Billy Bennett v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedJanuary 17, 2025
Docket2023-CA-1443
StatusUnpublished

This text of Billy Bennett v. Commonwealth of Kentucky (Billy Bennett 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
Billy Bennett v. Commonwealth of Kentucky, (Ky. Ct. App. 2025).

Opinion

RENDERED: JANUARY 17, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-1443-MR

BILLY BENNETT APPELLANT

APPEAL FROM RUSSELL CIRCUIT COURT v. HONORABLE SARA B. GREGORY, JUDGE ACTION NO. 17-CR-00187

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; ECKERLE AND A. JONES, JUDGES.

ECKERLE, JUDGE: Appellant, Billy Bennett, pro se (“Bennett”), seeks review of

an order of the Russell Circuit Court denying his motion to vacate his conviction

and sentence pursuant to Kentucky Rule of Criminal Procedure (“RCr”) 11.42.

Bennett contends that his guilty plea was tainted by ineffective assistance of

counsel. We agree with the Trial Court that Bennett presented no evidence of

deficient performance or prejudice sufficient to warrant setting aside his guilty

plea. Hence, we affirm. On November 28, 2017, a Russell County Grand Jury returned an

indictment charging Bennett with multiple counts of Rape in the First Degree,

Sodomy in the First Degree, and Incest regarding sexual abuse perpetrated against

his two minor step-daughters between 2004 and 2017. Following his arrest,

Bennett made statements to the police admitting to the crimes.

On January 29, 2019, Bennett accepted a plea offer to many reduced

charges with a sentence recommendation of a total of 30 years to serve.

Approximately six months later, on July 15, 2019, the Trial Court entered a

judgment imposing the recommended sentence.

More than three years later, on April 25, 2022, Bennett filed a motion

pro se to alter, amend, or vacate his sentence. In his motion, Bennett alleged that:

(1) he had received inadequate notice of the charges; (2) counsel had failed to

investigate and obtain discovery material; and (3) counsel had failed to prepare and

develop a trial strategy. The Trial Court held an evidentiary hearing at which

Bennett and his trial counsel testified.

More than 18 months after Bennett filed his pro se motion, on

November 13, 2023, the Trial Court issued an order of denial. With regard to the

first claim, the Trial Court found that the indictment was valid on its face; Bennett

had the opportunity to seek a more specific bill of particulars from the

Commonwealth requesting detailed allegations against him; and he failed to do so.

-2- On the second and third claims, the Trial Court found no evidence that trial

counsel’s performance was deficient or that it affected Bennett’s decision to plead

guilty. Bennett now appeals from this order. Additional facts will be set forth

below as necessary.

To prevail on an ineffective assistance of counsel claim, a movant

must show that his counsel’s performance was deficient and that, but for the

deficiency, the outcome would have been different. Strickland v. Washington, 466

U.S. 668, 687, 104 S. Ct. 2052, 2064, 80 L. Ed. 2d 674 (1984). The standard for

assessing counsel’s performance is whether the alleged acts or omissions were

outside the wide range of prevailing, professional norms based on an objective

standard of reasonableness. Id. at 688-89, 104 S. Ct. at 2065. A court must

indulge a strong presumption that counsel’s conduct falls within the wide range of

reasonable, professional assistance. Id. The defendant bears the burden of

identifying specific acts or omissions alleged to constitute deficient performance.

Id. at 690, 104 S. Ct. at 2066.

In the context of a guilty plea, the Trial Court must consider the

totality of the circumstances surrounding the guilty plea, evaluating whether errors

by trial counsel significantly influenced the defendant’s decision to plead guilty

such that the Trial Court should have a reason to doubt the voluntariness and

validity of the plea. Commonwealth v. Rank, 494 S.W.3d 476, 481 (Ky. 2016).

