Justia Kentucky Supreme Court Opinion Summaries

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

Appellee sought to void or reform a deed resulting from a sale of property through Appellant's real estate company. Specifically, Appellee claimed that the deed grossly misrepresented the amount of land he contracted to buy. The deed's description called for 300 acres but showed the property was being sold by tract, not acreage. Appellee learned through other sources that the property did not consist of 300 acres. After closing, a survey showed the tract contained forty-four acres. The trial court ruled in favor of Appellants, concluding that, because Appellee was aware at the time of closing that the tract did not contain 300 acres of land, no fraud existed that warranted reforming the deed. The Supreme Court agreed, holding that because Appellee was aware there was a deficiency in acreage, Appellee was on notice regarding the deficiency in the property, and the common law doctrine of caveat emptor applied. View "Manning v. Lewis" on Justia Law

After a jury trial, Defendant was convicted of theft of identity, theft by deception under $500, and being a first-degree persistent felony offender. Defendant appealed, contending that after he was taken into custody, he was not properly advised of his Miranda rights, and therefore, the trial court erred in admitting the statement he made to police. The Supreme Court reversed Defendant's convictions, holding (1) statements made in response to assurances of confidentiality are made in violation of Miranda and must be suppressed; (2) in this case, the officer's agreement that Appellant's statement would be confidential vitiated the previously given Miranda warnings; and (3) therefore, the trial court erred in failing to suppress the statements. Remanded. View "Leger v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of first-degree trafficking in a controlled substance, second-degree trafficking in a controlled substance, and being a first-degree persistent felony offender (PFO). Defendant appealed, contending, among other things, that the trial court erroneously admitted prior bad acts evidence and hearsay evidence. The Supreme Court reversed Defendant's convictions and sentences, holding (1) the trial court abused its discretion in admitting testimony of an anonymous tip that Defendant was trafficking pills because the anonymous tip evidence was inadmissible hearsay; and (2) given the extent to which the prosecutor focused on the anonymous tip in his closing argument, the erroneously admitted anonymous-tip evidence was not harmless. View "Kerr v. Commonwealth" on Justia Law

Appellee brought his vehicle to Appellant's shop for repairs. When Appellant presented Appellee with his bill, Appellee refused to pay until Appellant proved he purchased the parts he claimed to have installed. Appellant retained Appellee's vehicle while he attempted to resolve the dispute. Appellee subsequently filed a criminal complaint against Appellant, and Appellant was arrested for failure to make required disposition of property. Appellee regained possession of his vehicle, and the charges against Appellant were dismissed. Appellant then filed a mechanic's lien and brought suit against Appellee to enforce the lien. The complaint also claimed damages for, inter alia, malicious prosecution and abuse of process. The trial court directed a verdict in Appellee's favor on most of Appellant's claims but concluded that Appellant asserted a valid mechanic's lien and awarded Appellant $8,000. The court of appeals affirmed the trial court's orders directing verdicts on the abuse of process and malicious prosecution claims. The Supreme Court reversed, holding (1) the trial court erred in directing a verdict of dismissal on the malicious prosecution claim based on the advice of counsel defense; and (2) Appellant submitted sufficient evidence to survive a motion for a directed verdict on the abuse of process claim. View "Garcia v. Whitaker" on Justia Law

Appellant pled guilty to murder, resisting arrest, and tampering with physical evidence and was sentenced to fifty years' imprisonment. At trial, Appellant moved to suppress his confession to law enforcement officers, arguing that his Miranda waiver was involuntary, his right to counsel was invoked but denied, and his confession was coerced. The trial court denied the motion. The Supreme Court reversed the judgment and sentence of the circuit, holding that under the totality of the circumstances, Defendant's confession was involuntary under the Due Process Clause of the Fourteenth Amendment as the product of coercive police activity. View "Dye v. Commonwealth" on Justia Law

Appellant plead guilty to three counts each of capital murder, capital kidnapping, tampering with physical evidence, and related convictions. The circuit court sentenced Appellant to death for each of the six capital crimes. The Supreme Court affirmed the convictions and sentences, holding, inter alia, that (1) the trial court properly accepted Appellant's guilty plea; (2) the trial court did not reversibly err by asking Appellant to admit to the aggravating circumstances; (3) the jury was properly selected; (4) the trial judge's denial of Appellant's motion to recuse was not erroneous; (5) the introduction of certain photographs was proper to explain the circumstances surrounding the crimes and the extent of harm inflicted; (6) the trial court did not err in denying Appellant's motion for a mistrial and change of venue; (7) the instructions to the jury did not deny Appellant due process or reliable sentencing; and (8) Appellant's death sentences were not arbitrary or disproportionate. View "Dunlap v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of second-degree manslaughter, leaving the scene of an accident, second-degree assault, fourth-degree assault, and several drug-related offenses. The Supreme Court affirmed Defendant's convictions and resulting sentences, holding, inter alia, (1) the trial court did not err by denying Defendant's motion for directed verdict on the charge of second-degree manslaughter because the Commonwealth presented sufficient evidence; (2) the trial court did not err by trying the charges against Defendant in a single trial; (3) the Commonwealth's reference to an inadmissible statement during closing argument did not constitute palpable error; (4) the Commonwealth did not impermissibly use Ky. R. Evid. 404(b) evidence to obtain a conviction; (5) the jury instruction for second-degree assault was not erroneous; (6) the Commonwealth produced sufficient evidence to support Defendant's conviction for second-degree assault; and (7) no palpable error resulted from the first-responders testifying about their relationship with the victim. View "Doneghy v. Commonwealth" on Justia Law

The Department of Revenue audited Appellant for a three-year period. The Department determined that Appellant had omitted certain tangible personal property from its tax returns during the relevant years and billed Appellant for $151,943 in ad valorem taxes. Appellant paid the new assessments without protest. Appellant later filed a refund claim for a portion of the taxes, that the Department had improperly classified certain machinery, resulting in Appellant's overpayment. The Department denied the refund claim because Appellant had paid without protest. The Board of Tax Appeals reversed, and the circuit court and court of appeals affirmed. The Supreme Court affirmed, holding that Appellant properly followed the appropriate administrative remedies in accordance with the Court's recent decision in Cromwell Louisville Associates, LLP v. Commonwealth. View "Dep't of Revenue v. Cox Interior, Inc." on Justia Law

After a trial, Defendant was convicted of first-degree sodomy, tampering with physical evidence, and fourth-degree assault. The court of appeals reversed the sodomy conviction, concluding that the trial court erred in excluding statements the victim made to medical personnel about her history of drug use and addiction. The Supreme Court reversed the court of appeals' judgment insofar as it reversed the sodomy conviction and reinstated that portion of the trial court's judgment, holding that the trial court did not abuse its discretion in excluding evidence of the victim's prior drug use because it was highly prejudicial, and the exclusion of the evidence did not violate Defendant's right to present a defense. View "Commonwealth v. Bell" on Justia Law