Justia Criminal Law Opinion Summaries

The case concerns a man who was convicted of two counts of murder following the deaths of his aunt and cousin, who were found shot in the aunt’s home. The investigation revealed that the defendant had previously lived at the home, and evidence such as spent shell casings, a magazine, and drug paraphernalia was found at the scene and in his apartment. The defendant was located in California days after the murders, having left Kentucky and nearly emptied his bank account. He was apprehended and questioned by law enforcement, during which he made statements about the case.The Trigg Circuit Court conducted an eight-day trial, during which the defendant raised several objections. He challenged the inclusion of certain jurors for cause, the admission of evidence regarding prior drug use and related activities under Kentucky Rule of Evidence 404(b), and the admission of statements made after he referenced wanting a lawyer during police questioning. He also objected to the conduct of a law enforcement officer at trial, alleging that the officer’s nonverbal reactions could have influenced the jury. After the jury found him guilty and recommended life without parole, the trial court denied his motion for a new trial.On appeal, the Supreme Court of Kentucky reviewed each of the defendant’s claims. The court held that the trial court did not abuse its discretion in refusing to strike the challenged jurors for cause, admitting the contested 404(b) evidence, or admitting the defendant’s statements made before an unequivocal request for counsel. The court also found no abuse of discretion in denying a new trial based on the officer’s conduct, as there was insufficient proof of jury influence. The court further held that the cumulative error doctrine did not apply, as no individual errors were found. The judgment of the Trigg Circuit Court was affirmed. View "STINSON V. COMMONWEALTH OF KENTUCKY" on Justia Law

The case involved a violent confrontation between two former friends, Raiantez Shackles and Marvin Yarbrough, which escalated after a series of personal disputes, including threats and a romantic entanglement. On January 5, 2021, after a prior shooting incident involving their vehicles, Marvin and his wife Cassandra returned home from a funeral to find their residence under threat. Upon arrival, they were confronted by two armed men, and Shackles emerged from behind a tree, pointing a gun at them. A shootout ensued, resulting in both Marvin and Cassandra being shot, while their four children and Marvin’s brother were inside the home. The scene was chaotic, with multiple bullet holes found throughout the residence and a neighbor’s home.A jury in the Jefferson Circuit Court convicted Shackles of two counts of first-degree assault, six counts of first-degree wanton endangerment, possession of a handgun by a felon, and being a first-degree persistent felony offender. The jury recommended a sixty-year sentence, which the trial court reduced to forty-five years under Kentucky law. Shackles appealed, raising several claims of error regarding jury instructions, evidentiary rulings, and the conduct of the sentencing phase.The Supreme Court of Kentucky reviewed the case and affirmed the trial court’s judgment. The Court held that the trial court did not abuse its discretion in declining to give a self-defense instruction, as there was no evidence that Marvin used unlawful force. The Court found that while the admission of certain hearsay evidence was erroneous, it was harmless given the other evidence presented. The Court also upheld the admission of body camera footage and crime scene photographs, denied the directed verdict motions on the wanton endangerment charges, and found no manifest injustice in the jury polling or the admission of victim impact testimony. The judgment of conviction and sentence was affirmed. View "SHACKLES V. COMMONWEALTH OF KENTUCKY" on Justia Law

A police officer observed an individual walking in the middle of a street at night near a location known for drug activity. The officer, believing this to be a violation of Kentucky’s jaywalking statute, attempted to stop the individual by asking him to approach the patrol car. The individual ignored the officer’s verbal commands, turned away, and increased his pace. The officer then physically seized the individual by grabbing his arms and escorted him back to the patrol car. During this process, the officer observed the individual discard drugs, which led to his arrest. Additional drugs were found in the individual’s possession after the arrest.The Nelson Circuit Court held a suppression hearing, during which the officer and the defendant’s mother testified. The court found that the officer had probable cause to believe a jaywalking violation had occurred and concluded that the officer’s actions were justified. The court denied the motion to suppress the drug evidence. The defendant subsequently entered a conditional guilty plea to amended charges, reserving the right to appeal the suppression ruling. The Kentucky Court of Appeals affirmed the circuit court’s decision, reasoning that an officer may detain a pedestrian for a traffic law violation to issue a citation, and distinguished the case from prior precedent involving different circumstances.The Supreme Court of Kentucky reviewed the case and affirmed the lower courts’ decisions. The court held that the Fourth Amendment is not violated when police physically seize a person for an observed violation, such as jaywalking, for the purpose of issuing a citation if the person fails to comply with verbal commands. The court found the officer’s use of minimal force to be objectively reasonable under the circumstances and concluded that the subsequent discovery of contraband was not the result of an unreasonable search or seizure. The denial of the motion to suppress and the convictions were affirmed. View "BUECHELE V. COMMONWEALTH OF KENTUCKY" on Justia Law

