Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of murder and sentence of life imprisonment, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held that the trial court (1) did not err by refusing to remove six jurors for cause; (2) did not abuse its discretion in refusing a change of venue; (3) did not abuse its discretion in allowing testimony regarding Defendant's lack of remorse; (4) did not abuse its discretion in disallowing two defense exhibits; (5) did not err in limiting the evidence of Defendant's drug use; (6) did not err in allowing victim impact testimony; (7) did not abuse its discretion in admitting a certain witness's testimony; and (8) did not err in declaring another witness unavailable and allowing her prior trial testimony to be played for the jury. View "Hubers v. Commonwealth" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing the trial court's grant of summary judgment in favor of Louisville & Jefferson County Metropolitan Sewer District (MSD) on Mark Hill's claims under the Whistleblower Act, Ky. Rev. Stat. 61.101 et seq., and the Kentucky Civil Rights Act (KCRA), Ky. Rev. Stat. 344.010 et seq., holding that Hill's KCRA claims were correctly dismissed but that MSD was not subject to the Whistleblower Act.With respect to Hill's Whistleblower claim, the trial court found that MSD was not to be considered an "employer" under the Whistleblower Act. The court also found that Hill failed to present any affirmative evidence in support of his KCRA claims. The court of appeals affirmed the trial court as to Hill's KCRA claims but reversed as to Hill's Whistleblower claim. The Supreme Court reversed as to the Whistleblower claim, holding that MSD was not an "employer" for purposes of the Whistleblower Act. View "Louisville & Jefferson County Metropolitan Sewer District" on Justia Law

The Supreme Court affirmed Conrai Kaballah's conviction of criminal attempt-murder, first-degree assault, and other crimes and Ricardo Taylor's conviction of criminal attempt-murder, first-degree assault, and other crimes and both defendant's sentences of life imprisonment, holding that any errors were harmless.Specifically, the Supreme Court held (1) both defendants should have been Mirandized prior to being interrogated shortly after the assault occurred; (2) the trial court erred by allowing a transcript commissioned by the Commonwealth of a phone call Taylor made from jail to be shown during closing arguments; and (3) both errors were harmless as a matter of law due to the overwhelming evidence against the defendants and the inconsequential nature of the evidence produced from the errors. View "Taylor v. Commonwealth" on Justia Law

The Supreme Court reversed Defendant's conviction for first-degree manslaughter, tampering with physical evidence, possession of a handgun by a convicted felon, and second-degree persistent felony offender and twenty-five-year sentence, holding that Defendant was deprived of his right to counsel at a critical stage of the proceedings.On appeal, Defendant asserted that he was denied the right to conflict-free counsel during an in-chambers hearing that the trial court conducted on the fitness and ability of Defendant's private attorney to try the case. Defendant argued that the in-chambers hearing on his attorney's fitness was a critical stage of the proceedings and that he was prejudiced by not having conflict-free counsel represent him. The Supreme Court agreed, holding that the trial court's decision not to inform Defendant of the concerns raised about his counsel's fitness to try the case and not to offer Defendant the opportunity to retain independent counsel to represent his interests was an error of constitutional magnitude mandating reversal. View "Downs v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of three counts of first-degree trafficking in a controlled substance, holding that the trial court did not err in refusing to suppress evidence that was found on Defendant's person during a warrantless search.On appeal, Defendant argued that the trial court erred in denying his motion to suppress because (1) the officer illegally extended the traffic stop beyond its original purpose, (2) the continued detention of Defendant after the traffic stop constituted an illegal seizure, and (3) the officers did not have probable cause to search his person. The Supreme Court affirmed, holding (1) the lawful traffic stop had not concluded at the time consent was obtained to search the vehicle, and the officer did not inquire into matters unrelated to the stop's mission; (2) Defendant's detention during the search of the vehicle was reasonable; and (3) a search of Defendant's person was warranted under the circumstances. View "Carlisle v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the trial court's judgment in favor of Defendant on Plaintiff's age-discrimination claim, holding that the trial court committed reversible error by requiring the jury, rather than the court itself, to make the specific factual determination about whether Defendant, Plaintiff's former employer, replaced Plaintiff with a substantially younger person.Plaintiff sued Defendant for age discrimination in violation of the Kentucky Civil Rights Act and for retaliation, alleging that she was terminated for complaining about her former supervisor's behavior before she was replaced. During trial, Plaintiff relied on circumstantial evidence to support her age discrimination claim. The jury rendered a verdict for Defendant. The court of appeals reversed. The Supreme Court affirmed, holding that the trial court committed reversible error by instructing the jury to decide the element under the McDonnell Douglas framework that Defendant replaced Plaintiff with a substantially younger person. View "Norton Healthcare, Inc. v. Disselkamp" on Justia Law

