Alred v. Commonwealth, Judicial Conduct Commission

395 S.W.3d 417, 2012 WL 3000383
CourtKentucky Supreme Court
DecidedJuly 28, 2012
DocketNo. 2011-SC-000558-RR
StatusPublished
Cited by20 cases

This text of 395 S.W.3d 417 (Alred v. Commonwealth, Judicial Conduct Commission) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alred v. Commonwealth, Judicial Conduct Commission, 395 S.W.3d 417, 2012 WL 3000383 (Ky. 2012).

Opinions

Opinion of the Court by

Chief Justice MINTON.

Russell D. Aired, Judge of the 26th Judicial Circuit of Kentucky, became the focus of a lengthy investigation by the Judicial Conduct Commission, culminating in formal charges consisting of twenty allegations of misconduct in office. Following an adversarial hearing on these charges, the commission found official misconduct on nine of the charges and ordered Judge Aired removed from office.

On review by this Court, Judge Aired urges us to overturn the commission’s order. He contends:

1) He was denied fundamental due process because “misconduct in office” is an unconstitutionally vague standard, and the provisions of Kentucky’s Code of Judicial Conduct relied upon by the commission lack specificity, rendering those provisions unconstitutional facially and as applied;
2) He was denied his rights under the Sixth Amendment of the United States Constitution;
3) His rights under Supreme Court Rules (SCR) 4.170 were violated; and
4) The commission’s findings are the clearly erroneous result of the misapplication of law, and the order is not supported by the evidence and is generally indicative of the commission’s lack of. impartiality.

After reviewing the lengthy record, we affirm the order of the commission as to eight counts of official misconduct and the commission’s decision to remove Judge Aired from office. We reverse the commission’s findings and legal conclusions as clearly erroneous as to Count V.

I. PROCEDURAL HISTORY.

After receiving an initial complaint, the commission authorized an investigation of Judge Alred’s activities. The commission notified Judge Aired of the investigation, and he appeared at several informal conferences with the commission at which he either represented himself or had counsel assist him. At these informal conferences, Judge Aired received factual information gathered in the investigation, and the commission gave him an opportunity to present other information bearing on the investigation.

At the conclusion of the investigation, the commission issued formal charges against Judge Aired, consisting of twenty counts of violating the Kentucky Code of Judicial Conduct. Ultimately, the commission dismissed eleven of those counts.1

Following issuance of the charges, the commission conducted a formal hearing. Judge Aired attended the hearing and, acting as his own counsel, presented his defense.2

[423]*423One month later, the commission issued its ruling. The commission found by clear and convincing evidence that Judge Aired committed nine violations of the Code of Judicial Conduct. The order from the commission also expressed concern over Judge Alred’s lack of candor in his testimony before the commission. Specifically, the commission stated that “even when confronted with videotapes of his actions and orders which were clear on their face, [Judge Aired] continued to assert positions which were, at best, disingenuous and, at worst, blatant misrepresentations.” And, ultimately, the commission concluded that Judge Alred’s actions “show[ed] a blatant and persistent failure to uphold the impartiality and integrity of the judiciary.”

In its Findings of Fact, Conclusions of Law, and Final Order, the commission voted unanimously to remove Judge Aired from office in accordance with its authority under Section 121 of the Kentucky Constitution 3 and SCR 4.020.4 It is from Judge Alred’s timely appeal of the commission’s order that we review this matter.

II. ANALYSIS.

A. Judge Aired was not Denied Due Process. SCR 4.020 and 4.300 (Judicial Canons 1 and 2A) are not Unconstitutional Facially or as Applied.

Although this Court has addressed some due process and constitutional issues with respect to the commission’s removal authority and our judicial canons, we have not done so with respect to the particular rules and canons that Judge Aired calls into question. Judge Aired contends that his removal for “misconduct in office,”5 which he was found to have committed on nine counts, is impermissible because “misconduct in office” is an unconstitutionally vague standard. And he claims Canon 16 and Canon 2A7 lack the necessary specificity to define an objective standard, thereby allowing the commission too much discretion to determine when a violation occurs.

Although Kentucky has not discussed whether these particular rules violate the Constitution and due process, published [424]*424opinions in other states have addressed similar issues. Other state courts have found that “[t]he test for determining whether the [judicial conduct standards] are vague is whether they convey to a judge a sufficiently definite warning of the proscribed conduct when measured by common understanding and practice.”8 “The constitutionality of necessarily broad standards of professional conduct has long been recognized.”9 And it is generally understood that “a greater degree of flexibility and breadth is permitted with respect to judicial disciplinary rules and statutes than is allowed in criminal statutes,” because they are meant to achieve different goals — maintenance of judicial standards as opposed to punishment for criminal conduct.10

In support of his position, Judge Aired cites some limited case law on vagueness with respect to the law; but his leading authority discusses a city ordinance.11 Judge Aired correctly asserts that Grayned v. City of Rockford stands for the proposition that a law must be written so that a person of ordinary intelligence would have a reasonable opportunity to know what act is prohibited.12 But our Code of Judicial Conduct is not a general criminal or civil statute designed to guide the average citizen. Our Code of Judicial Conduct is an established set of professional standards that are in place to ensure the fitness of the judiciary. With this important distinction in mind, we turn to SCR 4.020 and Canons 1 and 2A of the Kentucky Code of Judicial Conduct.

I. SCR 4.020(1) (b)(i).

The authority to impose discipline upon judges for misconduct in office arises from Section 121 of the Kentucky Constitution, which says that a judge may be suspended without pay or removed from office “for good cause.” This constitutional provision is codified in SCR 4, including SCR 4.020(l)(b)(i), which allows the commission to impose sanctions against a judge who engages in misconduct. The Kentucky Code of Judicial Conduct defines misconduct through its canons and commentary.

In 1978, this Court concluded that the words “for good cause” found in Kentucky’s Constitution supply sufficiently definite notice to inform a judge of the type of conduct for which the judge could be disciplined.13 In Nicholson v. Judicial Retirement and Removal Comm’n, Judge S. Rush Nicholson challenged his censure on the grounds that the standard “for good cause” was too vague to identify what type of behavior might subject him to censure.14 The Nicholson court stated,

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Cite This Page — Counsel Stack

Bluebook (online)
395 S.W.3d 417, 2012 WL 3000383, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alred-v-commonwealth-judicial-conduct-commission-ky-2012.