The case concerns Isaiah Brown, who, along with Rayshawn Tucker and Fatima Alabusalim, was implicated in the murder and first-degree robbery of DaMani Dulaney in Louisville, Kentucky. Alabusalim, who had relationships with both Tucker and Dulaney, testified that Tucker was upset about her relationship with Dulaney and devised a plan to rob him, enlisting her and Brown’s help. On the night of the incident, Alabusalim lured Dulaney to a park, where Tucker and Brown confronted him. Brown broke the driver’s side window with a gun, and after Alabusalim was pulled from the car, a single gunshot was fired, resulting in Dulaney’s death. The trio fled to Florida after the crime. Evidence included text messages, cell site data, and testimony from Alabusalim, who initially gave false statements to police but later admitted her involvement.The Jefferson Circuit Court tried Brown alone after his co-defendants entered plea agreements. The jury found Brown guilty of murder (complicity) and first-degree robbery (complicity), recommending concurrent sentences of twenty-two years for murder and ten years for robbery. The court sentenced Brown accordingly. Brown appealed, raising issues about the admission of certain evidence, including hearsay regarding phone number attribution, the foundation for text messages, improper opinion testimony by a detective, the admission of co-conspirator statements, and cumulative error.The Supreme Court of Kentucky reviewed the case and affirmed the convictions. The court held that while the trial court erred in admitting hearsay evidence identifying Brown’s phone number and in allowing improper opinion testimony about a witness’s credibility, these errors were harmless or did not result in manifest injustice. The court found that the text messages were properly authenticated and that the co-conspirator exception to the hearsay rule was satisfied. The cumulative effect of the errors did not render the trial fundamentally unfair. View "BROWN V. COMMONWEALTH OF KENTUCKY" on Justia Law

Darrell Strunk participated in two robberies on the same day in December 2011: first, a home invasion, and then a business robbery. He was indicted for the business robbery, and later, with his consent, additional charges from the home robbery were added. Strunk entered a plea agreement, pleading guilty to two counts of second-degree robbery, each enhanced by his status as a second-degree persistent felony offender. The agreement called for consecutive sentences of 20 years and 10 years, totaling 30 years’ imprisonment.The Fayette Circuit Court accepted the plea and imposed the 30-year sentence, despite Strunk’s counsel raising concerns that this exceeded the statutory maximum under KRS 532.110(1)(c), which limits the aggregate sentence for Class C felonies to 20 years. Strunk later filed a motion under CR 60.02 to correct his sentence, arguing it was illegal. The trial court denied the motion, reasoning that the plea agreement treated the two robberies as separate cases and that Strunk had knowingly accepted the deal. On appeal, the Kentucky Court of Appeals reversed, holding that the 30-year sentence violated the statutory cap and that the statutory limit could not be waived, remanding for resentencing within the legal maximum.The Supreme Court of Kentucky reviewed the case and affirmed the Court of Appeals. The Court held that Strunk’s aggregate sentence of 30 years was illegal under KRS 532.110(1)(c), as the statutory maximum for his offenses was 20 years. The Court further held that, because Strunk sought only correction of his sentence and not withdrawal of his guilty plea, the proper remedy was to remand for resentencing with instructions to impose the highest legal sentence—20 years’ imprisonment. View "COMMONWEALTH OF KENTUCKY V. STRUNK" on Justia Law

On the night of June 23, 2019, a group of minors, including the defendant, traveled around Louisville discussing a planned burglary. Later that evening, two minors, J.M. and R.O., were shot and killed, while a third, S.H., survived her wounds. S.H. testified that the defendant shot her and R.O. after the group had driven to various locations and after an incident involving J.M. in an alley. The defendant was indicted for the murders of J.M. and R.O. and for the first-degree assault of S.H. He did not testify at trial.The Jefferson Circuit Court conducted a jury trial in which the defendant was convicted of the murder of R.O. and the first-degree assault of S.H., but acquitted of the murder of J.M. The jury recommended a life sentence for the murder conviction and a consecutive twenty-year sentence for the assault conviction, which the trial court reduced to life in prison. The defendant appealed, raising several claims, including challenges to the admission of cell phone location evidence, the handling of prospective and seated jurors, and the admission of a recorded jail call.The Supreme Court of Kentucky reviewed the case as a matter of right. The Court held that the trial court did not err in permitting a detective to testify about cell phone location data, finding that the detective’s testimony, though based on specialized training, was sufficiently disclosed and did not require exclusion or a Daubert hearing since the defense did not challenge the methodology’s reliability. The Court also found no abuse of discretion in the trial court’s decisions regarding juror challenges and the admission of the jail call, concluding that there was no evidence of juror bias or prejudice and that the recorded call was properly admitted for the jury’s consideration. The Supreme Court of Kentucky affirmed the convictions and sentence. View "HOLLINGSWORTH V. COMMONWEALTH OF KENTUCKY" on Justia Law

