Justia Kentucky Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of manufacturing methamphetamine, possession of anhydrous ammonia in an unapproved container with the intent to use or manufacture methamphetamine, and being a first-degree persistent felony offender. Appellant was sentenced to thirty years in prison. The Supreme Court affirmed, holding (1) the trial court did not err in denying Appellant's motion to suppress evidence obtained by a warrantless search of the house at which Appellant was found carrying methamphetamine precursors, as Appellant lacked sufficient standing to challenge the validity of the warrantless search; and (2) Appellant was not entitled to a directed verdict based on the Commonwealth's failure to disprove entrapment, as no reasonable juror could have concluded that Appellant was entrapped and not guilty of the crimes charged. View "Mackey v. Commonwealth" on Justia Law

Defendant pleaded guilty to charges of murder, first-degree burglary, and two counts of first-degree sexual abuse. After a sentencing hearing, the trial judge sentenced Defendant to death. Defendant subsequently filed a Ky. R. Crim. P. 11.42 motion collaterally attacking his sentence and conviction, claiming that his guilty plea should be set aside as involuntary because he believed the trial judge had agreed to sentence him to life without parole and because his trial counsel bullied him into entering the guilty plea. The trial judge denied the motion without an evidentiary hearing. The Supreme Court remanded the matter for an evidentiary hearing on whether there was judicial interference in the plea process and whether Defendant was coerced by his counsel. After an evidentiary hearing on remand, the trial judge denied Defendant's motion for relief. The Supreme Court affirmed, holding that the proof showed no judicial interference in the plea process and that Defendant's counsel did not threaten or otherwise coerce him into pleading guilty. View "Johnson v. Commonwealth" on Justia Law

Appellee, an inmate, allegedly assaulted another inmate. After a disciplinary report was submitted against Appellee, the Adjustment Committee (Committee) determined that Appellee was guilty of the infraction and sentenced Appellee accordingly. Appellee appealed the decision and filed a petition for declaration of rights, arguing that the Committee's reliance on information obtained from confidential informants violated his constitutional due process rights. After a rehearing, the Committee again declared Appellee guilty of the infraction. The trial court ultimately dismissed Appellee's petition, concluding that the Committee did not violate Appellee's due process rights. The court of appeals reversed, determining that there was insufficient evidence of the disciplinary charge against Appellee to pass the "some evidence" standard pronounced in Superintendent, Massachusetts Correctional Institution, Wadpole v. Hill. The Supreme Court affirmed, holding (1) the Committee, relying solely on the confidential informants' information, failed to supply some evidence to support its finding that the confidential informants and their information were credibl; and (2) accordingly, Appellee's due process rights were violated. View "Haney v. Thomas" on Justia Law

After a jury trial, Defendant was convicted of tampering with physical evidence, possession of drug paraphernalia, criminal littering, and carrying a concealed deadly weapon. The court of appeals reversed and remanded Defendant's criminal littering conviction but otherwise affirmed. Defendant sought discretionary review, challenging the constitutional validity of the initial traffic stop, the pat-down of his person, and the vehicle search which led to the evidence supporting his convictions. The Supreme Court reversed and remanded, holding (1) Defendant was arrested after the officer conducted an unlawful Terry pat-down of his person, resulting in the discovery of a bag of marijuana; and (2) therefore, the vehicle search incident to the unlawful arrest was also unlawful. View "Frazier v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of second-degree burglary. Defendant was placed on probation, which was later revoked due to Defendant's noncompliance with the terms of the county's drug court program. Defendant appealed both his burglary conviction and his probation revocation. The court of appeals reversed Defendant's conviction, concluding that the trial court erred in failing to conduct a Faretta v. California hearing to inquire into Defendant's desire to serve as his own attorney. The Supreme Court reversed, holding that because Defendant did not unequivocally request to dispense with counsel and to proceed pro se, the trial court was under no obligation to engage Defendant in a Faretta colloquy. Remanded. View "Commonwealth v. Martin" on Justia Law

