Justia Civil Rights Opinion Summaries
Articles Posted in Kentucky Supreme Court
Brafman v. Commonwealth
The Supreme Court reversed Defendant's conviction of first-degree and second-degree arson and six counts of attempted murder, of which four were charged as hate crimes, holding that Defendant was denied a fair trial when the Commonwealth, aware of Defendant's intoxication during her arrest, opposed the intoxication defense instructions and implied to the jury that Defendant was not intoxicated.On appeal, Defendant argued that six trial errors required reversal, either individually or cumulatively. The Supreme Court held that the prosecutorial misconduct was flagrant enough to render the trial fundamentally unfair, simultaneously leading the jury to conclude facts contrary to the known facts and depriving Defendant of an ability to present her defense. The Court held that this one error was enough to require reversal but also addressed Defendant's remaining allegations of error, concluding that there were multiple errors in this case. View "Brafman v. Commonwealth" on Justia Law
Exantus v. Commonwealth
The Supreme Court affirmed Defendant's sentence of twenty years' imprisonment and convictions of not guilty by reason of insanity for first-degree murder, not guilty by reason of insanity for first-degree burglary, guilty but mentally ill of two counts of second-degree assault and guilty but mentally ill of fourth-degree assault, holding that any error was not prejudicial.Specifically, the Supreme Court held (1) the jury’s verdicts were not impermissibly inconsistent; (2) the trial court did not err by failing to grant Defendant's motions for directed verdict; (3) the trial court did not abuse its discretion by failing to provide lesser-included offense instructions to the jury; (4) the trial court's failure to provide the jury with the definition of "dangerous instrument" was harmless error; (5) the trial court did not abuse its discretion by denying Defendant's motion to strike two jurors for cause; and (6) the trial court erred by not making the requisite statutory findings under Ky. Rev. Stat. 703 before admitting prior bad act evidence, but the error was harmless. View "Exantus v. Commonwealth" on Justia Law
Downs v. Commonwealth
The Supreme Court reversed Defendant's convictions for first-degree manslaughter, tampering with physical evidence, possession of a handgun by a convicted felon, and second-degree persistent felony offender, holding that Defendant was deprived of his right to counsel at a critical stage of the proceedings.On appeal, Defendant argued that he was denied the right to conflict-free counsel at a critical stage of the proceedings - during an in-chambers hearing the trial court conducted on the fitness and ability of Defendant's private attorney. The Supreme Court agreed, holding that the court's decision not to inform Defendant of the Commonwealth's allegations against his private attorney and not offer him the opportunity to retain independent counsel to represent his interests was of constitutional magnitude. View "Downs v. Commonwealth" on Justia Law
Rhoton v. Commonwealth
The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's drug-related convictions, holding that the circuit court did not err in denying Defendant's motion to suppress.After he was arrested and indicted, Defendant moved to suppress the evidence seized during a traffic stop, arguing that the law enforcement officer impermissibly prolonged the stop to facilitate a dog sniff search. The trial court denied the request. The court of appeals affirmed. The Supreme Court affirmed, holding that the actions taken to facilitate the arrest of Defendant's passenger did not impermissibly extend his traffic stop, and therefore, the trial court correctly denied Defendant's motion to suppress the evidence resulting from the subsequent use of the narcotics dog. View "Rhoton v. Commonwealth" on Justia Law
Commonwealth v. Mitchell
The Supreme Court affirmed in part and reversed in part the decision of the court of appeals reversing Defendant's conviction for being a convicted felon in possession of a handgun on the grounds that the trial court erred in denying Defendant's motion to suppress, holding that the court of appeals erred in concluding that the Commonwealth's reasonable suspicion argument was precluded.In his motion to suppress, Defendant argued that the traffic stop in the case was impermissibly prolonged beyond its original purpose and violated his Fourth Amendment rights. The trial court denied the motion without addressing whether the officers had independent reasonable suspicion to extend the stop. The court of appeals reversed, concluding (1) the officers deferred completion of the stop beyond its original purpose for a purpose totally unrelated to the original stop; and (2) the Commonwealth was precluded from arguing reasonable suspicion of criminal activity as a justification for the extension. The Supreme Court reversed in part, holding that the court of appeals (1) correctly held that Defendant's stop was impermissibly extended; but (2) erred in concluding that the Commonwealth's reasonable suspicion argument was precluded. The Court remanded the case to the trial court for additional factual findings and conclusions of law as to the officers' reasonable suspicion. View "Commonwealth v. Mitchell" on Justia Law
Hubers v. Commonwealth
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
Louisville & Jefferson County Metropolitan Sewer District
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
Taylor v. Commonwealth
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
Downs v. Commonwealth
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
Carlisle v. Commonwealth
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