Justia Constitutional Law Opinion Summaries

Appellant entered a conditional guilty plea to possession a handgun as a convicted felon, possessing marijuana, and operating a motor vehicle on a suspended license. Appellant appealed the trial court’s order denying his motion to suppress evidence found in the vehicle he was driving at the time of his arrest. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the record contained substantial evidence supporting the trial court’s findings of fact; (2) warrantless searches are per se unreasonable, subject to a few well-established exceptions, such as inventory searches; and (3) under the circumstances of this case, the police acted reasonably in seizing Appellant’s vehicle and performing the subsequent inventory search of its contents. View "Cobb v. Commonwealth" on Justia Law

In 2015, the Louisville/Jefferson County Metro Government (Louisville Metro) enacted its own minimum wage ordinance for al employers within the Louisville Metro boundary. The ordinance required a higher wage than the statutory minimum. Appellants filed an action against Louisville Metro, arguing that the ordinance was void as being outside the authority of Louisville Metro to enact. The circuit court entered a ruling in favor of Louisville Metro. The Supreme Court reversed, holding that Louisville Metro exceeded its authority by enacting the ordinance because the ordinance conflicts with the comprehensive statutory scheme in Ky. Rev. Stat. 337 on the issue of wages. View "Kentucky Restaurant Ass’n v. Louisville/Jefferson County Metro Government" on Justia Law

After a jury trial, Defendant was convicted of first-degree robbery and of being a first-degree persistent felony offender. Defendant appealed, arguing that the trial court violated his right to a public trial when it cleared visitors from the courtroom during the victim’s testimony and when it denied his motion to suppress an out-of-court photo identification. The Supreme Court affirmed the trial court’s judgment on both issues, holding (1) because Defendant failed to object to the courtroom closure, he waived his argument that his right to a public trial was violated; and (2) the trial court did not abuse its discretion in concluding that the out-of-court identification was valid. View "Crutcher v. Commonwealth" on Justia Law

The juvenile Appellant in this case, "Bill," a fifteen-year-old eighth-grade boy, was charged with multiple public offenses based on his sexual conduct with his thirteen-year-old girlfriend "Carol", who was not charged. He entered an unconditional admission to amended charges, and the district court entered an adjudication finding that he committed the alleged conduct. After disposition of his case, he appealed to the circuit court, which affirmed. The Court of Appeals denied his motion for discretionary review, but the Supreme Court granted it initially to address constitutional challenges that Bill raised. After consideration of those challenges, the Supreme Court concluded that the appeal should have been dismissed by the circuit court, with no consideration of any of the substantive issues raised, because Bill entered an unconditional admission to the offenses and thereby waived an appeal in this case. View "B. H. v. Kentucky" on Justia Law

The Magoffin County Board of Elections (the Board) and its members in their official capacities (Carson Montgomery, Susie Salyer, and Justin Williams, and Magoffin County Clerk Renee Arnett-Shepherd), and Democratic candidate for judge executive Charles Hardin, appealed a Court of Appeals decision to affirmed the setting aside the results of the November 4, 2014 election for Magoffin County judge executive and declaring the office vacant. The officially-tabulated vote count revealed that Republican candidate, Appellee John Montgomery, lost the election to Hardin by a mere twenty-eight votes. Montgomery filed this action to challenge the election results. Appellants contended: (1) that the trial court and the Court of Appeals nullified the election on grounds that were not set forth in Montgomery's petition to challenge the election, and thus deprived them of fair notice of such grounds; (2) that contrary to the trial court's conclusions, the election was conducted in substantial compliance with the applicable election laws; (3) that any violations of applicable election laws that occurred in the election were de minimus and had no impact on the result of the election; and (3) that Montgomery's evidence was insufficient to prove the illegalities he alleged and insufficient to prove that the result of the election was affected by any irregularities and improprieties which may have occurred. After review, the Kentucky Supreme Court concluded that Appellant Hardin was entitled to occupy the office of Magoffin County judge executive in accordance with the tabulated results of the November 4, 2014 election. View "Hardin v. Montgomery" on Justia Law

Appellant Donald Howard entered an open guilty plea to five counts of first-degree trafficking in a controlled substance, second offense. He was sentenced to ten years' imprisonment with a $1,000 fine on each count with two counts running consecutively for a maximum twenty-year total sentence. He appealed, arguing that the trial court's imposition of the statutory maximum sentence was unconstitutional and that the court erred by imposing a partial fee to the public defender and court costs. After review, the Supreme Court held that the trial court did not err in sentencing Howard, assessing court costs, or imposing a partial fee for the public defender. The Court agreed, however, that the trial court erred by imposing the criminal fines, so the criminal fines imposed in the judgment were vacated and the matter remanded back to the trial court for entry of a conforming judgment. View "Howard v. Kentucky" on Justia Law

