Alastar Martel Couch v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedJuly 21, 2022
Docket2020 CA 001116
StatusUnknown

This text of Alastar Martel Couch v. Commonwealth of Kentucky (Alastar Martel Couch v. Commonwealth of Kentucky) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alastar Martel Couch v. Commonwealth of Kentucky, (Ky. Ct. App. 2022).

Opinion

RENDERED: JULY 22, 2022; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2020-CA-1116-MR

ALASTAIR MARTEL COUCH APPELLANT

APPEAL FROM FRANKLIN CIRCUIT COURT v. HONORABLE THOMAS D. WINGATE, JUDGE ACTION NO. 10-CR-00212

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, COMBS, AND MAZE, JUDGES.

MAZE, JUDGE: Alastair Martel Couch (Couch) appeals the denial of his motion

for postconviction relief without an evidentiary hearing in accordance with RCr1

11.42(5). Finding no error in the decision of the Franklin Circuit Court, we affirm.

1 Kentucky Rules of Criminal Procedure. Tomma Graves, a long-time friend of Couch, was reported missing on

July 31, 2010. Two days later, her body was recovered. She had been shot in the

skull, arm, and hand.

Through witness testimony, the Commonwealth showed that she had

been seen with Couch on the morning of her death. Later that day, a witness saw a

black male running near the parking lot where Graves’ body was eventually

recovered. Another testified to seeing a black male walking in that area while

talking on a cell phone, giving directions. That witness indicated that the man

appeared to be holding a blood-stained shirt. He observed the black male getting

into a red truck with a farm plate.

Dusty Whitis, a key prosecution witness, testified that he had

scheduled a drug deal with Couch on the morning of the murder, but that Couch

changed the location several times, afraid that “someone had seen him.” Whitis

saw Couch remove spent shell-casings from a handgun and dispose of them. The

pair then traveled to the home of Whitis’ girlfriend, where Couch burned a blood-

stained shirt and a cell phone. Couch then left the home with Bryce Hodges and

Michael Williams. The three men drove out into the country where Couch was

observed disposing of something over a cliff. After receiving a tip, police officers

recovered a revolver from that area. It was later determined to be the murder

weapon.

-2- In his trial testimony, Couch told the jury that on the morning of the

murder, a masked man entered Graves’ truck and forced him into the back seat,

instructing her to drive. During a struggle between Couch and the attacker, the gun

went off and Graves screamed. When the vehicle halted, the assailant ran off and

Couch discovered that Graves was dead.

As an admitted drug dealer, he was too frightened to call the police.

He parked the car in downtown Frankfort, collected Graves’ cell phone, his

weapon and the one used by the attacker. The latter he disposed of in the manner

testified to by Whitis.

Following a jury trial, Couch was convicted of murder, tampering

with physical evidence, and being a persistent felony offender, second degree. In

accordance with the jury’s recommendation, he was sentenced to fifty (50) years

for murder, five (5) years for tampering with physical evidence, enhanced to ten

(10) years by the persistent felony offender conviction, for a total sentence of sixty

(60) years. The Supreme Court affirmed his conviction in an unpublished

opinion.2 His arguments that his trial counsel allowed references to his alleged

involvement in the drug trade and that trial counsel failed to object to the

Commonwealth’s “send a message” statement during voir dire were rejected on

direct appeal.

2 Couch v. Commonwealth, No. 2011-SC-000603-MR, 2013 WL 658151 (Ky. Feb. 21, 2013). -3- On March 11, 2016, Couch sought postconviction relief by filing a

motion pursuant to RCr 11.42. He alleged that his trial counsel, Mark Bubenzer,

was ineffective by 1) allowing repeated references to his involvement in the drug

trade; 2) failing to object to the Commonwealth’s “send a message” argument

during voir dire; 3) failing to properly advise and prepare him for his testimony

and cross-examination in the guilt phase of his trial; and 4) for failing to

investigate and present mitigation evidence in the penalty phase.

On August 13, 2020, the trial court denied his motion without

conducting an evidentiary hearing, noting that a hearing is only required where

there is a question of fact that cannot be resolved by an examination of the record.

Fraser v. Commonwealth, 59 S.W.3d 448, 452 (Ky. 2001). The trial court then

applied the standard set forth in Strickland v. Washington, 466 U.S. 668, 104 S. Ct.

2052, 80 L. Ed. 2d 674 (1984) (adopted in Gall v. Commonwealth, 702 S.W.2d 37

(Ky. 1985)), denying Couch’s postconviction motion on the merits. However, in

so doing, the trial court considered the affidavit of Couch’s trial counsel as

tendered by the Commonwealth in support of its response.

In Knuckles v. Commonwealth, 421 S.W.3d 399 (Ky. App. 2014), the

movant sought postconviction relief, an evidentiary hearing and appointment of

counsel. Although the Commonwealth argued that no hearing was necessary, it

did tender the affidavits of Knuckles’ trial counsel and his investigator in support

-4- of its response. The trial court then relied upon those affidavits in denying

Knuckles’ motions.

On appeal, this Court concluded that:

The Commonwealth’s supplementation of the record by providing the circuit court affidavits was essentially an admission that the record was insufficient for resolution of Knuckles’ motion. If the Commonwealth had truly believed the record was sufficient, then its objection to the RCr 11.42 motion . . . should have referred to that record alone, and should not have required supplemental affidavits. If, on the other hand, the Commonwealth believed the record was insufficient and necessitated sworn statements by trial counsel and the investigator, then it should have raised no objection to Knuckles’ request for a hearing and conceded that one was necessary.

Id. at 401.

In Knuckles, as here, the case of Commonwealth v. Elza, 284 S.W.3d

118 (Ky. 2009), was cited in support of the use of affidavits in the resolution of

RCr 11.42 cases. The Knuckles Court dismissed this argument as dispositive on

the issue, stating that, “Nowhere, however, did the Supreme Court state that the use

of affidavits could take the place of a hearing.” Knuckles, 421 S.W.3d at 402.

In Commonwealth v. Searight, 423 S.W.3d 226, 231 (Ky. 2014), the

Kentucky Supreme Court noted that, where, as here, no evidentiary hearing is held,

the appellate court’s review is “limited to determining ‘whether the motion on its

face states grounds that are not conclusively refuted by the record and which, if

-5- true, would invalidate the conviction.’” Therefore, this Court will proceed with its

analysis of the arguments raised in Couch’s motion.

The trial court found that trial counsel’s references to his drug dealing

history during voir dire were not evidence of incompetence but were in fact a

useful tool in enabling him to determine which potential jurors should be stricken

from the panel. Further, there was substantial, admissible evidence of record

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Donnie E. Johnson v. Ricky Bell
344 F.3d 567 (Sixth Circuit, 2003)
Fraser v. Commonwealth
59 S.W.3d 448 (Kentucky Supreme Court, 2001)
Gall v. Commonwealth
702 S.W.2d 37 (Kentucky Supreme Court, 1985)
Commonwealth v. Elza
284 S.W.3d 118 (Kentucky Supreme Court, 2009)
Hodge v. Commonwealth
68 S.W.3d 338 (Kentucky Supreme Court, 2002)
Knuckles v. Commonwealth
421 S.W.3d 399 (Court of Appeals of Kentucky, 2014)
Commonwealth v. Searight
423 S.W.3d 226 (Kentucky Supreme Court, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Alastar Martel Couch v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alastar-martel-couch-v-commonwealth-of-kentucky-kyctapp-2022.