Justia Kentucky Supreme Court Opinion Summaries

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

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

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

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

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

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

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

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