Bobby Ray Osborne entered a conditional guilty plea to first-degree trafficking in a controlled substance and possession of drug paraphernalia, receiving a five-year prison sentence. The case arose when officers, acting on a tip about a stolen trailer, visited Osborne's property. Osborne consented to a search, during which he was found with a baggie containing a brown substance believed to be heroin and a large amount of cash. The officers did not find the stolen trailer but obtained a search warrant for Osborne's residence, yielding additional evidence.The Estill Circuit Court denied Osborne's motion to suppress the heroin and cash, finding that he voluntarily consented to the search. Osborne's subsequent motions to reconsider were also denied. He then entered a conditional guilty plea, reserving the right to appeal the suppression ruling. The Kentucky Court of Appeals affirmed the trial court's decision.The Supreme Court of Kentucky reviewed the case to clarify the distinction between a consensual encounter and an investigative detention under the Fourth Amendment. The court affirmed the lower courts' rulings, holding that Osborne voluntarily consented to the search. The court found that the officers' actions did not convert the consensual encounter into an investigative detention. The court also upheld the application of the plain view doctrine, determining that the incriminating nature of the baggie was immediately apparent once Osborne removed it from his pocket. The court concluded that the trial court's findings were supported by substantial evidence and that additional findings were unnecessary. View "Osborne v. Commonwealth" on Justia Law

James Lynch was stopped in April 2022 under suspicion of driving under the influence and was subjected to five standardized field sobriety tests, including the horizontal gaze nystagmus (HGN) test. Lynch showed signs of impairment and was arrested and charged with DUI. In February 2023, Lynch moved to exclude the HGN test evidence, arguing it was unreliable without expert testimony. The Gallatin District Court agreed, requiring expert testimony for the HGN test and excluding it from evidence.The Commonwealth sought a writ of prohibition from the Gallatin Circuit Court to prevent the exclusion of the HGN test. The circuit court denied the writ, finding that the Commonwealth did not demonstrate great injustice or irreparable injury, as other evidence from the sobriety tests and officer observations could still be used. The Commonwealth appealed to the Court of Appeals, which reversed the circuit court's decision, holding that the exclusion of the HGN test constituted irreparable injury and that the test was admissible without expert testimony if properly administered by a trained officer.The Supreme Court of Kentucky reviewed the case and reversed the Court of Appeals' decision. The Supreme Court held that the Commonwealth failed to demonstrate great injustice or irreparable injury, as required for a writ of prohibition. The court emphasized that the remaining evidence was sufficient for prosecution and that the exclusion of the HGN test did not cause incalculable damage. The case was remanded to the Gallatin Circuit Court to reinstate the order denying the Commonwealth's petition for a writ of prohibition. View "Lynch v. Commonwealth" on Justia Law

Jeremy Mills was convicted in Allen Circuit Court for multiple offenses, including Unlawful Transaction with a Minor, Possession of Matter Portraying Sexual Performance by a Minor, and being a Persistent Felony Offender. Mills met the victim, A.C., through Facebook, where she initially claimed to be eighteen. They met in person, used drugs, and engaged in sexual activities, which Mills recorded. A.C. later revealed she was thirteen. Mills was sentenced to twenty years in prison.The Allen Circuit Court jury acquitted Mills of rape, strangulation, and kidnapping charges but convicted him on other counts. Mills argued that he never knew A.C. was underage, a claim contradicted by A.C. and Edward Troutt, a fellow inmate who testified that Mills confessed to knowing A.C.'s true age. Mills contended that Troutt fabricated the confession after accessing his case file.The Supreme Court of Kentucky reviewed the case, focusing on Mills' claim of a Brady violation due to the Commonwealth's failure to disclose a video interview with Troutt. The Court found that the video, which contained inconsistencies with Troutt's trial testimony, was favorable impeachment evidence. The trial court's failure to disclose this evidence and its refusal to recall Troutt for cross-examination constituted a Brady violation. The Supreme Court held that this violation undermined confidence in the verdict, warranting a reversal of Mills' convictions and a remand for further proceedings. View "Mills v. Commonwealth" on Justia Law

David Young was convicted by a jury in the Lewis Circuit Court of wanton murder, two counts of first-degree assault, and DUI with aggravating circumstances. The incident occurred on May 18, 2020, when Young, after consuming several beers, lost control of his vehicle in heavy rain, crossed the centerline, and collided head-on with a car driven by Jessica Tumlin, resulting in her death and serious injuries to two minor passengers, C.C. and B.M. Young's blood alcohol content was found to be 0.156 nearly three hours after the collision.The trial court denied Young's motion for a directed verdict on the murder charge, and he was convicted on all counts, receiving a sentence of twenty-five years' imprisonment. Young appealed, raising several issues, including the sufficiency of evidence for the murder charge, exclusion of a defense witness, limitations on discussing DUI per se law, sufficiency of evidence for serious physical injury to B.M., and a double jeopardy claim regarding the DUI and murder charges.The Supreme Court of Kentucky affirmed the murder and assault convictions but found a double jeopardy violation with the DUI conviction. The court held that the DUI conviction should be vacated because the elements required to prove DUI were subsumed within the wanton murder charge, thus violating double jeopardy principles. The case was remanded for entry of a new judgment consistent with this finding. View "Young v. Commonwealth" on Justia Law