canine sniff search of Defendant’s vehicle during a traffic stop. The Court held that the court of appeals did not err by concluding (1) the stop of Defendant’s vehicle was proper, but the sniff search improperly extended the traffic stop; (2) the traffic stop was the only legal justification for stopping Defendant; and (3) the Commonwealth failed to preserve for appellate review its claim that Defendant’s parole status subjected him to a warrantless and suspicionless search and seizure. View "Commonwealth v. Smith" on Justia Law
Shively v. Commonwealth
The Supreme Court affirmed the judgment of the trial court convicting Defendant of criminal attempt to commit murder, possession of a handgun by a convicted felon, and tampering with physical evidence and sentencing him to twenty years’ imprisonment. The Court held (1) the trial court did not err in denying Defendant’s motion to suppress his statement to police; (2) the trial court did not err in refusing to allow certain cross-examination of the victim; (3) the trial court did not err in denying Appellant’s motion for a mistrial; and (4) the jury instructions on the possession of a handgun by a convicted felon charge did not deprive Appellant of his right to a unanimous verdict. View "Shively v. Commonwealth" on Justia Law
Commonwealth v. Patton
The Supreme Court reversed the decision of the Court of Appeals reversing Defendant’s sentence and conviction and remanding for a new trial, having determined that Defendant’s guilty plea did not satisfy Boykin v. Alabama, 395 U.S. 238 (1969).A jury convicted Defendant of first-degree rape and third-degree unlawful transaction with a minor. After a Boykin colloquy, Defendant subsequently entered a guilty plea in exchange for a seventeen-year prison sentence. The Court of Appeals reversed, concluding that Defendant’s guilty plea did not satisfy Boykin. The Supreme Court reversed the decision of the Court of Appeals and reinstated Defendant’s conviction and sentencing, holding that, based on the totality of the circumstances, Defendant’s guilty plea was made knowingly, voluntarily, and intelligently. View "Commonwealth v. Patton" on Justia Law
Posted in:
Criminal Law