Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the trial court convicting Defendant of complicity to kidnapping, complicity to first-degree assault, and complicity to theft by unlawful taking and sentencing Defendant to twenty years’ imprisonment, holding that there was no reversible error in the proceedings below.Specifically, the Court held that (1) the trial court did not abuse its discretion when denying Defendant’s motions for continuances; and (2) the trial court did not abuse its discretion by denying Defendant's motions for directed verdict on his charges. View "McCoy v. Commonwealth" on Justia Law

The Supreme Court held that the Kentucky Parole Board’s revocation hearing in this case was an adjudicative function, a discretionary act for which the Parole Board enjoyed absolute immunity from liability for its decisions whether to grant, deny, or revoke parole.Phyllis Roach was sentenced to ten years’ imprisonment with a three-year conditional discharge period after she pled guilty to sodomy in the first degree. After she was released, Roach was charged with violating the terms of her postincarceration supervision. At a parole revocation hearing, the Parole Board sentenced Roach to serve fourteen months, the remainder of her conditional discharge period. Roach filed a complaint with the Board of Claims seeking damages for her “wrongful incarceration.” The Board of Claims rejected her claims. The circuit court reversed, finding that the Parole Board was grossly negligent in applying an unconstitutional sentence. The Court of Appeals reversed. The Supreme Court affirmed, holding that the Board’s adjudication of Roach’s rights as to whether she violated her postincarceration release requirements was a quasi-adjudicative function and therefore a discretionary act for which the Board enjoyed absolute immunity. View "Roach v. Kentucky Parole Board" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of the murder of his four-month-old son and his sentence of life imprisonment, holding that there was no reversible error in the proceedings below.Defendant was convicted after a jury trial. The Supreme Court affirmed the conviction and sentence, holding (1) the jury instructions did not violate Defendant’s right to a unanimous jury verdict; and (2) the trial court did not commit reversible error when it admitted certain evidence of text messages under Ky. R. Evid. 404(b) and 403. View "Cox v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of two counts of trafficking in a controlled substance in the first degree and other drug-related offenses and his sentence of twenty years’ imprisonment, holding that there was no reversible error in this case.Specifically, the Court held (1) the Commonwealth violated the notice requirement set forth in Ky. Rev. Stat. 508 by waiting until forty hours prior to trial to disclose a confidential informant’s identity, but the late disclosure did not compel a new trial; (2) Defendant’s claims of error with respect to the complicity to trafficking in a controlled substance in the first degree conviction were unavailing; (3) the parole officer’s “good time” credit testimony presented during the penalty phase of trial did not violate Defendant’s right to due process; and (4) the prosecutor’s closing argument during the penalty phase did not amount to flagrant misconduct. View "Little v. Commonwealth" on Justia Law

The Supreme Court affirmed the holdings of the circuit court and court of appeals determining that public defenders, as employees of the Department of Public Advocacy (DPA), a statutorily-created agency of the Commonwealth, are entitled to assert the defense of qualified immunity within the proper context.After he was discharged from custody, Plaintiff filed a malpractice action against his former attorney, alleging that as a result of Defendants negligent advice regarding parole eligibility, Plaintiff had served longer in prison than he expected when entering his guilty plea. The circuit court granted Defendant’s motion to dismiss, finding that Defendant was entitled to qualified official immunity from suit as an employee of the DPA. The Supreme Court affirmed, holding (1) public defenders performing discretionary tasks in good faith and within the scope of their employment are entitled to assert qualified immunity to any negligence claim; and (2) Defendant was entitled to the defense of qualified immunity under the circumstances of this case. View "Jacobi v. Holbert" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing Defendant’s convictions for possession of a controlled substance, first degree, first offense, and for tampering with physical evidence, holding that traffic stop in this case was unreasonably prolonged, and therefore, the incriminating evidence must be suppressed.Defendant’s convictions were based on evidence discovered after a canine sniff search of Defendant’s vehicle conducted during a traffic stop. The court of appeals concluded that the sniff search prolonged the traffic stop and that the incriminating evidence should have been suppressed. The Supreme Court affirmed, holding that the free air sniff of Defendant’s vehicle impermissibly extended the duration of the stop. View "Commonwealth v. Lane" on Justia Law

