Justia Civil Rights Opinion Summaries
Articles Posted in Kentucky Supreme Court
Hernandez v. Commonwealth
The Supreme Court affirmed Defendant's convictions for one count of first-degree rape and four counts of first-degree sexual abuse but vacated the trial court's judgment sentencing Defendant to an aggregate sentence of life plus twenty years, holding that Defendant's sentence was unlawful.During sentencing, the jury recommended a sentence of life on the rape conviction and five years on each of the sexual abuse charge running consecutively. The trial court sentenced Defendant in accordance with the jury's recommendation. The Supreme Court affirmed in part and vacated in part, holding (1) there was no error in the trial court's denial of Defendant's motion to suppress; (2) the trial court did not err in admitting other bad acts evidence pursuant to Ky. R. Evid. 404(b); and (3) the sentence of life plus twenty years was unlawful under this Court's holding in Bedell v. Commonwealth, 870 S.W.2d 779 (Ky. 1993). View "Hernandez v. Commonwealth" on Justia Law
Leavell v. Commonwealth
The Supreme Court affirmed the judgment of the circuit court convicting Defendant of one count each of murder, receiving stolen property - firearm, and tampering with physical evidence, holding that Appellant was not entitled to relief on her claims of error.Specifically, the Supreme Court held (1) the trial court did not err in admitting testimony that Appellant did not act consistently with someone who truly acted in self-defense; (2) the trial court did not err in denying Appellant's motions for a directed verdict on the murder and tampering with physical evidence charges; (3) the trial court did not err in admitting testimony that Appellant was potentially affiliated with a gang; (4) the Commonwealth's attorney did not commit prosecutorial misconduct; and (5) there was no cumulative error. View "Leavell v. Commonwealth" on Justia Law
Friends of Louisville Public Art, LLC v. Louisville/Jefferson County Metro Historic Landmarks & Preservation Districts Comm’n
The Supreme Court reversed the judgments of the court of appeals and circuit court affirming the decision of the Louisville/Jefferson County Metro Historic Landmarks & Preservation Districts Commission to approve the application of the Louisville/Jefferson County Metro Government to remove a certain statue, holding that the lower courts erred.In 2018, Louisville Metro filed an application to move a statue located in the historic Cherokee Triangle Preservation District. The application was deemed denied. On appeal, the Commission voted to approve the application. The parties opposing the application filed a complaint and appeal. The circuit court and court of appeals affirmed the Commission's decision. The Supreme Court reversed, holding that certain members of the Commission had a patent conflict of interest in the underlying decision, resulting in a denial of procedural due process. View "Friends of Louisville Public Art, LLC v. Louisville/Jefferson County Metro Historic Landmarks & Preservation Districts Comm'n" on Justia Law
Cameron v. EMW Women’s Surgical Center, P.S.C.
The Supreme Court affirmed the decision of the court of appeals dissolving the circuit court's temporary injunction against two statutes that effectively prohibit abortions in Kentucky except in limited circumstances where it is necessary to preserve the life of the mother, holding that the circuit court abused its discretion in granting the temporary injunction.Plaintiffs, several abortion providers, filed for injunctive and declaratory relief against Ky. Rev. Stat. 311.772 and Ky. Rev. Stat. 311.7707-11, arguing that the bans contained in the statutes violated their patients' right to privacy under sections 1 and 2 of the Kentucky Constitution. The circuit court granted the temporary injunction. The court of appeals dissolved the temporary injunction against the bans. The Supreme Court affirmed, holding (1) Plaintiffs lacked third-party standing to challenge the statutes on behalf of their patients, but Plaintiffs did have first-party, constitutional standing to challenge one of the statutes on their own behalf; and (2) the court of appeals did not err in holding that the circuit court abused its discretion by granting the temporary injunction. View "Cameron v. EMW Women's Surgical Center, P.S.C." on Justia Law
Simpson v. Commonwealth
The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to twenty years' imprisonment for his convictions of two counts of manslaughter in the second degree, driving under the influence of controlled substances first offense, and persistent felony offender first degree, holding that Defendant's claims of error did not warrant reversal.Specifically, the Supreme Court held (1) the trial court was correct in declining to suppress Defendant's statements statements he made at the accident scene, and suppression of Defendant's blood test was not required in this case; (2) the trial court did not err in excusing a prospective juror for cause; and (3) while certain statements were not properly admissible during the Commonwealth's examination of detective Brandon McPherson, they did not rise to the level of palpable error resulting in manifest injustice. View "Simpson v. Commonwealth" on Justia Law
