Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals upholding the trial court’s suppression of evidence discovered as a result of a canine sniff search of Defendant’s vehicle during a traffic stop. The Court held that the court of appeals did not err by concluding (1) the stop of Defendant’s vehicle was proper, but the sniff search improperly extended the traffic stop; (2) the traffic stop was the only legal justification for stopping Defendant; and (3) the Commonwealth failed to preserve for appellate review its claim that Defendant’s parole status subjected him to a warrantless and suspicionless search and seizure. View "Commonwealth v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of criminal attempt to commit murder, possession of a handgun by a convicted felon, and tampering with physical evidence and sentencing him to twenty years’ imprisonment. The Court held (1) the trial court did not err in denying Defendant’s motion to suppress his statement to police; (2) the trial court did not err in refusing to allow certain cross-examination of the victim; (3) the trial court did not err in denying Appellant’s motion for a mistrial; and (4) the jury instructions on the possession of a handgun by a convicted felon charge did not deprive Appellant of his right to a unanimous verdict. View "Shively v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of criminal attempt to commit murder, possession of a handgun by a convicted felon, and tampering with physical evidence and sentencing him to twenty years’ imprisonment. The Court held (1) the trial court did not err in denying Defendant’s motion to suppress his statement to police; (2) the trial court did not err in refusing to allow certain cross-examination of the victim; (3) the trial court did not err in denying Appellant’s motion for a mistrial; and (4) the jury instructions on the possession of a handgun by a convicted felon charge did not deprive Appellant of his right to a unanimous verdict. View "Shively v. Commonwealth" on Justia Law

The Supreme Court reversed the decision of the Court of Appeals reversing Defendant’s sentence and conviction and remanding for a new trial, having determined that Defendant’s guilty plea did not satisfy Boykin v. Alabama, 395 U.S. 238 (1969).A jury convicted Defendant of first-degree rape and third-degree unlawful transaction with a minor. After a Boykin colloquy, Defendant subsequently entered a guilty plea in exchange for a seventeen-year prison sentence. The Court of Appeals reversed, concluding that Defendant’s guilty plea did not satisfy Boykin. The Supreme Court reversed the decision of the Court of Appeals and reinstated Defendant’s conviction and sentencing, holding that, based on the totality of the circumstances, Defendant’s guilty plea was made knowingly, voluntarily, and intelligently. View "Commonwealth v. Patton" on Justia Law

The Supreme Court reversed the decision of the Court of Appeals reversing Defendant’s sentence and conviction and remanding for a new trial, having determined that Defendant’s guilty plea did not satisfy Boykin v. Alabama, 395 U.S. 238 (1969).A jury convicted Defendant of first-degree rape and third-degree unlawful transaction with a minor. After a Boykin colloquy, Defendant subsequently entered a guilty plea in exchange for a seventeen-year prison sentence. The Court of Appeals reversed, concluding that Defendant’s guilty plea did not satisfy Boykin. The Supreme Court reversed the decision of the Court of Appeals and reinstated Defendant’s conviction and sentencing, holding that, based on the totality of the circumstances, Defendant’s guilty plea was made knowingly, voluntarily, and intelligently. View "Commonwealth v. Patton" on Justia Law

The Supreme Court upheld Defendant’s convictions for three counts of wanton endangerment in the first degree, holding that an instructional error did not require vacating Defendant’s convictions.The Court of Appeals reversed and vacated Defendant’s convictions, ruling, sua sponte, that the jury instructions required proof of an additional element in order to find Defendant guilty of wanton endangerment, first-degree, and that the error was not harmless. The Supreme Court disagreed and reinstated the judgment of the trial court, holding that the instructional error was harmless. Given that the Commonwealth proved its case to the jury with an additional element to prove, there was no reasonable probability that omitting this added element would change the jury’s verdict. View "Commonwealth v. Caudill" on Justia Law

