Justia Constitutional Law Opinion Summaries

Appellant pled guilty to several crimes, including capital murder. The circuit court sentenced Appellant to death for his six capital crimes and to life imprisonment for rape, kidnapping, and arson. The Supreme Court affirmed, holding, inter alia, that (1) the trial court properly accepted Appellant’s guilty plea; (2) playing Appellant’s videotaped guilty plea colloquy for the jury did not constitute reversible error; (3) the trial court properly denied Appellant’s guilty but mentally ill plea; (4) the jury was properly selected; (5) the trial judge did not err in denying Appellant’s motion to exclude certain photographs; (6) the trial court properly denied Appellant’s motion to suppress statements he made to law enforcement officers and properly permitted the jury to watch his videotaped statement; (7) the jury instructions did not deny Appellant due process or reliable sentencing; and (8) Appellant’s sentences were constitutional, and his death sentences were not arbitrary and disproportionate. View "Dunlap v. Commonwealth" on Justia Law

After a jury trial, Appellee was convicted of possession of a controlled substance, fleeing or evading police, and being a persistent felony offender. The judgment was affirmed on appeal. Appellee subsequently filed a Ky. R. Crim. P. 11.42 motion seeking relief from the judgment by alleging ineffective assistance of counsel. The trial court denied the motion without an evidentiary hearing, concluding that Appellee was not prejudiced by counsel’s alleged errors. The court of appeals reversed and remanded the case to the trial court for a hearing, concluding that Appellee’s allegations of ineffective assistance of trial counsel were not clearly refuted by the record. The Supreme Court reversed the opinion of the court of appeals and reinstated the trial court’s order, holding that the trial court did not err in denying Appellee’s Rule 11.42 motion without an evidentiary hearing because a hearing was not necessary to determine that Appellee was not prejudiced by any errors of trial counsel regardless of whether those errors amounted to unprofessional performance. View "Commonwealth v. Searight" on Justia Law

Appellee, an experienced criminal attorney, was indicted on five counts of failure to file Kentucky tax returns for the tax years 2002 through 2006. Appellee proceeded pro se until a day before the jury trial was scheduled to begin, at which point Appellees requested a continuance for the purpose of possibly retaining private counsel. The trial court overruled the motion for a continuance. At no stage during the proceedings did the court conduct a Faretta hearing. Appellee was subsequently found guilty of five counts of failing to file a state tax return. The court of appeals reversed. The Supreme Court reversed the court of appeals and reinstated the judgment of the circuit court, holding that criminal defendants who are experienced criminal trial attorneys are not entitled to a Faretta hearing or inquiry prior to representing themselves. View "Commonwealth v. Ayers" on Justia Law

After a jury trial, Appellant was convicted of intentional murder and sentenced to life imprisonment. Appellant appealed, arguing that the trial court erred when it (1) denied her motion to suppress statements she gave to police after a polygraph examination because she did not knowingly and voluntarily waive her Miranda rights, and (2) failed to instruct the jury on the lesser-included offense of first-degree manslaughter. The Supreme Court affirmed Appellant's conviction and sentence, holding (1) the trial court did not err in admitting Appellant's statements given to the police because, under the totality of the circumstances, nothing showed that Appellant did not knowingly and voluntarily waive her rights as to her post-polygraph interview with police; and (2) Appellant's argument that the trial court failed to give an instruction on first-degree manslaughter was not properly preserved and not subject to palpable-error review. View "Wise v. Commonwealth" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree assault and of being a second-degree persistent felony offender. The Supreme Court affirmed one of Appellant's convictions for first-degree assault, reversed the other conviction, and remanded, holding (1) the trial court did not commit reversible error by failing to strike three prospective jurors for cause, failing to provide limiting instructions, or allowing a fact witness to present an expert opinion; (2) the Commonwealth's question to Appellant was to whether it was lawful for him to possess a firearm was not reversible error; but (3) the Commonwealth's proof did not support a conviction for one of the first-degree assault convictions. View "McDaniel v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of first-degree assault, first-degree wanton endangerment, and operating a motor vehicle under the influence of alcohol, among other charges. The Supreme Court affirmed except as to Defendant's conviction for wanton endangerment, which the Court reversed, holding (1) the trial court did not violate Defendant's due process right to a fair trial by failing to remove two jurors for cause; (2) the trial court did not violate Defendant's right to confrontation by introducing a hospital laboratory report without the testimony of the person who prepared the report; but (3) the prosecution of the wanton endangerment charge violated Defendant's double jeopardy rights, and the wanton endangerment instruction violated Defendant's right to a unanimous verdict. Remanded. View "Little v. Commonwealth" on Justia Law

