Justia Criminal Law Opinion Summaries

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

The Supreme Court vacated the judgment of the circuit court sentencing Defendant to life in prison plus fifty years, holding that the violent offender statute is not applicable to youthful offenders for purposes of consideration of probation, even if they are sentenced after they have reached the age of majority.Defendant committed the crimes for which he was convicted when he was seventeen years old. The district court transferred the charges to circuit court for Defendant's prosecution as a youthful offender. Defendant was nineteen years old when he pleaded guilty pursuant to plea agreements to murder, first-degree robbery, and other crimes. Under the assumption that Defendant was ineligible for probation, the trial court imposed a life sentence with a fifty-year sentence to run consecutively. The Supreme Court vacated the judgment, holding (1) Kentucky's Juvenile Code and relevant caselaw support the conclusion that the violent offender statute is not applicable to youthful offenders for purposes of consideration of probation, even if they are sentenced after they reach the age of eighteen years and five months; and (2) the trial court erred in failing to consider probation or other forms of conditional discharge as possible alternatives. View "Thomas 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 Defendant's convictions for one count of murder and one count of possession of a firearm by a convicted felon, holding that the trial court did not err by failing to give the jury a no duty to retreat instruction and by failing to strike two jurors for cause.A jury convicted Defendant of murder and being a convicted felon in possession of a firearm. Defendant was found to be a first-degree persistent felony offender and was sentenced to life imprisonment. The Supreme Court affirmed, holding (1) the trial court did not err by denying Defendant's request for a "no duty to retreat" jury instruction; and (2) the trial court did not err by failing to strike two jurors, Juror 5 and Juror 50, for cause. View "Curry 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