Justia Kentucky Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of capital murder and sentenced to death. The Supreme Court affirmed the conviction but remanded for a new sentencing trial. After a retrial, the jury again returned a death-penalty verdict. Appellant was sentenced in accordance with that verdict. Appellant appealed the denial of his motion for a new trial and his death sentence. The Supreme Court affirmed Appellant’s murder conviction, to the extent it was challenged on appeal, and sentence of death, holding that (1) Appellant’s claims of error were either without merit or did not require reversal; and (2) the jury’s verdict was factually substantiated, and the sentence was valid. View "St. Clair v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of one count of burglary, three counts of theft by unlawful taking of a firearm, one count of theft by unlawful taking of property having a value of $500 or more, and of being a persistent felony offender in the first degree. Defendant was sentenced to twenty-five years in prison. The Supreme Court reversed, holding (1) the trial court abused its discretion in allowing admission of detailed evidence of Defendant’s past domestic violence, as the evidence became an expose of Defendant’s extensive domestic misconduct, and the probative value of the evidence was clearly outweighed by its prejudicial nature; (2) Defendant’s convictions on the three separate counts of theft by unlawful taking of a firearm violated Defendant’s double jeopardy rights; and (3) the evidence was not sufficient to support the first-degree burglary conviction. View "Wilson v. Commonwealth" on Justia Law

Appellant pleaded guilty to several offenses, including manufacturing methamphetamine while in possession of a firearm and being a first-degree persistent felony offender, and received a maximum sentence of twenty years’ imprisonment. Based on his convictions, the Department of Corrections classified Appellant as a violent offender, which required Appellant to serve a greater part of his sentence before reaching parole eligibility. Appellant sued the Department in circuit court to block the violent-offender classification’s application to him, arguing that his convictions were all non-violent drug offenses. The circuit court dismissed Appellant’s suit, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the Controlled Substances Act operates to enhance the conviction, not simply the sentence; and (2) the firearm-enhancement provision of the Act served to elevate Appellant’s conviction for manufacturing methaphetamine from a Class B to a Class A felony conviction, which qualified Appellant for classification as a violent offender. View "Mills v. Dep’t of Corr. Offender Info. Servs." on Justia Law

After a jury convicted Appellant of possession of a handgun by a convicted felon Appellant entered a conditional guilty plea to various other charges. On appeal, Appellant challenged the trial court’s exclusion of prior-bad-acts evidence and hearsay testimony. The court of appeals affirmed, concluding that the trial court erred by excluding the evidence but that Appellant did not properly preserve the issue for appellate review. The Supreme Court affirmed Appellant’s conviction and sentence, holding (1) counsel’s offer of proof about the excluded testimony was insufficient to preserve appellate review; and (2) regardless of any preservation misstep, the trial court’s exclusion of the testimony was harmless. View "Henderson v. Commonwealth" on Justia Law

Appellant pled guilty to charges of murder, abuse of a corpse, and tampering with physical evidence in connection with the shooting death of her husband, as well as several counts of forgery. Appellant was sentenced to thirty years’ imprisonment. On appeal, Appellant argued that the trial court committed two errors in its decisions regarding her sentencing. The Supreme Court affirmed, holding (1) the trial court did not err in concluding that Appellant was not entitled to the victim-of-domestic-violence exception to the parole eligibility requirement for violent offenders established by Ky. Rev. Stat. 439.3401; and (2) if the trial court erred in failing to consider probation as a sentencing alternative, the error was harmless. View "Gaines v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of burglary in the first degree, assault in the fourth degree, and for being a persistent felony offender in the first degree. The Supreme Court affirmed, holding that the trial court (1) did not err by refusing to dismiss the entire jury venire after certain statements by a prospective juror instead of issuing an admonition; (2) erred in allowing the narration of security footage by witnesses, but the error was harmless; (3) improperly allowed speculative testimony regarding Defendant, but the error was harmless; and (4) did not err in finding Defendant to be a persistent felony offender in the first degree. View "Boyd v. Commonwealth" on Justia Law

Appellant’s charges in this case stemmed from a search of his residence by his parole officers and local sheriff’s deputies. Appellant entered a conditional guilty plea to manufacturing methamphetamine and being a second-degree persistent felony offender and was sentenced to fifty years’ imprisonment. The Supreme Court affirmed, holding that the trial court did not err in (1) denying Appellant’s motion to suppress the products of the search of his home, as Appellant consented to the search and there was no indication that the consent was invalid; and (2) denying Appellant’s motion to suppress the results of lab testing on the products of the search, as the lab results were clearly admissible. View "Helphenstine v. Commonwealth" on Justia Law

In 2000, Appellant pled guilty to one count of theft by deception and was sentenced to a one-year term of imprisonment, probated for a period of five years. After Appellant failed to report to her probation officer, the trial court issued a warrant for her arrest. In 2011, Appellant was finally served with the arrest warrant. After a probation revocation hearing, the trial court dismissed the Commonwealth’s motion to revoke Appellant’s probation, determining that Appellant’s period of probation had already expired. The court of appeals reversed, concluded that because Appellant “intentionally absconded,” she was barred from claiming that her probationary period had expired. The Supreme Court affirmed, holding (1) the issuance of a warrant for a probation violation will toll the period of probation preventing the probationer from being automatically discharged pursuant to Ky. Rev. Stat. 533.020(4); (2) the warrant, however, must be issued before the expiration of the period of probation; and (3) since the circuit court issued a warrant for Appellant’s arrest within the five-year probationary period, it retained jurisdiction to conduct a probation revocation hearing.View "Whitcomb v. Commonwealth" on Justia Law

After a jury trial, Appellant was convicted of first-degree sodomy and first-degree burglary, enhanced by the status offense of persistent felony offender (PFO) in the second degree, and was sentenced to thirty-five years' imprisonment. The Supreme Court affirmed, holding that the trial court (1) did not err by denying Appellant's motion for a directed verdict on the first-degree burglary charge; (2) properly applied Ky. R. Evid. 412, the rape shield rule, to prohibit admission of evidence of the victim's sexual history; and (3) did not err in allowing the Commonwealth to proceed to trial on the PFO charge. View "Minter v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of first-degree assault, first-degree wanton endangerment, and operating a motor vehicle under the influence of alcohol, among other charges. The Supreme Court affirmed except as to Defendant's conviction for wanton endangerment, which the Court reversed, holding (1) the trial court did not violate Defendant's due process right to a fair trial by failing to remove two jurors for cause; (2) the trial court did not violate Defendant's right to confrontation by introducing a hospital laboratory report without the testimony of the person who prepared the report; but (3) the prosecution of the wanton endangerment charge violated Defendant's double jeopardy rights, and the wanton endangerment instruction violated Defendant's right to a unanimous verdict. Remanded.View "Little v. Commonwealth" on Justia Law