Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals reversing the ruling of the trial court denying Defendant's motion to classify him as a domestic violence victim pursuant to Ky. Rev. Stat. 439.3401(5), holding that the evidence was sufficient to satisfy Defendant's burden of proving by a preponderance of the evidence that he was a victim of domestic violence.Defendant pleaded guilty to manslaughter in the first degree for the death of his wife. Defendant moved the trial court to classify him as a domestic violence victim, which would reduce his parole eligibility from eighty-five percent of his sentence to twenty percent of his sentence. The trial court denied the motion, but the court of appeals reversed, concluding that Defendant successfully connected the physical and verbal domestic violence he experienced to the crime he committed. The Supreme Court affirmed, holding that Defendant proved that he was a victim of domestic violence in regard to the manslaughter of his wife. View "Commonwealth v. Crowe" on Justia Law

The Supreme Court affirmed Defendant's conviction and sixty-five-year sentence for attempted murder, first-degree robbery, and other crimes, holding that the trial court did to err by denying two of Defendant's directed verdict motions and that there was no error in Defendant's sentencing phase.On appeal, Defendant argued that the trial court committed reversible error when it denied his directed verdict motions for first-degree robbery and first-degree wanton endangerment and that his sentencing phase was unfairly tainted by incorrect information regarding parole eligibility. The Supreme Court affirmed, holding (1) this Court overrules precedent requiring defendants to comply with the "second rule" of preservation; (2) in order to preserve an alleged directed verdict issue for appeal, criminal defendants must move for a directed verdict at the close of the Commonwealth's evidence and renew the directed verdict motion at the close of all evidence; (3) the trial court did not err by denying Defendant's motions for directed verdict; (4) even though testimony by the Commonwealth's sole witness in the sentencing phase regarding first-degree wanton endangerment was clearly false, the error was not palpable; and (5) the Commonwealth's misstatement of parole eligibility during its closing argument did not constitute manifest injustice resulting in palpable error. View "Ray v. Commonwealth" on Justia Law

The Supreme Court affirmed the order of the trial court denying Defendant's motion for DNA testing with respect to hair found at the residence of the victims whom Defendant was convicted of murdering, burglarizing, and robbing, holding that the trial court did not err.Defendant was convicted of murder and sentenced to death. This appeal concerned Defendant's motion seeking DNA testing of hair that was found in the victims' home. The trial court denied the motion. The Supreme Court affirmed after noting that Defendant's DNA arguments have been raised and rejected by both the Supreme Court and the federal courts, holding that no reasonable probability existed that the DNA testing and analysis would produce exculpatory evidence. View "Hodge v. Commonwealth" on Justia Law

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

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of wanton murder and four counts of first-degree wanton endangerment, holding that the trial court did not err in denying Defendant's motion for a directed verdict.On appeal, Defendant argued that the trial court erroneously denied his motions for a directed verdict on the wanton murder and wanton endangerment charges because the evidence was insufficient to establish "aggravated wantonness" and to prove that his conduct caused the victim's death. The Supreme Court affirmed, holding that the Commonwealth met its burden of persuasion, and therefore, the trial court did not err by denying Defendant's motion for a directed verdict of acquittal on the charges. View "Taylor v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the circuit court's denial of Appellant's petition to declare his violent offender classification unconstitutional, holding that a defendant convicted of robbery in the first degree qualifies as a violent offender pursuant to Ky. Rev. Stat. 439.3401(1) regardless of whether the victim suffered serious physical injury or death and regardless of whether the trial court's judgment addresses the victim's status.Appellant was convicted of twelve counts of first-degree robbery and was classified as a violent offender. The circuit court did not state in its judgment that any of Appellant's victims suffered serious physical injury or death. Appellant filed a petition seeking to declare her violent offender classification unconstitutional. The lower courts denied the petition. The Supreme Court affirmed, holding (1) Benet v. Commonwealth, 253 S.W.3d 528 (Ky. 2008) correctly interprets the requirements of section 439.3401(1) for violent offender status; and (2) the portion of Pate v. Department of Corrections, 466 S.W.3d 480 (Ky. 2015), that is inconsistent with Benet is overruled. View "Lee v. Kentucky Department of Corrections" on Justia Law

The Supreme Court reversed Defendant's conviction of second-degree manslaughter by complicity, holding that the trial court committed reversible error when it allowed the Commonwealth to present a thirty-five-minute video of a police interview with Defendant in which Defendant was shown handcuffed and wearing an inmate's orange jumpsuit.After Defendant was arrested, an Assistant Commonwealth's Attorney and the lead homicide detective met Defendant and his attorney at the jail. They recorded their questioning of him, and throughout the interview, Defendant was handcuffed and wore an orange jumpsuit. During trial, the court allowed the Commonwealth to display the video version of the recording to the jury. The court of appeals affirmed Defendant's conviction, concluding that any error in admitting the video was harmless. The Supreme Court reversed, holding that, while the video was not "inherently prejudicial," the video prejudiced Defendant, and the Commonwealth did not satisfy its burden of demonstrating beyond a reasonable doubt that the video did not impact the verdict. View "Deal v. Commonwealth" on Justia Law

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 the judgment of the circuit court convicting Defendant of attempted murder and theft by unlawful taking of a firearm, holding that the trial court did not err in instructing the jury and denying Defendant's motion for directed verdict.A jury found Defendant guilty of attempted murder and theft by unlawful taking of a firearm. Consistent with the jury's recommendation, the trial court sentenced Defendant to a total sentence of twenty years. The Supreme Court affirmed, holding (1) the trial court did not err by declining Defendant's request for a renunciation instruction; and (2) the trial court did not err by denying Defendant's motion for directed verdict on the charge of theft by unlawful taking of a firearm. View "Bowen v. Commonwealth" 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