Appellant David Jenkins appealed his convictions for first-degree rape and first-degree sodomy. A jury found appellant guilty and recommended twenty-year sentences for both crimes, to be served consecutively (for a total maximum term of forty years). On appeal, appellant argued: (1) the evidence presented against him at trial was insufficient to support the jury's verdicts and that, accordingly, he was entitled to a dismissal of the charges; and (2) even if the evidence was not so lacking as to require a directed verdict, a number of trial court errors rendered the proceedings unfair and entitle him to a new trial. Agreeing with Jenkins that the jury's instruction on a single count of sodomy when the evidence reflected two such acts, did not comport with recent cases construing the Kentucky Constitution's unanimous verdict requirement, the Supreme Court reversed the sodomy conviction and the sodomy portion of Jenkins's sentence, and remand for additional proceedings. Finding no other reversible error, the Court affirmed appellant's rape conviction and corresponding twenty-year sentence for that crime. View "Jenkins v. Kentucky" on Justia Law

Appellant Kyle Sheets was convicted of first-degree sexual abuse and two counts of first-degree sodomy. In a separate trial with a separate jury, he was convicted of possession of a handgun by a convicted felon. He was sentenced to ten years' imprisonment for the sexual-abuse conviction, forty years' for each sodomy conviction, and six years' for the handgun conviction, all to run consecutively, subject to the statutory maximum aggregate sentence of seventy years. Sheets appealed, arguing: (1) the trial court erred when it failed to grant his motions for directed verdicts of acquittal; (2) the trial court violated his right to be free from double jeopardy; (3) the trial court violated his right to a unanimous verdict; (4) the Commonwealth erred when it introduced irrelevant evidence of legal sexual acts between Sheets and his wife; (5) the Commonwealth erred when it alleged Sheets' defense attorney acted immorally or illegally by investigating the allegations; (6) one of the Commonwealth's witnesses gave improper testimony on cross examination; (7) the trial court erred by failing to conduct an in camera review of Sheets's alleged victim's psychological counseling records; and (8) the trial court erred when it included an instruction on a definition of "constructive possession" on his possession-of-a-handgun-by-a-convicted-felon charge. The Kentucky Supreme Court concluded it did not have jurisdiction to review the possession-of-a-handgun-by-a-convicted-felon conviction and sentence on direct appeal because the sentence for that conviction was less than twenty years' imprisonment. Thus, the Court did not address Sheets' final claim of error. The Court reversed appellant's conviction with regard to the sodomy conviction, and remanded that for further proceedings. The Court affirmed in all other respects. View "Sheets . Kentucky" on Justia Law

In May and July of 2012, Jonathan McDaniel, David DeShields, and John Martin, all inmates at the State Reformatory in LaGrange, and all serving sentences for felony sex offenses, filed very similar pro se motions at their respective trial courts challenging the legality of the conditional discharge requirement of KRS 532.043, and sought to have the discharge period deleted from their sentences. All three trial courts denied the motion, and all three defendants appealed. The Supreme Court granted defendants' joint motion for discretionary review to address their concern that the Court of Appeals inappropriately characterized their trial court motions as having been brought pursuant to Kentucky Rule of Criminal Procedure (RCr) 11.42, and to address the Court's own concern that the Court of Appeals, "perhaps in its eagerness to try to calm the waters after the 2011 amendment to KRS 532.043," inappropriately ruled on a question not properly before it. After that review, the Court affirmed the Court of Appeals' ultimate affirmance of the trial court rulings denying relief, but "vacated" the Court of Appeals' opinion except as to the issue of whether Martin's and McDaniel's guilty pleas were subject to appellate review. View "McDaniel v. Kentucky" on Justia Law

After entering a guilty plea, the Appellant Bryan Russell sent a letter to the trial court complaining about the effectiveness of his counsel and the legality of the sentence to which he had agreed. The letter did not specifically ask for any relief, such as the setting aside of Russell's plea. The primary issue in this case was whether Russell's letter was sufficient to constitute a pro se motion to withdraw his guilty plea under Criminal Rule 8.10. Resolution of that issue turned primarily on whether the letter "set[s] forth the relief or order sought" as required under the Rule. After review of the letter, the Supreme Court concluded that because Russell's letter did not expressly ask for any relief, much less ask to withdraw his guilty plea, it could not be construed as a motion under Criminal Rule 8.14. Therefore, the Supreme Court affirmed the circuit court's judgment. View "Russell v. Kentucky" on Justia Law