Justia Criminal Law Opinion Summaries

In a case involving Steven Roark who was convicted of manufacturing methamphetamine, possession of methamphetamine, and tampering with physical evidence, the Supreme Court of Kentucky reversed the decision of the Court of Appeals, which had held that the jury instruction for manufacturing methamphetamine violated Roark's right to a unanimous verdict. In the case, the police had found Roark in a trailer with an active methamphetamine lab, along with multiple items used in the manufacture of methamphetamine. The jury instructions allowed for a conviction based on either of two theories under Kentucky Revised Statute (KRS) 218A.1432 - either that Roark knowingly manufactured methamphetamine, or that he knowingly possessed two or more items of equipment or chemicals with the intent to manufacture methamphetamine. Roark argued that such instruction violated his right to a unanimous verdict. However, the Supreme Court of Kentucky found no error in the jury instruction, concluding that both theories were supported by the evidence presented at trial, and thus did not violate Roark's right to a unanimous verdict. The court thereby affirmed the judgment and sentence of the trial court as to Roark’s manufacturing conviction. View "Commonwealth v. Roark" on Justia Law

In the case at hand, Jose Sanchez was convicted of five counts of first-degree rape and four counts of third-degree rape. The Supreme Court of Kentucky affirmed these convictions, holding that the text messages and videos were properly authenticated. The court also found that Sanchez was not entitled to a missing evidence instruction regarding his cellphone, as the data extracted from it was preserved, and the phone itself contained no evidence. However, the court reversed and vacated the trial court's imposition of public defender fees against Sanchez, ruling that the imposition of public defender fees was an error as the trial court failed to hold a hearing and determine that Sanchez should not continue to be considered an indigent person. The court also held that the cumulative error did not occur in this case. View "SANCHEZ V. COMMONWEALTH" on Justia Law

In the case before the Supreme Court of Kentucky, the defendant, Gregory Stephens, was convicted of first-degree rape and being a persistent felony offender in the second-degree. The conviction was based on the testimony of the child victim, Amy, and was supported by the testimony of additional witnesses who recounted Amy's prior hearsay statements and vouched for her credibility. Stephens appealed, arguing that the inclusion of these hearsay statements and credibility endorsements rendered his trial fundamentally unfair. The Supreme Court of Kentucky agreed, reversing and remanding the case.The court found that the evidence against Stephens consisted entirely of Amy's statements. There was no physical evidence, and the only other possible witness, Amy's mother, did not testify. The court held that the prosecution was erroneously allowed to elicit testimony from additional witnesses to bolster Amy's testimony, amounting to palpable error. Furthermore, the court found that multiple witnesses were improperly allowed to vouch for Amy's credibility.The court also noted that the deputy jailer's testimony about the impact of the rape on Amy during the guilt phase was improperly admitted. The court stated that such victim impact evidence is not permissible during the guilt phase of the trial.The court concluded that the combined errors of hearsay bolstering, vouching testimony, and victim impact testimony rendered the trial fundamentally unfair and demanded a reversal of the conviction. The case was remanded for a new trial. View "STEPHENS V. COMMONWEALTH" on Justia Law

The Supreme Court of Kentucky affirmed the convictions of Jaikorian J. Johnson for second-degree manslaughter and four counts of first-degree wanton endangerment but reversed the sentence and remanded for a new penalty phase due to palpable error in the victim impact statement. Johnson was convicted for shooting dead one person and injuring another, arguing self-defense. On appeal, Johnson raised three issues: the exclusion of two witnesses' testimony regarding the victim's alleged criminal scheme at the time of shooting; the failure to direct verdicts on all four counts of wanton endangerment; and the impropriety and prejudicial nature of the victim impact statement. The court held that the exclusion of character evidence of the victim was not an abuse of discretion because it was irrelevant and inadmissible under KRS 404(b). The court also held that the directed verdicts for the four counts of wanton endangerment were justified because substantial danger existed for the people in the vicinity when Johnson fired his gun. However, the court found palpable error in the victim's mother's impact statement, which included biblical references urging the death penalty and unproven accusations of witness intimidation, thereby seriously affecting the fairness of the proceedings. View "JOHNSON V. COMMONWEALTH" on Justia Law

The Supreme Court of Kentucky upheld the conviction of Eric Berry, who was found guilty of first-degree burglary, first-degree sexual assault, two counts of fourth-degree assault, first-degree fleeing or evading, and resisting arrest. The court rejected Berry's appeal that his right to a speedy trial was violated, arguing that delays in his trial were due to valid reasons such as Berry's own actions, the COVID-19 pandemic, and personal reasons of his attorneys. The court also denied Berry's argument that the trial court erred in not giving an intoxication defense instruction, stating that while Berry was intoxicated during the incident, he clearly knew what he was doing and acted deliberately. The court further dismissed Berry's claim that his former testimony from a domestic violence hearing should have been allowed, as the Commonwealth did not have an opportunity to cross-examine him during that hearing. Additionally, the court found no error in the joinder of the April and December incidents for the trial, as Berry failed to demonstrate actual prejudice from the record. Lastly, the court rejected Berry's claim for cumulative error, as they found no error in the other arguments presented. View "BERRY V. COMMONWEALTH" on Justia Law

