Justia Kentucky Supreme Court Opinion Summaries

Appellant entered a guilty plea to manufacturing methamphetamine, first-degree possession of a controlled substance, and promoting contraband. On appeal, Appellant argued that the trial court erred by not allowing him to withdraw his guilty plea. The Supreme Court affirmed the circuit court’s denial of Appellant’s motion to withdraw guilty plea, holding (1) the trial court’s decision was not arbitrary, unreasonable, unfair, or unsupported by sound legal principles; and (2) the trial court’s decision to release the Commonwealth from its recommended conditional penalty and to allow the prosecution to recommend the maximum sentence instead did not amount to a rejection of the plea agreement. View "Prater v. Commonwealth" on Justia Law

Appellant pled guilty to several crimes, including capital murder. The circuit court sentenced Appellant to death for his six capital crimes and to life imprisonment for rape, kidnapping, and arson. The Supreme Court affirmed, holding, inter alia, that (1) the trial court properly accepted Appellant’s guilty plea; (2) playing Appellant’s videotaped guilty plea colloquy for the jury did not constitute reversible error; (3) the trial court properly denied Appellant’s guilty but mentally ill plea; (4) the jury was properly selected; (5) the trial judge did not err in denying Appellant’s motion to exclude certain photographs; (6) the trial court properly denied Appellant’s motion to suppress statements he made to law enforcement officers and properly permitted the jury to watch his videotaped statement; (7) the jury instructions did not deny Appellant due process or reliable sentencing; and (8) Appellant’s sentences were constitutional, and his death sentences were not arbitrary and disproportionate. View "Dunlap v. Commonwealth" on Justia Law

Appellant entered a conditional guilty plea to possession of a controlled substance and carrying a concealed deadly weapon. Appellant appealed the district court’s denial of his motion to suppress evidence seized upon his arrest. The circuit court and court of appeals both affirmed the district court’s ruling. The Supreme Court affirmed the district court’s denial of Appellant’s motion to suppress, holding that police officers’ search and ultimate seizure of a gun and controlled substances found on Appellant’s person was supported by sufficient cause and thus was a valid search incident to arrest. View "Vega v. Commonwealth" on Justia Law

After a jury trial, Appellant was found guilty of robbery, burglary, unlawful imprisonment, receiving stolen property, and being a persistent felony offender (PFO). Appellant was sentenced to thirty years’ imprisonment. The Supreme Court reversed Appellant’s convictions and remanded the case for further proceedings, holding (1) the trial court erred when it misinformed Appellant that he could not proceed to trial with a hybrid form of representation and therefore denied Appellant his right to represent himself for one pretrial motion while still retaining the services of counsel for the remainder of the proceedings; and (2) because the trial judge misstated the law, reversal and a new trial were necessary. View "Mitchell v. Commonwealth" on Justia Law

After a jury trial, Appellant was found guilty of first-degree wanton endangerment, first-degree fleeing or evading the police, illegal possession of a controlled substance, and second-degree criminal mischief. The jury also found Appellant guilty of being a persistent felony offender (“PFO”) in the first-degree. The trial court sentenced Appellant to an enhanced sentence of twenty years. The Supreme Court affirmed Appellant’s conviction and sentence, holding (1) Ky. R. Crim. P. 9.40, the rule prescribing the number of peremptory challenges in a criminal case, is valid, and the trial court properly relied on that rule in this case; and (2) the Commonwealth improperly characterized Appellant’s PFO status, but the mischaracterization was not palpable error. View "Glenn v. Commonwealth" on Justia Law

Appellee, an experienced criminal attorney, was indicted on five counts of failure to file Kentucky tax returns for the tax years 2002 through 2006. Appellee proceeded pro se until a day before the jury trial was scheduled to begin, at which point Appellees requested a continuance for the purpose of possibly retaining private counsel. The trial court overruled the motion for a continuance. At no stage during the proceedings did the court conduct a Faretta hearing. Appellee was subsequently found guilty of five counts of failing to file a state tax return. The court of appeals reversed. The Supreme Court reversed the court of appeals and reinstated the judgment of the circuit court, holding that criminal defendants who are experienced criminal trial attorneys are not entitled to a Faretta hearing or inquiry prior to representing themselves. View "Commonwealth v. Ayers" on Justia Law

After a jury trial, Appellee was convicted of possession of a controlled substance, fleeing or evading police, and being a persistent felony offender. The judgment was affirmed on appeal. Appellee subsequently filed a Ky. R. Crim. P. 11.42 motion seeking relief from the judgment by alleging ineffective assistance of counsel. The trial court denied the motion without an evidentiary hearing, concluding that Appellee was not prejudiced by counsel’s alleged errors. The court of appeals reversed and remanded the case to the trial court for a hearing, concluding that Appellee’s allegations of ineffective assistance of trial counsel were not clearly refuted by the record. The Supreme Court reversed the opinion of the court of appeals and reinstated the trial court’s order, holding that the trial court did not err in denying Appellee’s Rule 11.42 motion without an evidentiary hearing because a hearing was not necessary to determine that Appellee was not prejudiced by any errors of trial counsel regardless of whether those errors amounted to unprofessional performance. View "Commonwealth v. Searight" on Justia Law

A grand jury indicted Appellee for one count of murder. Appellee moved to dismiss the indictment, contending that he was legally justified to act in self-defense and therefore immune from prosecution pursuant to Ky. Rev. Stat. 503.085. The trial court denied Appellee’s motion to dismiss. Appellee subsequently filed a notice of appeal. The court of appeals concluded that it had jurisdiction to consider the interlocutory appeal, holding that an order denying immunity from prosecution is immediately appealable. The Supreme Court reversed, holding (1) the court of appeals was not authorized by statute or by the Constitution to consider an appeal from an interlocutory order denying immunity pursuant to section 503.085; and (2) furthermore, the collateral order exception to the finality doctrine did not apply in this circumstance. View "Commonwealth v. Farmer" on Justia Law

After a jury trial, Appellant was found guilty of first-degree wanton endangerment, fleeing or evading the police, first-degree illegal possession of a controlled substance, and second-degree criminal mischief. The trial court sentenced Appellant as a persistent felony offender (PFO) to twenty years' incarceration. The Supreme Court affirmed Appellant's conviction and sentence, holding (1) Ky. R. Crim. P. 9.40, which prescribes the number of peremptory challenges in a criminal case, is valid, and the Court has the authority to promulgate that rule and all other rules of practice and procedure in the Commonwealth; and (2) the Commonwealth improperly mischaracterized Appellant's PFO status during closing arguments of the PFO guilt phase trial, but the error was not palpable. View "Glenn v. Commonwealth" on Justia Law

Appellee, a licensed attorney with experience in the practice of criminal law, was indicted on five counts of failure to file Kentucky tax returns for several years. Prior to trial, Appellee appeared on his own behalf, but one day before jury trial was to begin, Appellee requested a continuance to retain private counsel. The trial judge overruled the motion without holding a formal Faretta hearing. After a jury trial, Appellee was convicted on five counts of failing to file a state tax return. The court of appeals reversed the conviction. The Supreme Court reversed the court of appeals and reinstated the circuit court's judgment, holding that criminal defendants who are experienced criminal trial attorneys are not entitled to a Faretta hearing or inquiry prior to representing themselves. View "Commonwealth v. Ayers" on Justia Law