Justia Constitutional Law Opinion Summaries

Appellant was indicted for being a convicted felon in possession of a handgun, carrying a concealed deadly weapon, and alcohol intoxication in a public place. Appellant filed a motion to suppress the weapon seized at his arrest, arguing that the arresting officer lacked sufficient cause to arrest Appellant for alcohol intoxication and that the ensuing search of his person incident to the improper arrest violated his Fourth Amendment rights. The trial court denied the motion. The court of appeals upheld the validity of the arrest. The Supreme Court reversed, holding (1) Appellant’s arrest for alcohol intoxication in a public place was unlawful because the offense was not committed in the presence of the arresting officer; and (2) therefore, the search conducted incident to that arrest was not valid, and the evidence obtained during the search should have been suppressed. View "Maloney v. Commonwealth" on Justia Law

After a jury trial, Appellant was convicted of murder and four counts of first-degree criminal abuse. Appellant was sentenced to life imprisonment. The Supreme Court affirmed, holding (1) the trial court’s admission of evidence of Appellant’s prior bad acts - namely, his history of domestic violence against his spouse - was not in error; (2) the admission of hearsay statements made to an examining pediatrician was not in error, and the admission of a detective’s hearsay testimony in violation of Appellant’s confrontation rights was harmless beyond a reasonable doubt; and (3) improper closing statements made during the Commonwealth’s closing argument did not rise to the level of misconduct requiring reversal. View "Dickerson v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of one count of intentional murder and one count of being a first-degree persistent felony offender. Defendant was sentenced to twenty years’ imprisonment. Defendant appealed, arguing (1) the trial court’s power to establish the number of peremptory challenges awarded to the Commonwealth is an impermissible delegation of legislative authority under Kentucky’s separation of governmental powers principle, and (2) he was entitled to a directed verdict on the intentional-homicide charge. The Supreme Court affirmed, holding (1) because Defendant did not notify the Attorney General of his intent to challenge the constitutionality of Ky. Rev. Stat. 29A.290(2)(b), Defendant failed to comply with Ky. Rev. Stat. 418.075, and therefore, the Court must decline to address the merits of his argument; and (2) Defendant was not entitled to a directed verdict. View "Craft v. Commonwealth" on Justia Law

Defendant was charged with multiple drug-related criminal offenses. Defendant filed a motion to suppress all the evidence collected from his trailer, arguing that law enforcement officers unlawfully exceeded the scope of a warrantless knock and talk by entering the protected curtilage of his residence. The trial court denied the suppression motion. Defendant subsequently entered a conditional guilty plea to complicity to manufacture methamphetamine, complicity to possess marijuana, and complicity to possess drug paraphernalia. The court of appeals reversed, concluding that the officers did not have the right to venture away from the front of Defendant’s house pursuant to a knock and talk and to invade the curtilage of Defendant’s residence. The Supreme Court reversed, holding that, based on the totality of the factors set forth in United States v. Dunn, as well as the officers’ uncontroverted testimony, neither officer unlawfully encroached on the trailer’s curtilage. View "Commonwealth v. Dixon" on Justia Law

Laul Deng (“Aker”) sued his former employer, Norton Healthcare, Inc., for racial discrimination in terminating his employment. Specifically, Aker alleged that Norton’s failure to reinstate him after termination of his employment was retaliation for filing a pro se discrimination complaint. The trial court granted Norton summary judgment on all of Aker’s claims. Despite acknowledging that Aker never applied for any position with Norton, the court of appeals reversed, concluding that the futile-gesture doctrine excused the requirement that Aker show that he applied for a position in order to establish a prima facie claim for employment discrimination. The Supreme Court reversed, holding (1) the court of appeals erred in invoking the futile-doctrine theory sua sponte; and (2) the trial court did not err in granting summary judgment to Norton as a matter of law. View "Norton Healthcare, Inc. v. Deng" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder for intentionally killing his parents and one count of tampering with physical evidence. Defendant was sentenced to a total of forty-five years’ imprisonment. At issue on appeal was whether the trial court erred in failing to suppress Defendant’s confession made during protracted interrogation by sheriff’s detectives. The Supreme Court reversed Defendant’s convictions, holding (1) Defendant’s confession was involuntarily extracted through interrogation techniques employed by law enforcement that were constitutionally unjustifiable; and (2) the trial court improperly excluded Defendant’s alternate perpetrator evidence at trial. View "Gray v. Commonwealth" on Justia Law

Defendant was charged with first-degree trafficking in a controlled substance and possession of a firearm by a convicted felon. Defendant was tried and convicted on the handgun charge. After his trial on this charge, Defendant filed a motion to suppress, his second such motion. The trial court denied the motion, and Defendant was subsequently tried on the trafficking charge. During trial, the Commonwealth elicited testimony from a police officer about Defendant’s testimony at the second suppression hearing. Defendant did not object to this testimony but elected not to testify in his own defense. Defendant was subsequently convicted on the trafficking charge. The court of appeals reversed the trafficking conviction, concluding that the use of Defendant’s suppression-hearing testimony violated his right not to incriminate himself and that the error was palpable. The Supreme Court reversed, holding that the requirement of an objection is a substantive aspect of the constitutional rule that bars palpable error review, and therefore, the court of appeals erred in resorting to that review. View "Commonwealth v. Taylor" on Justia Law

Appellant pleaded guilty to first-degree manslaughter, second-degree manslaughter, and other crimes. Before final sentencing, Appellant moved to withdraw his guilty plea, arguing that he was provided ineffective assistance of counsel and that he relied on erroneous legal advice regarding time served when he entered his guilty plea. After holding an evidentiary hearing, the trial court denied the motion. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in ruling that Appellant may have received inaccurate advice from his trial counsel about jail-time credit but that Appellant was not prejudiced by counsel’s mistake. View "Greene v. Commonwealth" on Justia Law

Appellant was convicted of driving a motor vehicle under the influence of alcohol (DUI) after being stopped at a police roadblock conducted by the Kentucky State Police (KSP) at a highway intersection. The court of appeals reversed, concluding that the evidence leading to Appellant’s conviction was unconstitutionally obtained because the procedures the KSP employed to set up the roadblock failed to comply with the procedures necessary to implement a suspicionless traffic stop. The Supreme Court affirmed, holding that the KSP did not comply with the factors set forth in Commonwealth v. Buchanon substantially enough to render this roadblock a reasonable seizure performed in the absence of a warrant or individualized suspicion. View "Commonwealth v. Cox" on Justia Law

Each of these three consolidated cases originated with the filing of an action in the circuit court asserting claims against nursing home facilities for personal injuries suffered by a nursing home resident, violations of Ky. Rev. Stat. 216.510 et seq., and for wrongful death of the resident. At the time of each resident’s admission to the nursing home, the resident’s attorney-in-fact executed a written document providing that disputes arising out of the relationship between the resident and the nursing home would be submitted to arbitration. When each case was commenced, the defendant nursing home moved the circuit court to compel the parties to submit the claims to a formal arbitration proceeding. The circuit court denied the motion in each case, concluding that the respective power-of-attorney instruments did not authorize the resident’s attorney-in-fact to waive the resident’s right to access to the courts. The Supreme Court affirmed, holding (1) without a clear and convincing manifestation of the principal’s intention to do so, delegation to an agent of the authority to waive a trial by jury is not authorized, and the principal’s assent to the waiver is not validly obtained; and (2) the arbitration agreements in these cases were never validly formed. View "Extendicare Homes, Inc. v. Whisman" on Justia Law