Three sisters, Danielle, Angela, and Alyssa, were placed in the custody of their aunt, Kathy Riggle, and her husband, William Kenneth Riggle Sr. (Senior) in 2009 due to their parents' struggles with drug abuse. For the eight years they lived with the Riggles, the sisters alleged that they were sexually abused by Senior and his son, William Kenneth Riggle Jr. (Junior). The abuse was reported in 2017 after the girls were returned to the custody of their mother. Senior was charged with and convicted of multiple counts of sodomy in the first degree, sexual abuse in the first degree, and intimidating a participant in the legal process. The trial court imposed a 70-year sentence in line with Kentucky law. Senior appealed, raising four allegations of error.The Supreme Court of Kentucky found no reversible error and affirmed the convictions. It held that the trial court correctly admitted testimony from two other minor girls who had experienced inappropriate sexual conduct from Senior, as this evidence demonstrated a pattern of conduct and was not merely proof of propensity. The Court also ruled that the testimony from Angela's school counselor was admissible for rehabilitative purposes, as it was offered to explain an inconsistency in Angela's testimony, not to verify the truth of her allegations. The Court further held that any issues with jury instructions regarding unanimity did not rise to palpable error, given the overwhelming weight of evidence against Senior. Finally, the Court found that the trial court did not err in failing to direct a verdict of acquittal on certain counts, as the Commonwealth had produced more than a mere scintilla of evidence to support the charges. View "RIGGLE V. COMMONWEALTH" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree rape, first-degree sexual abuse, intimidating a participant in a legal process, and being a first-degree persistent felony offender and his sentence of twenty years' imprisonment, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) the Commonwealth did not improperly comment on Defendant's right to remain silence during voir dire or deprive him of an impartial jury by making a burden-shifting argument to the venire should Defendant have chosen to testify; (2) the trial court did not err by denying Defendant's motion to strike two jurors for cause; and (3) no cumulative error occurred because no prejudicial error occurred. View "Finch v. Commonwealth" on Justia Law

The Supreme Court affirmed in part and reversed in part the opinion of the court of appeals concluding that the sentence Defendant negotiated upon a plea of guilty and instituted by the trial court was illegal, and therefore his probation revocation was also illegal, holding that the court of appeals erred in concluding that an illegal probation mandated release of Defendant from custody.After Defendant entered into supervised probation according to his plea deal the Commonwealth sought to revoke his probation. Defendant responded that the sentence for probation after serving his prison term was illegal. After a hearing, the trial court concluded that it could not alter the sentence and revoked Defendant's probation based on the testimony of Defendant's probation officer. The court of appeals reversed, declaring the probation revocation unlawful. The Supreme Court remanded the case for resentencing, holding that the court of appeals (1) properly concluded that the simultaneous imposition of ten years' incarceration and ten years' probation subsequent to incarceration was illegal; and (2) with Defendant's underlying conviction and sentence of imprisonment being lawful, the remedy for an illegal order of probation is to remand for resentencing. View "Commonwealth v. Moreland" on Justia Law

The Supreme Court affirmed Defendant's conviction of murder and tampering with a witness and his sentence of life imprisonment, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the jury instructions did not yield a verdict that violated the unanimous verdict requirement, and the trial court properly denied Defendant's motion for a mistrial; (2) the opinion testimony of two police officers did not constitute palpable error; (3) testimony regarding parole eligibility and meritorious good time credit did not render the trial fundamentally unfair; and (4) the Commonwealth's comments during the penalty phase's closing argument did not constitute palpable error. View "James v. Commonwealth" on Justia Law

The Supreme Court reversed Defendant's convictions of rape in the first-degree, victim under twelve; sodomy in the first-degree, victim under twelve; sexual abuse in the first-degree, victim under twelve; and incest, holding that Juror A.R. should have been struck for cause.During voir dire, when the Commonwealth asked the venire if anyone was uncomfortable with pornography, Juror A.R. made a physical indication. During a colloquy, the trial court asked several times if Juror A.R. could be fair and impartial. After one final time of asking whether Juror A.R. could remain fair and impartial, Juror A.R. affirmed that she could. The Supreme Court reversed Defendant's convictions and remanded the case for further proceedings, holding that, under the circumstances of this case, the trial court's failure to strike Juror A.R. for cause was an abuse of discretion. View "Moulder v. Commonwealth" on Justia Law