The Supreme Court reversed Defendant's convictions for first-degree fleeing or evading, first-degree wanton endangerment, reckless driving, and being a first-degree persistent felony offender, holding that the trial court erred by depriving Defendant of the right to be represented during a critical stage of the trial.On appeal, Defendant argued, among other things, that he was denied representation at a critical stage of his trial through the trial court's ex parte discussion with a juror who had been offered a bribe. The trial court's interview with the juror was conducted outside of Defendant's presence. The Supreme Court reversed Defendant's convictions, vacated the sentences, and remanded this matter to the trial court for further proceedings, holding that the trial court's failure to take action to include counsel during the bench conference and the failure to admonish the juror to disregard her encounter and not to discuss the attempted bribe with fellow jurors violated Defendant's right to a fair trial as guaranteed by his rights to representation and right to be present at all critical stages of trial. View "Eversole v. Commonwealth" on Justia Law

The Supreme Court vacated the interlocutory orders of the trial court concluding that Defendants' individual psychological assessments provided further support for the exclusion of the death penalty as to Defendants individually, holding that the constitutional issue in this case was not a "justiciable cause" before the circuit court and was not properly before the Supreme Court.At issue in these consolidated cases was whether evolving standards of decency require that the Eighth Amendment prohibit imposition of the death penalty as to a defendant under twenty-one years old at the time of his offense. Defendants argued before the circuit court that the current national consensus and scientific research supported raising the age for death-penalty eligible from age eighteen to twenty-one. At this stage in the proceedings, none of the defendants had been convicted or sentenced. The circuit court declared Kentucky's death penalty statute unconstitutional under the Eighth Amendment insofar as it permits capital punishment for offenders under twenty-one years old at the time of their offense and that two of the defendants should not receive the death penalty. The Supreme Court vacated the interlocutory orders, holding that none of the defendants had standing to raise an Eighth Amendment challenge to the death penalty. View "Commonwealth v. Bredhold" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree sexual abuse, first-degree sodomy, and related crimes, and sentencing Defendant to seventy years in prison, holding that the trial court improperly admitted certain Ky. R. Evid. 404(b) evidence, but neither of those instances rose to the level of palpable error.Specifically, the Court held (1) the trial judge did not abuse his discretion in finding that Defendant failed to present sufficient evidence to merit an in camera review of the juvenile records of some of the alleged victims; (2) the trial court did not err in denying Defendant's motion for an independent evaluation and to continue the trial; (3) the trial court did not err by allowing two of the juvenile victims to testify in chambers and outside of Defendant's presence; and (4) there were two instances of improperly admitted Rule 404(b) evidence, but Defendant was not prejudiced by the admission of the evidence. View "Howard v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree rape and imposing a twenty-year term of imprisonment, holding that the trial court did not err by denying Defendant's motion for a directed verdict and by denying his motion to suppress his statements to police.Defendant's rape sentence was enhanced pursuant to the jury finding Defendant guilty of being a first-degree persistent felony offender (PFO 1), which was based on an out-of-state statutory rape conviction. Defendant filed a motion for a directed verdict on the PFO 1 charge asserting that the Commonwealth failed to prove Defendant committed a prior sex crime against a minor. The trial court denied the motion. The Supreme Court affirmed, holding (1) while it is better practice to introduce a minor victim's age into evidence as part of the PFO proof, "statutory rape" is commonly understood to be the offense of unlawful sexual intercourse with a minor, and therefore, the trial court did not err in denying Defendant's motion for a directed verdict on the PFO charge; and (2) the trial court did not err in denying Defendant's motion to suppress because Defendant's Fifth Amendment rights were not violated. View "Bullitt v. Commonwealth" on Justia Law