Justia Criminal Law Opinion Summaries

Appellee was an inmate when he was allegedly involved in a riot. During an interview with an investigating officer, Appellee requested that three witnesses be questioned who could corroborate his version of events, but the witnesses were not interviewed. After a disciplinary hearing, at which Appellee did not call witnesses or present evidence in his defense, Appellee was disciplined for his participation in the riot. Appellee subsequently filed a petition for declaration of rights in the circuit court, arguing that Appellants violated his due process rights by failing to interview the three purported witnesses and by denying him the right to call witnesses and present evidence in his defense. The trial court dismissed the complaint, concluding that the hearing complied with the minimal requirements of procedural due process as outlined in Wolff v. McDonnell. The court of appeals reversed. The Supreme Court affirmed, holding (1) the interviewing officer’s failure to interview the requested witnesses did not deprive Appellant of procedural due process as outlined in Wolff; but (2) while Appellee did not have had the right to remain silent or the right to an attorney during his disciplinary hearing, he deserved a new disciplinary hearing because he was erroneously informed that he enjoyed the rights espoused in Miranda. View "White v. Boards-Bey" on Justia Law

After a jury trial, Appellant was found guilty of murdering his wife and sentenced to life in prison. On appeal, Appellant alleged, inter alia, that he was entitled to a directed verdict and that the trial court erred in admitting evidence of other acts. The Supreme Court reversed Appellant’s conviction and remanded for further proceedings, holding (1) Appellant was not entitled to a directed verdict of acquittal and therefore may be retried; and (2) the trial court’s admission of the other acts evidence was error under Ky. R. Evid. 404(b) given the Commonwealth’s failure to establish proof of the factual condition necessary to make it relevant, and the error was not harmless and prejudiced Appellant. View "Southworth v. Commonwealth" on Justia Law

After a prison disciplinary hearing, Appellant, a prisoner, was found guilty of committing physical action against another inmate resulting in death or serious physical injury. Appellant subsequently filed a declaration of rights action in circuit court appealing the finding of guilt, contending that his due process rights were violated because the prison’s disciplinary hearing officer refused to allow him to call the victim of the assault and declined to view surveillance camera footage of the incident. The circuit court denied the petition. The court of appeals affirmed. The Supreme Court reversed, holding (1) if a prison challenges the denial of a prisoner’s request for a particular witness in a disciplinary proceeding by appealing the discipline imposed, the adjustment officer (AO) must provide for the record on review the AO’s reason for denying the witness; (2) if requested by the prisoner in a disciplinary proceeding an AO must review surveillance footage or similar documentary evidence; and (3) Appellant was found guilty and subject to prison discipline as a result of a process that failed to comport with the minimum requirements of due process. Remanded. View "Ramirez v. Nietzel" on Justia Law

After a jury trial, Appellant was found guilty of one count of complicity to murder and one count of first-degree complicity to robbery. Appellant was sentenced to life imprisonment on the murder count and to twenty years on the robbery count. The Supreme Court affirmed Appellant’s convictions and sentences, holding (1) the trial court did not err by denying Appellant’s motions for mistrial after the Commonwealth referenced two of the three co-indictees’ guilty pleas in the presence of the jury; (2) the trial court did not err by admitting eighteen jail letters written by Appellant and her co-indictee into evidence; and (3) the trial court did not err by denying Appellant’s motion for a mistrial after the jury briefly accessed inadmissible evidence during deliberations. View "Mayse v. Commonwealth" on Justia Law

Appellant was convicted of rape in the first degree, sodomy in the first degree, and assault in the fourth degree, third offense. The trial in this case was trifurcated. During the first phase, the jury convicted Appellant of fourth-degree assault, and during the second phase, the jury convicted Appellant of fourth-degree assault, third offense based on two prior convictions of fourth-degree assault. The Supreme Court reversed the portion of the judgment convicting Appellant of fourth-degree assault, third offense, and vacated the corresponding sentence for that offense, holding that the evidence was insufficient to support the charge and that retrial for the charge was precluded under the double jeopardy clause of the Fifth Amendment. Because Appellant was not sentenced for the fourth-degree assault conviction, however, the case was remanded for sentencing for that conviction. View "Galloway v. Commonwealth" on Justia Law

