Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court upheld Defendant’s convictions for three counts of wanton endangerment in the first degree, holding that an instructional error did not require vacating Defendant’s convictions.The Court of Appeals reversed and vacated Defendant’s convictions, ruling, sua sponte, that the jury instructions required proof of an additional element in order to find Defendant guilty of wanton endangerment, first-degree, and that the error was not harmless. The Supreme Court disagreed and reinstated the judgment of the trial court, holding that the instructional error was harmless. Given that the Commonwealth proved its case to the jury with an additional element to prove, there was no reasonable probability that omitting this added element would change the jury’s verdict. View "Commonwealth v. Caudill" on Justia Law

In this appeal from a criminal conviction, the Supreme Court vacated the portion of the circuit court’s judgment imposing criminal restitution and otherwise affirmed the judgment of conviction and sentence. Defendant was convicted of second-degree manslaughter and of being a first-degree persistent felony offender (PFO). The Supreme Court affirmed in part and vacated in part the judgment, holding (1) the trial court erred when it ordered Defendant to pay criminal restitution because the court did not comply with the procedural due process requirements for imposing restitution as outlined in Jones v. Commonwealth, 382 S.W.3d 22 (Ky. 2011), and therefore, the criminal restitution award must be vacated and remanded for a new hearing; (2) the trial court did not err in allowing evidence that Defendant cut off his ankle monitor while on probation because evidence of probation violations, like evidence of parole violations, can be admissible evidence in the penalty phase of a criminal trial; and (3) the trial court did not err when it allowed the use of Defendant’s prior conviction for drug possession as a qualifier for PFO enhancement. View "Brown v. Commonwealth" on Justia Law

The Supreme Court held that the denial of Defendant’s motion to suppress evidence seized from her vehicle during a traffic stop was proper.In her suppression motion, Defendant argued that the traffic stop of her vehicle was not justified because she was not required to have her license plate illuminated when Sergeant James Jenkins pulled her over. The Commonwealth acknowledged that a license plate violation may not have been a proper basis for the stop but that Detective Wade Shoemaker had reasonable suspicion of Defendant’s participation in controlled drug buys, and Det. Shoemaker’s reasonable suspicion to stop Defendant’s vehicle transferred to Sgt. Jenkins so as to justify the traffic stop. The trial court concluded that no traffic violation occurred but that law enforcement had reasonable suspicion to pull over Defendant’s vehicle. The Court of Appeals reversed, concluding that because Sgt. Jenkins did not actually rely on Det. Shoemaker’s information and instead made the stop based solely on the license plate violation, the collective knowledge doctrine was irrelevant. The Supreme Court reversed, holding that the record reflected that the real reason Sgt. Jenkins pulled over Defendant’s vehicle was upon Det. Shoemaker’s request, and because Det. Shoemaker had reasonable suspicion to make the investigatory stop, suppression of the evidence was not required. View "Commonwealth v. Blake" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court convicting Defendant of incest, first-degree unlawful transaction with a minor, use of a minor in a sexual performance, first-degree unlawful imprisonment, and first-degree sexual abuse. The trial court sentenced Defendant to seventy years’ imprisonment. In reversing in part, the Supreme Court held that Defendant’s convictions of incest, use of a minor in a sexual performance, and unlawful imprisonment were reasonably likely a result of prosecutorial vindictiveness. The court otherwise affirmed, holding that the trial court (1) did not err in overruling Defendant’s motion to dismiss his indictment due to prosecutorial vindictiveness; (2) did not err by not granting a directed verdict on the charge of unlawful transaction with a minor; (3) did not permit double jeopardy violations; and (4) erred by permitting the victim’s mother to improperly vouch for the victim’s credibility, but the error was harmless. View "Yates v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Appellant of murder, criminal attempt to commit murder, and related crimes. The Supreme Court held that the trial court (1) did not err by denying Appellant’s request to introduce parole eligibility information during the death penalty phase of the trial; (2) did not err by permitting the Commonwealth to introduce during the guilt phase evidence of other crimes committed by Appellant against the victim’s family; and (3) did not err by allowing the testimony of a witness who was three years old at the time of the crimes and six years old at the time of the trial. View "Huddleston v. Commonwealth" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress the evidence obtained during a traffic stop, holding that the law enforcement officer did not violate Defendant’s right to privacy when he reviewed Defendant’s license and registration information.The officer’s police car in this case was equipped with a camera that could read license plates in order to provide information about the vehicle’s registered owner. The record check performed by the camera indicated that Defendant had an active warrant for failing to appear in court. The officer pulled Defendant’s vehicle over and, after noticing several signs that Defendant was intoxicated, arrested Defendant for, inter alia, driving under the influence. The district court denied Defendant’s motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant’s rights under the Fourth Amendment were not violated by the officer obtaining information linked to Defendant’s license plate, which was displayed in a place where Defendant had no reasonable expectation of privacy; and (2) the officer had the articulable and reasonable suspicion required to stop the vehicle. View "Traft v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to life imprisonment for murder, first-degree assault, and other crimes and sentencing Defendant to life imprisonment for murder. The court held (1) the trial court did not abuse its discretion in denying Defendant’s motion for change of venue; (2) the trial court did not abuse its discretion in denying Defendant’s motion to exclude an incriminating statement Defendant made to a witness; (3) the trial court did not abuse its discretion in denying Defendant’s motions for a continuance; (4) the trial court did not abuse its discretion by refusing Defendant’s motion to excuse jurors for cause; (5) the trial court did not abuse its discretion in denying Defendant’s request for a mistrial; and (6) the trial court erred in permitting testimony about what would constitute an appropriate sentence for Defendant, but the error was harmless. View "Hilton v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree trafficking in a controlled substance over two grams and of being a first-degree persistent felony offender and sentencing Defendant to twenty years’ imprisonment. The court held (1) Defendant was not denied a fair trial by the trial court’s admission of testimony from a detective; (2) Defendant was not entitled to a mistrial because of alleged errors in the sentencing phase of the trial proceeding; (3) there was no palpable error with the sentencing evidence; and (4) contrary to Defendant’s argument on appeal, the jury finding that Defendant was a persistent felony offender first-degree was unanimous. View "Conrad v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of first-degree assault, eleven counts of first-degree criminal abuse, and one count of second-degree assault and sentencing Defendant to seventy years’ imprisonment. The convictions stemmed from the abuse of Defendant’s boyfriend’s minor child, N.V. After Defendant and her boyfriend were arrested, N.V. was released to foster care. On appeal, Defendant argued that the trial court erred in allowing the testimony of the foster mother. The Supreme Court disagreed, holding that the trial court did not err in allowing the testimony of the foster mother. View "Richmond v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of three counts of violating a protective order, kidnapping, two counts of first-degree unlawful imprisonment and other offenses. On appeal, Defendant argued that the trial court erred by admitting improper character evidence and by failing to grant a directed verdict on the two counts of first-degree unlawful imprisonment. The Supreme Court held (1) evidence of Defendant’s “other crimes, wrongs, or acts” was properly admitted; and (2) this court declines to grant palpable error review of Defendant’s claim that he was entitled to a directed verdict on first-degree unlawful imprisonment. View "Gray v. Commonwealth" on Justia Law