The Supreme Court affirmed Appellant’s conviction of first-degree trafficking in a controlled substance, felony possession of a firearm, and being a first-degree persistent felony offender and sentence of twenty years’ imprisonment, holding that Defendant’s arguments on appeal were unavailing.Specifically, the Court held (1) any minor discrepancies in the search warrant did not require suppression of the evidence; (2) Appellant’s right to be free from double jeopardy was not violated because the trial court instructed the jury on two counts of trafficking instead of one; (3) it was not clearly unreasonable for the jury to convict Appellant of trafficking in heroin and methamphetamine; (4) the trial court did not abuse its discretion in denying Appellant’s request for expert funding; and (5) the length of Appellant’s sentence did not violate Ky. Rev. Stat. 532.110(1)(c) or 532.080(6)(b). View "Johnson v. Commonwealth" on Justia Law

The Supreme Court affirmed Defendant’s convictions of murder, driving under the influence, and first-degree assault and their corresponding sentences, holding that there was no reversible error in the proceedings below.Specifically, the Court held (1) the trial court did not err in failing to direct a verdict on Defendant’s murder charge; (2) the trial court did not abuse its discretion in allowing the Commonwealth’s expert witness to testify concerning Defendant’s potential head injury and blood glucose level; (3) the trial court erred in allowing a deputy coroner to testify regarding the results of the crash victim’s blood tests, but the error was harmless; (4) even if the Commonwealth committed prosecutorial misconduct, any such error would not be palpable; (5) Defendant’s right to be free from double jeopardy was not violated through his convictions for both wanton murder and driving under the influence; and (6) the trial court did not err in imposing a $500 fine on Defendant for driving under the influence. View "Bowling v. Commonwealth" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Defendant’s motion to convert court costs to a jail term, holding that Defendant did not properly preserve the imposition for court costs for appellate review.Defendant pled guilty to several drug offenses and received ten- and twenty-year sentences, respectively, to be served consecutively, totaling thirty years’ imprisonment. The circuit court also imposed court costs totaling $302 and provided that Defendant must pay those costs within 180 days of his release from prison. Defendant filed a motion to convert court costs to a definite jail term under Ky. Rev. Stat. 534.060. The circuit court denied the motion. Defendant then filed a motion to waive or convert the court costs. The circuit court also denied this motion. The Supreme Court affirmed, holding (1) court costs are mandatory in a criminal proceeding and will be waived or modified only upon a showing of “poor person” status; (2) without a determination or request for a determination of Defendant’s financial status, the Court will not review the imposition of court costs; and (3) court costs are not a component of a plea agreement. View "Elliott v. Commonwealth" on Justia Law

The Supreme Court held that Ky. Rev. Stat. 532.130(2), which contains what the Court determined was an “outdated test” for ascertaining intellectual disability, is unconstitutional under the Eighth Amendment to the United States Constitution.Nearly twenty years ago, Defendant was convicted for the kidnapping, rape, and murder of a teenage girl. Defendant was sentenced to death. Here, Defendant filed a postconviction motion under section 532.130(2) requesting that the trial court declare him to be intellectually disabled, which would preclude the imposition of the death penalty. The trial court denied the motion. The Supreme Court reversed, holding that any rule of law that states that a criminal defendant automatically cannot be ruled intellectually disabled and precluded from execution simply because he or she has an IQ of 71 or above is unconstitutional. The Court remanded the case to the trial court to conduct a hearing, make findings, and issue a ruling on the issue of Defendant’s potential intellectual disability following this Court’s and the United States Supreme Court’s guidelines on such a determination, especially as set forth in Moore v. Texas, 137 S.Ct. 1039 (2017). View "Woodall v. Commonwealth" on Justia Law