Haney v. Commonwealth
The Supreme Court affirmed in part and vacated in part the judgment of the circuit court in this criminal case, holding that the case must be remanded for the trial court to consider whether Defendant's consent to a blood draw was voluntary under the totality of the circumstances.Defendant entered a conditional plea to one count of manslaughter in the first degree and one count of manslaughter in the second degree. The Supreme Court affirmed in part and vacated in part, holding that the trial court (1) did not err by failing to suppress Defendant's statements obtained without a Miranda warning; (2) erred in suppressing the results of Defendant's blood draw without determining whether her consent was voluntary where she received a warning that if she refused the blood test and were convicted of DUI, her mandatory minimum jail sentence would be doubled; and (3) did not err by failing to dismiss the case due to alleged abuse of the grand jury process. View "Haney v. Commonwealth" on Justia Law
Commonwealth v. Reed
The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court denying Defendant's motion to suppress location data obtained from the police's search of his real-time cell-site location information (CSLI) and the evidence obtained from the search, holding that suppression was required.Defendant entered a conditional guilty plea to one count of first-degree robbery, one count of possession of a handgun by a convicted felon, and one count of receiving stolen property. The court of appeals reversed, concluding that the trial court erred in denying Defendant's motion to suppress because the police's acquisition of Defendant's real-time CSLI constituted a warrantless, unreasonable search. The Supreme Court affirmed, holding that the officers illegally obtained Defendant's real-time CSLI and that the evidence obtained therefrom should be excluded from evidence. View "Commonwealth v. Reed" on Justia Law
Epperson v. Commonwealth
The Supreme Court affirmed the judgment of the circuit court denying Appellant's Ky. R. Crim. P. 11.42, Ky R. Crim. P. 10.02, Ky. R. Civ. P. 60.02, and Ky. R. Civ. P. 60.03 motion for relief, holding that the circuit court did not err.Appellant was convicted of two counts of complicity to murder and other crimes and sentenced to death. In the instant motion, Appellant argued that McCoy v. Louisiana, 138 S.Ct. 1500 (2018), governed his claim that his defense counsel provided ineffective assistance. The circuit court denied the motion, determining that the claim was both substantively and procedurally improper. The Supreme Court affirmed, holding that there was no error in the circuit court's denial of relief. View "Epperson v. Commonwealth" on Justia Law
Hall v. Commonwealth
The Supreme Court affirmed the judgment of the circuit court finding Defendant guilty of two counts of murder and four counts of wanton endangerment in the first degree and sentencing him to life in prison without the possibility of parole, holding that there was no error or abuse of discretion.In 2012, a jury found Defendant guilty but mentally ill of murder and wanton endangerment. The Supreme Court reversed the conviction and remanded the case for a new trial. On remand, the main issue at trial was Defendant's affirmative defense of insanity or, in the alternative, extreme emotional disturbance. A jury found Defendant guilty of the crimes and sentenced to life in prison without the possibility of parole. The Supreme Court affirmed, holding Defendant's claims on appeal were without merit. View "Hall v. Commonwealth" on Justia Law
Commonwealth v. Clayborne
The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress evidence of cocaine discovered after a dog sniff of the vehicle in which Defendant was a passenger, holding that the stop was extended, and that extension was not justified by reasonable, articulable suspicion.Defendant was charged with first-degree possession of cocaine. He pled not guilty and filed a motion to dismiss, claiming that he was illegally detained and that the police did not have reasonable, articulable suspicion to call the dog. The trial court determined that it was a valid stop and that the evidence should not be suppressed. The Supreme Court affirmed, holding (1) the traffic stop was extended; (2) the Commonwealth failed to establish simultaneous missions that permitted the seizure; and (3) the Commonwealth did not meet its burden of establishing reasonable, articulable suspicion. View "Commonwealth v. Clayborne" on Justia Law