The Supreme Court upheld Defendant’s convictions for three counts of wanton endangerment in the first degree, holding that an instructional error did not require vacating Defendant’s convictions.The Court of Appeals reversed and vacated Defendant’s convictions, ruling, sua sponte, that the jury instructions required proof of an additional element in order to find Defendant guilty of wanton endangerment, first-degree, and that the error was not harmless. The Supreme Court disagreed and reinstated the judgment of the trial court, holding that the instructional error was harmless. Given that the Commonwealth proved its case to the jury with an additional element to prove, there was no reasonable probability that omitting this added element would change the jury’s verdict. View "Commonwealth v. Caudill" on Justia Law

The Supreme Court held that the denial of Defendant’s motion to suppress evidence seized from her vehicle during a traffic stop was proper.In her suppression motion, Defendant argued that the traffic stop of her vehicle was not justified because she was not required to have her license plate illuminated when Sergeant James Jenkins pulled her over. The Commonwealth acknowledged that a license plate violation may not have been a proper basis for the stop but that Detective Wade Shoemaker had reasonable suspicion of Defendant’s participation in controlled drug buys, and Det. Shoemaker’s reasonable suspicion to stop Defendant’s vehicle transferred to Sgt. Jenkins so as to justify the traffic stop. The trial court concluded that no traffic violation occurred but that law enforcement had reasonable suspicion to pull over Defendant’s vehicle. The Court of Appeals reversed, concluding that because Sgt. Jenkins did not actually rely on Det. Shoemaker’s information and instead made the stop based solely on the license plate violation, the collective knowledge doctrine was irrelevant. The Supreme Court reversed, holding that the record reflected that the real reason Sgt. Jenkins pulled over Defendant’s vehicle was upon Det. Shoemaker’s request, and because Det. Shoemaker had reasonable suspicion to make the investigatory stop, suppression of the evidence was not required. View "Commonwealth v. Blake" on Justia Law

The Supreme Court held that the denial of Defendant’s motion to suppress evidence seized from her vehicle during a traffic stop was proper.In her suppression motion, Defendant argued that the traffic stop of her vehicle was not justified because she was not required to have her license plate illuminated when Sergeant James Jenkins pulled her over. The Commonwealth acknowledged that a license plate violation may not have been a proper basis for the stop but that Detective Wade Shoemaker had reasonable suspicion of Defendant’s participation in controlled drug buys, and Det. Shoemaker’s reasonable suspicion to stop Defendant’s vehicle transferred to Sgt. Jenkins so as to justify the traffic stop. The trial court concluded that no traffic violation occurred but that law enforcement had reasonable suspicion to pull over Defendant’s vehicle. The Court of Appeals reversed, concluding that because Sgt. Jenkins did not actually rely on Det. Shoemaker’s information and instead made the stop based solely on the license plate violation, the collective knowledge doctrine was irrelevant. The Supreme Court reversed, holding that the record reflected that the real reason Sgt. Jenkins pulled over Defendant’s vehicle was upon Det. Shoemaker’s request, and because Det. Shoemaker had reasonable suspicion to make the investigatory stop, suppression of the evidence was not required. View "Commonwealth v. Blake" on Justia Law

In this appeal from a criminal conviction, the Supreme Court vacated the portion of the circuit court’s judgment imposing criminal restitution and otherwise affirmed the judgment of conviction and sentence. Defendant was convicted of second-degree manslaughter and of being a first-degree persistent felony offender (PFO). The Supreme Court affirmed in part and vacated in part the judgment, holding (1) the trial court erred when it ordered Defendant to pay criminal restitution because the court did not comply with the procedural due process requirements for imposing restitution as outlined in Jones v. Commonwealth, 382 S.W.3d 22 (Ky. 2011), and therefore, the criminal restitution award must be vacated and remanded for a new hearing; (2) the trial court did not err in allowing evidence that Defendant cut off his ankle monitor while on probation because evidence of probation violations, like evidence of parole violations, can be admissible evidence in the penalty phase of a criminal trial; and (3) the trial court did not err when it allowed the use of Defendant’s prior conviction for drug possession as a qualifier for PFO enhancement. View "Brown v. Commonwealth" on Justia Law