Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of trafficking in a controlled substance (heroin) in the first degree and of being a persistent felony offender in the first degree and sentencing him to twenty years in prison, holding that the circuit court did not err in the proceedings below.Specifically, the Supreme Court held that the circuit court (1) did not err by denying Defendant's pretrial motion to either suppress the evidence from an undercover drug buy or to dismiss the indictment for lack of jurisdiction; and (2) properly admitted into evidence better-quality copies of Snapchat messages than the ones provided to Defendant in discovery. View "Pope v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of murder and tampering with physical evidence and sentencing him to forty-three years' imprisonment, holding that the trial court erred in admitting two items of tangible evidence but that this error was not enough to warrant reversal.Specifically, the Supreme Court held (1) the trial court did not err in admitting evidence of Defendant's time fraud as motivation to murder; (2) admitting into evidence a red knife and latex gloves found in Defendant's truck was error, but those errors were harmless; (3) the trial court did not commit reversible error by denying a missing-evidence instruction; and (4) Defendant was not entitled to a new trial for cumulative error. View "Dooley v. Commonwealth" on Justia Law

The Supreme Court reversed the opinion of the court of appeals rejecting the trial court's conclusion that Defendant was not required to register under the Sex Offender Registration Act (SORA) but nevertheless affirming the judgment, holding that Defendant qualified for lifetime SORA registration for his crimes.Defendant pleaded guilty to three felony counts of distributing child pornography. At sentencing, the trial court found, in contrary to the Commonwealth's argument, that Defendant was not required to become a SORA registrant because his crimes were not sex crimes. The court of appeals affirmed, holding (1) SORA requires those who have committed crimes against minors, such as Defendant, to register; but (2) Defendant's three felony convictions exempted him from SORA because his convictions were each charged as first-offense crimes against a minor and all three convictions arose from a single course of conduct. The Supreme Court reversed, holding that Defendant must register under SORA for his lifetime because he was convicted of multiple offenses defined as a crime against a minor. View "Commonwealth v. Daughtery" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder, first-degree assault, and first-degree wanton endangerment of a child, holding that there was no prejudicial error in the proceedings below.Specifically, the Supreme Court held (1) the trial court did not abuse its discretion in denying requested instructions on extreme emotional disturbance and voluntary intoxication; (2) the prosecutor did not improperly reenact Defendant's theory of the shooting during the direct examination of the medical examiner; and (3) the trial court properly applied the law in denying Defendant's motion to suppress. View "Hargroves v. Commonwealth" on Justia Law

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

The Supreme Court affirmed the judgment of the trial court convicting Defendant of four counts of first-degree assault and other crimes and sentencing him as a first-degree persistent felony offender (PFO) to forty years' imprisonment, holding that any error was harmless.Specifically, the Supreme Court held that the trial court (1) did not err when it allowed into evidence a Facebook video from an anonymous tipster allegedly depicting the shooting; (2) did not commit palpable error when it allowed the testimony of Detective O'Daniel, who narrated surveillance video footage; (3) properly allowed Aleisha Courtney's prior identification of Defendant; (4) properly allowed another detective's prior identification of Defendant; (5) improperly excluded evidence of a civil suit by the victims against Defendant, but the error did not likely affect the outcome of the trial; (6) properly allowed Defendant's prior felony convictions at trial and at sentencing; and (7) properly allowed a summary sheet of Defendant's prior convictions that was prepared with certified records. Further, there was sufficient evidence of Defendant's prior felony convictions to support his conviction for possession of a handgun. View "Mattingly v. Commonwealth" on Justia Law

The Supreme Court reversed the opinion of the court of appeals vacating and remanding the circuit court's denial of Defendant's motion to modify the terms of his probation to remove a restriction prohibiting him from having access to the internet during his probationary period, holding that Defendant's failure to challenge the probation restriction prohibiting all access to the internet at the time the restriction was imposed was fatal to Defendant's request to relief.In vacating the probation restriction, the court of appeals concluded that the complete ban on internet access under the facts of this case was impermissibly vague and overly burdensome on Defendant's right to free speech. The Supreme Court reversed, holding that because Defendant did not object to the restriction, the court of appeals should not have entertained this challenge, and its decision on the merits was in error. View "Commonwealth v. Jennings" on Justia Law

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

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

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