-3- See also Stiger v. Commonwealth, 381 S.W.3d 230, 237 (Ky. 2012), and

Commonwealth v. Elza, 284 S.W.3d 118, 120-21 (Ky. 2009). When an evidentiary

hearing is held, RCr 11.42(6) requires the Trial Court to make findings on the

material issues of fact, which we review under a clearly erroneous standard.

Kentucky Rules of Civil Procedure (“CR”) 52.01.

Bennett first argues that his trial counsel failed to protect his rights

adequately by neglecting to object to the sufficiency of the charges set forth in the

indictment. But as the Trial Court noted, an indictment is sufficient if it fairly

informs the defendant of the nature of the crimes with which he is charged, without

detailing the factual elements. Howard v. Commonwealth, 554 S W 2d 375, 377

(Ky. 1977); see also RCr 6.10 and RCr 6.12. The indictment in this case set out

the nature of the charges, the approximate dates the offenses occurred, and the

victims involved. We agree with the Trial Court that the indictment was sufficient

on its face.

Additionally, a defect in an indictment is deemed waived unless raised

by a timely objection. Stark v. Commonwealth, 828 S.W.2d 603, 605 (Ky. 1991),

overruled on other grounds by Thomas v. Commonwealth, 931 S.W.2d 446 (Ky.

1996). Bennett’s trial counsel testified that she considered filing a request for a

more specific bill of particulars and discussed that option with Bennett. However,

she decided that such a motion was unnecessary because the discovery and the

-4- statements provided by the victims were specific in the time frames and acts

alleged. Based upon this uncontroverted evidence, we agree with the Trial Court

that Bennett failed to establish that his guilty plea was influenced by trial counsel’s

failure to challenge the indictment or bill of particulars.

Bennett next argues that he did not knowingly and voluntarily make

his guilty plea because his trial counsel failed to investigate sufficiently and obtain

readily available discovery material. This argument essentially encompasses the

second and third grounds that he had raised to the Trial Court.

It is well-established law that trial counsel must undertake a

reasonable investigation into facts and law that support a client’s defense. Wiggins

v. Smith, 539 U.S. 510, 521-22, 123 S. Ct. 2527, 2535, 156 L. Ed. 2d 471 (2003).

However, “[a] reasonable investigation is not an investigation that the best criminal

defense lawyer in the world, blessed not only with unlimited time and resources,

but also with the benefit of hindsight, would conduct.” Haight v. Commonwealth,

41 S.W.3d 436, 446 (Ky. 2001), overruled on other grounds by Leonard v.

Commonwealth, 279 S.W.3d 151 (Ky. 2009). The focus of the inquiry must be on

whether trial counsel’s decision to refrain from pursuing evidence or defenses was

objectively reasonable under all the circumstances. Wiggins, 539 U.S. at 523, 123

S. Ct. at 2536.

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Related

Boykin v. Alabama
395 U.S. 238 (Supreme Court, 1969)
Blackledge v. Allison
431 U.S. 63 (Supreme Court, 1977)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Wiggins v. Smith, Warden
539 U.S. 510 (Supreme Court, 2003)
Edmonds v. Commonwealth
189 S.W.3d 558 (Kentucky Supreme Court, 2006)
Commonwealth v. Elza
284 S.W.3d 118 (Kentucky Supreme Court, 2009)
Thomas v. Commonwealth
931 S.W.2d 446 (Kentucky Supreme Court, 1996)
Stark v. Commonwealth
828 S.W.2d 603 (Kentucky Supreme Court, 1991)
Leonard v. Commonwealth
279 S.W.3d 151 (Kentucky Supreme Court, 2009)
Haight v. Commonwealth
41 S.W.3d 436 (Kentucky Supreme Court, 2001)
David Stiger v. Commonwealth of Kentucky
381 S.W.3d 230 (Kentucky Supreme Court, 2012)
Commonwealth of Kentucky v. Douglas Rank
494 S.W.3d 476 (Kentucky Supreme Court, 2016)
Howard v. Commonwealth
554 S.W.2d 375 (Kentucky Supreme Court, 1977)

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