Alicia Thomas v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedFebruary 20, 2026
Docket2024-CA-0672
StatusUnpublished

This text of Alicia Thomas v. Commonwealth of Kentucky (Alicia Thomas 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
Alicia Thomas v. Commonwealth of Kentucky, (Ky. Ct. App. 2026).

Opinion

RENDERED: FEBRUARY 20, 2026; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-0672-MR

ALICIA THOMAS APPELLANT

APPEAL FROM BOONE CIRCUIT COURT v. HONORABLE JAMES R. SCHRAND, II, JUDGE ACTION NOS. 23-CR-00135 AND 23-CR-00136

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: COMBS, A. JONES, AND KAREM, JUDGES.

JONES, A., JUDGE: Alicia Thomas appeals from the May 3, 2024 order of the

Boone Circuit Court revoking her probation and imposing a sentence of

imprisonment. Thomas argues the circuit court abused its discretion by revoking

her probation, given the allegedly insufficient evidence and without adequately

considering alternative sanctions. Finding no error, we affirm. I. BACKGROUND

On March 15, 2023, Thomas entered guilty pleas in two Boone

Circuit Court cases. In Case No. 23-CR-00135, Thomas pleaded guilty to first-

degree possession of a controlled substance (methamphetamine), tampering with

physical evidence, possession of drug paraphernalia, and theft by unlawful taking.

In Case No. 23-CR-00136, she pleaded guilty to one count of theft of identity. By

judgments entered April 20, 2023, the circuit court imposed an aggregate sentence

of six-years’ imprisonment, which was probated for five years.

Thomas’s probation conditions included, among other requirements,

that she refrain from illegal drug use, comply with substance-abuse treatment,

report as directed, avoid new criminal conduct, and avoid association with

convicted felons. In August 2023, Thomas tested positive for methamphetamines

and amphetamines during routine drug screening. Although she initially denied

illegal drug use, Thomas later admitted to using these illegal substances in

violation of probation conditions. She agreed to graduated sanctions through the

Division of Probation and Parole, which included enhanced supervision, referral to

out-patient substance-abuse treatment, and a requirement that she meet with a

social-service clinician and comply with all treatment recommendations.

-2- Despite being afforded additional treatment in the community,

Thomas’s compliance did not improve. In October 2023, Probation and Parole

filed a violation report alleging that Thomas had absconded from supervision and

failed to comply with treatment requirements. A warrant was issued for her arrest.

In February 2024, a second violation report was filed alleging continued illegal

drug use, a new misdemeanor charge, and association with a convicted felon.

After Thomas was taken into custody, she was provided with a written

copy of the charges and appointed counsel to assist her. The circuit court

conducted a probation revocation hearing that proceeded in two phases. An

evidentiary hearing was held on March 14, 2024, at which the court heard

testimony from Thomas and her probation and parole officer, as well as the

argument of counsel. During her testimony, Thomas admitted most of the alleged

violations, including absconding, continued use of illegal substances, and the new

misdemeanor charge. At Thomas’s request, disposition was continued to allow her

to pursue admission into drug court.

The disposition phase of the revocation hearing was held on April 25,

2024. After Thomas was denied entry into drug court and failed to present any

viable alternative treatment option, the circuit court revoked her probation. In its

written order entered May 3, 2024, the circuit court found that Thomas violated the

conditions of her probation by using controlled substances, absconding from

-3- supervision, committing a new misdemeanor offense, and associating with a

convicted felon. After the court found that Thomas posed a significant risk to the

community and could not be appropriately managed in the community, it revoked

her probation, imposing a three-year term of imprisonment. This appeal followed.

II. ANALYSIS

“The conditions of probation and conditional discharge shall be such

as the court, in its discretion, deems reasonably necessary to ensure that the

defendant will lead a law-abiding life or to assist him or her to do [so].” KRS1

533.030(1). Before the expiration of a defendant’s probation, “[t]he court may

summon the defendant to appear before it or may issue a warrant for his arrest

upon a finding of probable cause to believe that he has failed to comply with a

condition of the sentence[.]” KRS 533.050(1)(a). A defendant charged with a

probation violation is entitled to written notice of the grounds for revocation or

modification, representation by counsel, and a hearing on the charge. KRS

533.050(2).

Following a hearing, a defendant found to have violated probation is

subject to “two possible outcomes: revocation and possible incarceration, KRS

439.3106(1), or the imposition of sanctions ‘other than revocation,’ KRS

439.3106(2).” Commonwealth v. Andrews, 448 S.W.3d 773, 777 (Ky. 2014).

1 Kentucky Revised Statutes.

-4- “[I]ncarceration for failure to comply with the conditions of supervision” is an

available option when the defendant’s “noncompliance constitutes a significant

risk to prior victims of the supervised individual or the community at large, and

cannot be appropriately managed in the community[.]” KRS 439.3106(1)(a).

Proper considerations in making these determinations include, but are not limited

to, the nature of the violation and the defendant’s prior criminal history. Andrews,

448 S.W.3d at 780-81.

We review a trial court’s probation revocation decision under the

deferential abuse-of-discretion standard. Commonwealth v. Lopez, 292 S.W.3d

878 (Ky. 2009); Kendrick v. Commonwealth, 664 S.W.3d 731, 734 (Ky. App.

2023). As applied in the context of probation revocation, “we will not hold a trial

court to have abused its discretion unless its decision cannot be located within the

range of permissible decisions allowed by a correct application of the facts to the

law.” McClure v. Commonwealth, 457 S.W.3d 728, 730 (Ky. App. 2015) (citing

Miller v. Eldridge, 146 S.W.3d 909, 915 n.11 (Ky. 2004)).

Thomas argues that the circuit court violated her due-process rights by

revoking her probation without first conducting an evidentiary hearing. This

assertion is belied by the record. The circuit court conducted the probation

revocation hearing in two phases. The evidentiary phase occurred on March 14,

2024, during which the court heard testimony from Thomas and her probation and

-5- parole officer, as well as the argument of counsel. During her testimony, Thomas

admitted multiple violations of the conditions of her probation, including

absconding from supervision, continued use of illegal substances, and the

commission of a new misdemeanor offense. At Thomas’s request, the circuit court

continued the matter to allow her to pursue admission into drug court. After

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Related

Miller v. Eldridge
146 S.W.3d 909 (Kentucky Supreme Court, 2004)
Commonwealth v. Lopez
292 S.W.3d 878 (Kentucky Supreme Court, 2009)
Commonwealth v. Andrews
448 S.W.3d 773 (Kentucky Supreme Court, 2014)
McClure v. Commonwealth
457 S.W.3d 728 (Court of Appeals of Kentucky, 2015)
Hall v. Commonwealth
566 S.W.3d 578 (Court of Appeals of Kentucky, 2018)

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