Justia Kentucky Supreme Court Opinion Summaries

Appellant was convicted of murder and intimidating a participant in the legal process for shooting and killing Troya Sheckles. Appellant was sentenced to fifty-five years’ imprisonment. The Supreme Court affirmed the murder conviction but reversed the conviction for intimidating a participant in the legal process, holding (1) the evidence of Sheckles’s intentional murder did not support conviction on the intimidation-of-a-witness charge; but (2) Defendant’s argument that delayed disclosures of discovery material by the Commonwealth constituted unconstitutional arbitrary state action warranting dismissal of the charges against him was without merit. View "Pettway v. Commonwealth" on Justia Law

Appellant’s two-year-old son died when she left him in the car overnight and into the afternoon. Appellant was convicted of wanton murder, second-degree criminal abuse, and first-degree wanton endangerment. The Supreme Court vacated Appellant’s conviction for wanton murder, reversed her conviction for first-degree wanton endangerment, and affirmed her conviction for second-degree criminal abuse, holding (1) while Appellant’s conduct historically would have supported a conviction for wanton murder, it cannot support such a conviction now, as the General Assembly, in 2000, amended the homicide statutory scheme to create a new type of second-degree manslaughter applicable to circumstances such as these; and (2) the evidence was insufficient to support a conviction for first-degree wanton endangerment. Remanded for a new trial on the homicide charge, conviction for which is capped at second-degree manslaughter. View "Shouse v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of five counts of trafficking in prescription blanks and being a first-degree persistent felony offender for securing and selling five forged prescriptions for a controlled substance. The Supreme Court affirmed the convictions, holding that the trial court (1) did not err in denying Appellant’s motion for a directed verdict, as the evidence was sufficient to support the convictions; and (2) did not violate the bar on double jeopardy, as the separate trafficking convictions for each forged prescription did not violate Defendant’s double jeopardy rights. View "Early v. Commonwealth" on Justia Law

Defendant was indicted for first-degree possession of a controlled substance. Defendant filed a motion to suppress evidence collected from the search of the bedroom of a residence that police officers entered while executing a valid police warrant. The trial court denied the motion. Defendant subsequently entered a conditional guilty plea to the charge. The Court of Appeals affirmed the denial of Defendant’s motion to suppress. The Supreme Court affirmed, holding (1) police may enter a suspect’s residence with a valid arrest warrant when they have reason to believe that the suspect lives in the residence and can currently be found inside; and (2) the officers in this case did not exceed the scope of a lawful search under Payton v. New York. View "Barrett v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of first-degree stalking, violation of a protective order, and being a first-degree persistent felony offender. Relying upon post-trial comments attributed to jurors implying that the jury had not agreed unanimously on all of the statutory elements of the crime of first-degree stalking, Defendant filed a motion for judgment of acquittal notwithstanding the verdict or a new trial. The trial court denied the motion, and the Court of Appeals affirmed. The Supreme Court affirmed, holding that the record in this case did not warrant departure from the historic rule prohibiting the use of post-trial juror statements to impeach a facially valid verdict. View "Maras v. Commonwealth" on Justia Law

Ronnie Lee Bowling, who is currently on Kentucky’s death row for two murder convictions obtained in 1992, was also convicted in 1996 of attempted murder. Bowling was sentenced to a twenty year term for the attempted murder conviction, to be served concurrently with the earlier sentence. The 1996 judgment failed to award Bowling his entitled jail-time credit that would mean he had served out that sentence in 2009. The Department of Corrections (DOC), however, treated the twenty-year sentence as though it had been served out at that time. In 2012, Bowling filed a petition for habeas corpus in a federal district court challenging his 1996 conviction. Before the federal court could exercise jurisdiction, it had to determine whether Bowling was “in custody” under the challenged conviction. The Supreme Court accepted certified questions from the federal court regarding the issue and answered (1) the DOC may award an inmate jail-time credit that was mistakenly left off the judgment of conviction and sentence entered when the trial court was statutorily commanded to award appropriate credit; and (2) whether the DOC properly did so in this case required fact-finding to be done by the district court. View "Bowling v. White" on Justia Law

Defendant was arrested for driving under the influence of alcohol and transported to a corrections facility for a court admissible breathalyzer test. Defendant submitted to the breathalyzer test, which registered a blood-alcohol content of more than twice the legal limit. Defendant filed a motion to suppress the results of his breathalyzer test, arguing that his statutory right to attempt to contact and communicate with an attorney was violated subsequent to his arrest. The district court denied the motion to suppress. The circuit court reversed, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the Commonwealth did violate Defendant’s statutory right to attempt to contact and communicate with an attorney under Ky. Rev. Stat. 189A.105(3); but (2) because of Kentucky’s implied consent law as set forth in Ky. Rev. Stat. 189A.103 and the potential penalties attendant thereto, suppression of Defendant’s breathalyzer test results was an inappropriate remedy in this case. Remanded. View "Commonwealth v. Bedway" on Justia Law

After a jury trial, Defendant was found guilty but mentally ill of murdering Lisa Tackett and Alan Tackett and of the first-degree wanton endangerment of the victims’ four children. The Supreme Court reversed Defendant’s convictions and remanded the case for a new trial on all charges, holding (1) the trial court properly denied Defendant’s motion for a directed verdict on the four first-degree wanton endangerment counts; (2) the trial court erred in admitting very graphic and gruesome crime scene and autopsy photos of the victims, as the probative value in admitting the photographs was substantially outweighed by the undue prejudice created by the photographs; and (3) the trial court did not err in denying directed verdicts on the four charges of first-degree wanton endangerment. View "Hall v. Commonwealth" on Justia Law

Appellant was convicted of the murder of her husband and of tampering with physical evidence for hiding the gun used in the shooting. The Supreme Court reversed Appellant’s convictions, holding (1) the trial court erred by preventing Appellant from testifying that her husband had a prior felony conviction and abused its discretion by not allowing Appellant to testify about “threatening, commanding, and questioning” statements allegedly made by her husband just before, during, and after the shooting; and (2) these errors infringed on Appellant’s right to due process of law and were not harmless. View "Daughtery v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of complicity to first-degree trafficking in a controlled substance and of being a second-degree persistent felony offender. The court of appeals reversed and remanded for a new trial, concluding that the trial court abused its discretion by permitting the jurors, during deliberations, to use the Commonwealth’s attorney’s laptop computer to review an audio recording of a controlled buy. The Supreme Court reversed, holding (1) the trial court did not err in permitting the jury to review the recording at issue using the Commonwealth’s laptop; (2) the trial court did not err when it denied Defendant’s motion for directed verdict; (3) the admission of portions of a law enforcement officer’s testimony interpreting and narrating the recording was improper, but the admission of that testimony did not amount to palpable error; (4) the admission of the officer’s testimony concerning the confidential informant in this case amounted to improper character evidence, but the admission of the testimony did not amount to palpable error; and (5) the trial court did not err in admitting the confidential informant’s testimony regarding Defendant’s guilt and mental state. View "Commonwealth v. Wright" on Justia Law