After a jury trial in 1993, Appellant was found guilty of murdering two brothers, Rodney Vaughn and Lynn Vaughn. The trial court sentenced Appellant to death for both murders. In 2013, Appellant filed a motion for post-conviction relief alleging that he was entitled to a new trial based on “newly discovered evidence.” Appellant’s challenge to his convictions was founded upon a report prepared by John Nixon, a forensic expert on firearms and ballistics, who concluded that new information supported Appellant’s version of events, thereby supporting Appellant’s claim that he acted in self-defense in shooting Rodney and that Rodney shot Lynn. The trial court summarily denied Appellant’s motion without conducting an evidentiary hearing. The Supreme Court affirmed, holding that the “newly discovered evidence” presented by Appellant fell short of the standards that must be met to obtain such relief. View "Foley v. Commonwealth" on Justia Law

Appellant’s charges in this case stemmed from a search of his residence by his parole officers and local sheriff’s deputies. Appellant entered a conditional guilty plea to manufacturing methamphetamine and being a second-degree persistent felony offender and was sentenced to fifty years’ imprisonment. The Supreme Court affirmed, holding that the trial court did not err in (1) denying Appellant’s motion to suppress the products of the search of his home, as Appellant consented to the search and there was no indication that the consent was invalid; and (2) denying Appellant’s motion to suppress the results of lab testing on the products of the search, as the lab results were clearly admissible. View "Helphenstine v. Commonwealth" on Justia Law

After a trial, Appellant was convicted of one count of first-degree rape and one count of first-degree sexual abuse for an incident involving his fourteen-year-old stepdaughter. The Supreme Court reversed, holding (1) insufficient evidence supported Appellant’s conviction for first-degree rape because the Commonwealth did not prove the “forcible compulsion” element; (2) the trial court did not err in admitting Appellant’s computer password into evidence; and (3) the trial court committed reversible error when it did not allow Appellant to ask the victim about her prior inconsistent statement, and thus, Appellant’s conviction for first-degree sexual abuse must also be reversed. Remanded. View "Yates v. Commonwealth" on Justia Law

In 2000, Appellant pled guilty to one count of theft by deception and was sentenced to a one-year term of imprisonment, probated for a period of five years. After Appellant failed to report to her probation officer, the trial court issued a warrant for her arrest. In 2011, Appellant was finally served with the arrest warrant. After a probation revocation hearing, the trial court dismissed the Commonwealth’s motion to revoke Appellant’s probation, determining that Appellant’s period of probation had already expired. The court of appeals reversed, concluded that because Appellant “intentionally absconded,” she was barred from claiming that her probationary period had expired. The Supreme Court affirmed, holding (1) the issuance of a warrant for a probation violation will toll the period of probation preventing the probationer from being automatically discharged pursuant to Ky. Rev. Stat. 533.020(4); (2) the warrant, however, must be issued before the expiration of the period of probation; and (3) since the circuit court issued a warrant for Appellant’s arrest within the five-year probationary period, it retained jurisdiction to conduct a probation revocation hearing. View "Whitcomb v. Commonwealth" on Justia Law

After a jury trial, Appellant was found guilty of robbery in the first degree and of being a persistent felony offender in the first degree for robbing a cashier clerk at a convenience store at knifepoint. The Supreme Court affirmed, holding that the trial court (1) did not err by allowing three witnesses to identify Appellant as the perpetrator on the store surveillance video and in still shot photos; (2) did not err or violate Appellant’s due process rights by denying Appellant’s motion for a continuance of trial; and (3) did not err by denying Appellant’s motion for a directed verdict of acquittal. View "Morgan v. Commonwealth" on Justia Law