Justia Civil Rights Opinion Summaries
Articles Posted in Kentucky Supreme Court
Kerr v. Commonwealth
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
Dye v. Commonwealth
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
Dunlap v. Commonwealth
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
Doneghy v. Commonwealth
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
Commonwealth v. Bell
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
Bartley v. Commonwealth
Defendant and Co-defendant were jointly charged with having neglected and abused Defendant's disabled son. After a jury trial, Defendant was convicted of first-degree assault and first-degree criminal abuse. The Supreme Court affirmed, holding (1) counsel's representation of Defendant was not adversely affected by a conflict of interest because Defendant's counsel worked for the same office as did Co-defendant's counsel; (2) Defendant was lawfully charged with and fairly convicted of first-degree assault; (3) the trial court did not err in instructing the jury with respect to the alleged assault; (4) the trial court did not err in instructing the jury with respect to a lesser included offense of assault; (5) the trial court did not abuse its discretion by denying Defendant's pre-trial motion for a continuance; and (6) the trial court did not abuse its discretion by denying Defendant's motion for a mistrial. View "Bartley v. Commonwealth" on Justia Law
Turley v. Commonwealth
Appellant was convicted of first-degree possession of a controlled substance, possession of marijuana, and of being a second-degree persistent felony offender. Appellant appealed, arguing that the trial court erred by denying his motion to suppress the drug-related evidence seized during a routine traffic stop because its discovery was the product of a custodial detainment that extended beyond the scope of the original purpose of the traffic stop in violation of the Fourth Amendment. The Supreme Court reversed, holding that the trial court erred in failing to suppress the illegally obtained drug evidence, as the evidence was discovered after the purpose of the traffic stop had concluded, and no exception applied so as to permit the police officer to extend his encounter with Appellant beyond that time. Remanded.
View "Turley v. Commonwealth" on Justia Law
Murray v. Commonwealth
After a jury trial, Defendant was convicted of complicity to commit murder, first-degree robbery, first-degree burglary, and tampering with physical evidence. The Supreme Court affirmed the judgment of conviction and sentence, holding (1) any error by the trial court in allowing certain testimony into evidence was harmless; (2) the trial court properly decided to try the murder charges in a single trial; (3) the trial court correctly refused to dismiss the tampering with physical evidence charges as unconstitutional; (4) the admission of testimony regarding alleged homosexual conduct between Defendant and his co-conspirator was appropriate; and (5) the trial court did not err by failing to instruct the jury on criminal facilitation to murder and robbery. View "Murray v. Commonwealth" on Justia Law
Grider v. Commonwealth
Appellant was indicted for the robbery and murder of Caesaro Gomez. Appellant, who was sixteen years old at the time of the crimes, was tried as a youthful offender and found guilty by a circuit court jury of murder, first-degree robbery, and intimidating a participant in the legal process. Appellant was sentenced to life imprisonment. The Supreme Court affirmed the conviction and sentence, holding (1) the trial court did not abuse its discretion in denying Appellant's motion to strike for cause; (2) Appellant's argument regarding the validity of Ky. R. Crim. P. 9.40 was unpreserved for appellate review; and (3) the trial court did not err in sentencing Appellant. View "Grider v. Commonwealth" on Justia Law
Cox v. Commonwealth
Defendant was sentenced as a second-degree persistent felon to a twenty-year term of imprisonment for first-degree possession of a controlled substance, firearm enhanced and to a concurrent ten-year term of imprisonment for possession of a handgun by a convicted felon. Defendant appealed, contending that a parole officer's incomplete and inaccurate testimony regarding sentence credits potentially available to parolees rendered the penalty phase of his trial fundamentally unfair. The Supreme Court affirmed Defendant's sentence, holding that to the extent, if any, that the parole officer's lack of detail about credits against a parolee's sentence could be deemed erroneous, the error was not palpable, and therefore, Defendant was fairly sentenced. View "Cox v. Commonwealth" on Justia Law