In 1992, Defendant pled guilty to illegal possession of a controlled substance in the first degree. In 2010, Defendant filed a motion to void her felony conviction, which the circuit court granted. Thereafter, Defendant moved to expunge the newly voided felony conviction. The Commonwealth opposed the motion, asserting that neither Ky. Rev. Stat. 431.076 nor Ky. Rev. Stat. 431.078 provide for expungement of a voided conviction. The trial court expunged Defendant's record pursuant to Ky. R. Civ. P. 60.02(f), which permits a court to relieve a party from its final judgment for any reason of an extraordinary nature that justifies such relief. The court of appeals affirmed but on different grounds, concluding that Defendant's voided conviction amounted to the underlying charge being dismissed with prejudice, thereby qualifying for expungement under section 431.076. The Supreme Court reversed, holding (1) the trial court lacked authority under section 431.076 to expunge Defendant's newly voided conviction, as voiding Defendant's conviction was not the same as her charges being dismissed with prejudice; and (2) the use of the catch-all provision found in Rule 60.02(f) was error. View "Commonwealth v. Jones" on Justia Law

Appellant pled guilty to four counts of complicity to rape (victim under twelve years of age) and one count each of first-degree rape, first-degree sodomy, and first-degree sexual abuse pursuant to a conditional guilty plea. Appellant subsequently appealed the trial court's denial of his motion to suppress statements he made to a social worker on the grounds that Appellant was not provided with Miranda warnings. The trial court determined that, under the totality of the circumstances, Appellant was not entitled to Miranda warnings. The Supreme Court affirmed, holding that, considering the totality of the circumstances, Appellant was not subjected to custodial interrogation for purposes of Miranda, and therefore, the trial court properly denied Appellant's motion to suppress. View "Buster v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of burglary in the second degree, burglary in the third degree, and of being a persistent felony offender in the first degree. Defendant was sentenced to twenty years' imprisonment. The Supreme Court affirmed, holding (1) the trial court did not err in not instructing the jury on criminal trespass as a lesser included offense of second-degree burglary, as Defendant did not request a lesser included offense of criminal trespass; and (2) Defendant's argument that the trial court improperly imposed court costs in its oral ruling at sentencing failed because the written order did not impose court costs. View "Brock v. Commonwealth" on Justia Law

Appellant pled guilty to possession of drug paraphernalia (PDP), second offense, pursuant to a plea agreement and received a five-year pretrial diversion. At the time Appellant entered into the diversion, the penalty for second offense PDP, a felony, was one to five years in prison. The statute was amended in April 2010, however, making the penalty for a second or subsequent offense of PDP, now a misdemeanor, ninety days to twelve months in jail. Appellant subsequently pled guilty to DUI. At her sentencing hearing, Appellant requested that the trial court continue her diversion, given that second offense PDP was now a misdemeanor, or apply the new sentence for second offense POP. The trial court voided the diversion agreement and sentenced Appellant to felony time in accordance with the prior law. The court of appeals affirmed. The Supreme Court reversed, (1) when Appellant violated the terms of her diversion agreement, the court was vested with the authority to void the contract in its entirety; but (2) because there was no final judgment entered when Appellant violated the terms of her diversion, any law that had gone into effect that would mitigate Appellant's sentence should have been applied. View "Smith v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of murder and sentenced to twenty years in prison. The Supreme Court affirmed, holding (1) the post-trial revelation that the victim's wife and one of the jurors were Facebook friends did not establish grounds for a new trial, as the juror did not manifestly give a false answer regarding her Facebook relationship with the victim's wife, and merely being friends on Facebook does not, per se, establish a close relationship from which partiality on the part of a juror may reasonably be presumed; (2) Appellant's argument that the jury improperly considered penalty phase issues during the guilt phase deliberations was without merit; and (3) the trial court's exclusion of certain evidence did not afford Appellant grounds upon which his conviction should be reversed. View "McGaha v. Commonwealth" on Justia Law