In Peak v. Commonwealth, defendants Michael Peak and Patrick Meeks were jointly tried and convicted of intentional or wanton murder, first-degree robbery, conspiracy to commit murder, and tampering with physical evidence after they and a third co-defendant killed and robbed a drug dealer whose body was later found in a dry creek bed. Peak received a life sentence without parole eligibility for 25 years on the murder count plus concurrent terms on the other charges, while Meeks received a similar overall sentence. The Kentucky Supreme Court consolidated their appeals and affirmed the convictions and sentences, holding that the trial court did not err in admitting Meeks's statement to police, denying suppression, handling evidentiary and jury-instruction issues, or managing peremptory challenges and other procedural matters. The court concluded that the evidence was constitutionally sufficient and that any alleged errors were not reversible.
The case concerned whether Randall Scott Lucas's confession to sexual abuse during a second police interview was obtained in a custodial interrogation without required Miranda warnings, leading to his conditional guilty plea and sentence. The trial court denied suppression after finding the interview non-custodial, but the Court of Appeals reversed in a split decision. On discretionary review, the Kentucky Supreme Court applied a de novo standard to the mixed question of law and fact, examined the totality of circumstances including Lucas's voluntary appearance, prior warnings, the detective's statements, and the shift to a new allegation, and held the interrogation was non-custodial so the confession was admissible. A dissent argued the circumstances indicated custody once questioning turned to the new felony allegation.
This case concerned whether evidence obtained from a search incident to arrest for criminal trespass should be suppressed, specifically challenging whether an officer had probable cause to arrest for a misdemeanor committed in his presence under KRS 431.005. The defendant was arrested after evasive behavior and inability to name residents he claimed to visit in a posted no-trespassing apartment complex, leading to discovery of cocaine. The trial court denied suppression, but the Court of Appeals reversed on the arrest standard. The Kentucky Supreme Court reversed the Court of Appeals and reinstated the trial judgment, holding that probable cause is the proper standard for a warrantless misdemeanor arrest if a reasonable officer could conclude from the facts that the offense occurred in his presence, overruling contrary precedent in Mash and applying the Mobley analysis, while finding the initial stop justified by reasonable suspicion from evasive actions.
The case concerned whether an individual unemployed at the time of a car accident could recover work loss benefits under Kentucky's Motor Vehicle Reparation Act for a job offered afterward that she declined on her physician's advice due to accident-related injuries, and whether her insurer had a reasonable foundation to deny the claim. The trial court submitted the issues to a jury, which awarded Foster work loss benefits, 18% interest, and attorney fees after finding the denial lacked a reasonable foundation. The Court of Appeals reversed, concluding the insurer had a reasonable basis as a matter of law, but the Kentucky Supreme Court reversed that decision and reinstated the jury verdict, reasoning that the MVRA covers work the injured person probably would have performed if uninjured and provides the exclusive remedies for untimely or unfounded denials of no-fault benefits.
Epperson was convicted after a 1996 retrial of two counts of complicity to murder, first-degree robbery, and first-degree burglary arising from the 1985 shooting deaths of a husband and wife in their home during a robbery; he received a death sentence for the murders and forty years on the other charges. On direct appeal he raised thirty-two claims, including challenges to the sufficiency of the indictment, adequacy of notice regarding complicity liability, voir dire on pretrial publicity and sentencing views, and residual doubt. The Kentucky Supreme Court reviewed each allegation under the applicable standards for death-penalty cases and held that the indictment properly notified Epperson of the charges, that the jury-selection process was within the trial court's discretion, and that no individual or cumulative error occurred. The court therefore affirmed the convictions and sentences.
This case is an appeal from the Jefferson Circuit Court's denial of Simmons's RCr 11.42 motion to vacate his convictions for three counts of first-degree murder, three counts of first-degree rape, one count of attempted murder, one count of attempted rape, and four counts of kidnapping, along with his death sentences. The Kentucky Supreme Court affirmed the denial after a nine-day evidentiary hearing, reviewing fifteen claims of alleged ineffective assistance of counsel under the Strickland v. Washington standard. The court held that RCr 11.42 motions are limited to issues not raised or raisable on direct appeal, that many claims were previously rejected or amounted to attempts to relitigate direct appeal issues, and that Simmons failed to show counsel's performance was objectively unreasonable or prejudicial to the outcome. It also rejected arguments to reopen the direct appeal or find cumulative error.