In 1983, Appellant, the owner and chief executive officer of an asphalt company, pled guilty to violating the Sherman Antitrust Act for unlawfully bidding on state highway construction contracts. In order to have his company's privilege of bidding on new contracts reinstated, Appellant agreed to cooperate with the Attorney General's (AG) investigation and proffered information pertaining to Appellant's involvement in a scheme to "rig" bids for highway construction contracts with the Kentucky Department of Transportation. In 2009, reporters for several newspapers submitted an Open Records Act (ORA) request to have the proffer disclosed. When Appellant learned the AG intended to release the proper, Appellant brought this action against the AG and ORA reporters seeking to have the release enjoined under the privacy exemption or the law enforcement exemption to the ORA. In 2011, the trial court ruled that the proffer should be released to the ORA requestors. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Appellant did not have standing to invoke the law enforcement exemption provision to the ORA; and (2) matters of sufficient public interest warranted an invasion of Appellant's limited privacy interest in keeping his proffer from being disclosed. View "Lawson v. Office of Attorney Gen." on Justia Law

A writer for the Kentucky New Era, Inc., a newspaper serving the city of Hopkinsville and the neighboring area, requested records from the Hopkinsville City Clerk, including copies of arrest citations and police incident reports involving stalking, harassment, or terroristic threatening. The City Clerk withheld some records and redacted from others certain types of personal data. The City then initiated an action essentially seeking a declaration that its decisions to withhold and to redact records did not violate the Kentucky Open Records Act (ORA). The circuit court ultimately ruled that the City's redactions of social security and driver's license numbers, of home addresses, and of telephone numbers comported with the ORA. The court of appeals upheld the redactions and held that the City had the right to redact the names of all juveniles in the records. The Supreme Court affirmed, holding that the court of appeals correctly applied the ORA's privacy exemption in concluding that the redactions at issue in this case were in accordance with the ORA. View "Ky. New Era, Inc. v. City of Hopkinsville" on Justia Law

After the foreign language taught at Knott County Central High School was switched from French to Spanish, Grace Patton, the high school's French teacher, lost her job. Patton brought suit against Appellants - the Knott County Board of Education, individual Board members, the high school principal, the superintendent, and individual members of the school's Site-Based Decision-Making Council. Appellant's complaint did not specifically identify any particular claim or cause of action. The trial court granted summary judgment in favor of Appellants. The court of appeals reversed on the grounds that (1) Patton's complaint had stated a claim against the school board under the whistleblower statute, and the evidence precluded summary judgment; and (2) the individual Appellants were not subject to qualified official immunity because the actions taken to Patton's detriment were ministerial, not discretionary. The Supreme Court reversed, holding (1) Patton did not state a claim under the whistleblower act and had no claim under the act under the facts as alleged; and (2) the individual Appellants were engaged in the performance of discretionary duties covered by the qualified official immunity doctrine. View "Knott County Bd. of Educ. v. Patton" on Justia Law

Appellee entered guilty pleas to three charges of theft by unlawful taking over $300. The final judgment provided that Appellee be placed on supervised probation for five years and pay restitution. After the expiration of Appellee's probationary period, the Commonwealth moved to revoke Appellee's probation based upon his failure to pay restitution. The circuit court denied the motion, concluding that, pursuant to Conrad v. Evridge, the circuit court was without jurisdiction to revoke Appellee's probation. In so holding, the circuit court rejected the Commonwealth's argument that Ky. Rev. Stat. 533.020(4) operated to automatically extend Appellee's probationary period so long as he failed to complete payment of the restitution as ordered. The Supreme Court affirmed, holding (1) section 533.020(4) authorizes a trial court to extend the duration of a sentence of probation only if such an extension is necessary for payment of restitution; and (2) upon expiration of Appellee's probationary period, the trial court lost jurisdiction over the case and was without authority to revoke Appellee's probation. View "Commonwealth v. Wright" on Justia Law