Justia Kentucky Supreme Court Opinion Summaries

In these consolidated appeals, the Supreme Court affirmed the convictions of Lonnie Conyers, Roy Tucker, and Joseph Hardy. Defendants were all found guilty of two counts of first-degree burglary following a joint jury trial. Each defendant was sentenced as a first-degree persistent felony offender (PFO) to concurrent, twenty-year terms of imprisonment. In affirming, the Supreme Court held (1) juror and witness misconduct did not necessitate a mistrial; (2) the trial court did not err by refusing to dismiss the first-degree burglary charges and by failing to give a jury instruction on receiving stolen property as a lesser, alternative offense to burglary; (3) Hardy was not entitled to a jury instruction on the defense of voluntary intoxication; and (4) the trial court did not err during the PFO proceedings by refusing to exclude evidence of one of Conyers’s prior felonies. View "Conyers v. Commonwealth" on Justia Law

The Supreme Court reversed the circuit court’s judgment convicting Appellant of first-degree sexual abuse and sentencing him to six years’ imprisonment. On appeal, Appellant argued that he was denied a fair and impartial jury due to the jury foreman being the brother-in-law of an assistant Commonwealth attorney. At issue before the Supreme Court was the trial court and Court of Appeals’ faulty conclusion that the jury foreman - and other panelists - disclosed a relationship with the assistant Commonwealth attorney. The Supreme Court concluded (1) the actions of the trial judge and defense counsel undermine the conclusion that defense counsel was made aware that the foreman had a relationship with the attorney; and (2) because Appellant never had the opportunity to challenge the assistant Commonwealth attorney’s presence on the jury, he was entitled to a new trial. View "Edmondson v. Kentucky" on Justia Law

Jeffrey Dewayne Clark and Garr Keith Hardin (collectively, Appellees) were convicted of the 1992 murder of a young woman. In 2009, the Innocence Project, Inc. and the Department of Public Advocacy Kentucky Innocence Project agreed to represent Appellees to secure DNA testing of evidence found on the victim. The trial court denied Appellees’ motion for release of the evidence for DNA analysis. The Supreme Court reversed, ruling that Appellees were entitled to the testing. On remand, the circuit court granted Appellees’ motion, vacated Appellees’ convictions due to newly discovered evidence, and ordered a new trial. The Supreme Court affirmed, holding that, considering the new evidence at issue, the trial court did not abuse its discretion in vacating Appellees’ convictions and in granting a new trial. View "Commonwealth v. Clark" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to twenty years’ imprisonment for murder and tampering with physical evidence. The court held (1) the trial court did not abuse its discretion by permitting the introduction of expert testimony regarding historical data analysis of cell phone and cell tower records; (2) the trial court’s admission of a detective’s statement regarding Defendant’s credibility was harmless error; (3) the trial court did not abuse its discretion in admitting photographs of the victim’s body; (4) Defendant’s incriminating pretrial statements were properly admitted; (5) the trial court properly instructed the jury; and (6) the Commonwealth correctly defined reasonable doubt during voir dire. View "Holbrook v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to death for the rape and murder of Pamela Armstrong. On appeal, Defendant raised thirty-three claims of error, the first and most compelling of which is that the trial court committed reversible error when it allowed the Commonwealth to admit other bad acts evidence of Defendant under Ky. R. Evid. 404(b). The Supreme Court held (1) the trial court did not abuse its discretion in allowing evidence of Defendant’s prior murder convictions; and (2) the remainder of Defendant’s allegations of error did not warrant reversal. View "White v. Commonwealth" on Justia Law

In this criminal case, reversible error occurred when the trial court allowed the Commonwealth to introduce sexually explicit social media exchanges Appellant had with other women after the victim’s death, and the erroneous admission of this evidence was not harmless errorAppellant was convicted and sentenced to twenty years’ imprisonment for second-degree manslaughter, tampering with physical evidence, and fraudulent use of a credit card over $500. Appellant appealed, arguing, inter alia, that the trial court erred by allowing into evidence sexually explicit communications Appellant made after the victim’s death. The Supreme Court reversed Appellant’s conviction and remanded the case for a new trial. View "Rucker v. Commonwealth" on Justia Law

Appellant was convicted of kidnapping, first-degree manslaughter, tampering with physical evidence, and theft by unlawful taking. Upon Appellant’s motion for postconviction relief, the trial court set aside Appellant’s kidnapping sentence and granted a new penalty phase trial on that charge. After a retrial, the trial court sentenced Appellant to imprisonment for life, to be served concurrently with the twenty-year sentence for manslaughter. The Supreme Court affirmed, holding that the retrial of the kidnapping penalty phase was not fatally flawed because (1) gruesome details of the condition of the victim’s body were irrelevant and cumulative but did not sway the jury’s sentencing decision; (2) victim impact testimony relating to several victims was proper, and certain improper victim impact testimony was not palpable error; (3) the trial court did not improperly limit Appellant’s presentation of mitigation evidence; and (4) the trial court did not err by permitting the Commonwealth to use guilt-phase physical evidence during its closing argument. View "Gaither v. Commonwealth" on Justia Law

Appellant appealed his conviction for the murder of his brother. The Supreme Court affirmed, holding that the trial court (1) did not abuse its discretion in failing to strike Juror 500 for cause because there was nothing in the record to establish a reasonable ground to doubt the juror’s qualifications; (2) did not abuse its discretion by denying Appellant’s motion to strike Juror 566 for cause because there was no reasonable ground to believe that the Juror could not render a fair and impartial verdict on the evidence; (3) properly determined that the evidence did not support an instruction on reckless homicide; and (4) did not err by permitting the Commonwealth to introduce statements made by the victim in the form of text messages sent in the days and weeks immediately preceding the shooting. View "Sturgeon v. Commonwealth" on Justia Law

Appellant appealed his convictions stemming from three separate robberies committed in downtown Louisville in January 2014. The Supreme Court affirmed, holding (1) the trial court did not err in declining to suppress Appellant’s recorded statements to a detective; (2) the trial court did not abuse its discretion in prohibiting Appellant from introducing evidence about his refusal to sign a Miranda-waiver form without having an attorney present; (3) the admission into evidence of Appellant’s hooded sweatshirt was improper, but any error was harmless and did not require reversal; and (4) the trial court’s denial of Appellant’s motion to sever the charged offenses for separate trials did not result in any actual undue prejudice to Appellant. View "Smith v. Commonwealth" on Justia Law

Appellant entered an Alford plea to one count of murder. Before sentencing, Appellant submitted a motion to withdraw his plea, arguing that his counsel deceived him when she informed him that he could withdraw his plea at any time before sentencing and that his plea was involuntarily entered. After a hearing, the trial court denied the motion. On appeal, Appellant argued that the trial court erred by resolving the plea issue without taking evidence and without appointing conflict-free counsel. The Supreme court vacated the judgment and the order denying Appellant’s motion to withdraw his guilty plea, holding (1) an actual conflict existed in this case, and an evidentiary hearing should have been held at which Appellant’s attorney’s testimony would have been necessary; and (2) the error created a manifest injustice. Remanded to the trial court for further proceedings. View "Zapata v. Commonwealth" on Justia Law