Brandon Blair v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedJune 20, 2025
Docket2023-SC-0296
StatusPublished

This text of Brandon Blair v. Commonwealth of Kentucky (Brandon Blair v. Commonwealth of Kentucky) 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
Brandon Blair v. Commonwealth of Kentucky, (Ky. 2025).

Opinion

RENDERED: JUNE 20, 2025 TO BE PUBLISHED

Supreme Court of Kentucky 2023-SC-0296-DG

BRANDON BLAIR APPELLANT

ON REVIEW FROM COURT OF APPEALS V. NOS. 2021-CA-0537, 2021-CA-0490, 2021-CA-0535, & 2021-CA-0536 JOHNSON CIRCUIT COURT NOS. 20-CR-00204, 20-CR-00205, 20-CR-00206 AND 20-CR-00207

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION OF THE COURT BY JUSTICE BISIG

AFFIRMING

Brandon Blair was separately indicted in Johnson Circuit Court for five

felony counts of trafficking in methamphetamine. As part of his conditional

release on bond, Blair agreed to appear at subsequent proceedings. After

failing to appear at a scheduled court date, Blair was charged in five separate

indictments of first-degree bail jumping—one charge for each underlying

trafficking indictment scheduled to be heard that day. Blair filed a motion to

dismiss four of the bail jumping charges based on double jeopardy, which the

trial court denied. He subsequently entered a conditional guilty plea and was

sentenced to a total of ten years in prison. The Court of Appeals affirmed his convictions. Having granted discretionary review and hearing oral arguments,

we affirm the Court of Appeals.

FACTS AND PROCEDURAL HISTORY

In August 2019, Brandon Blair was charged with five felony counts of

first-degree trafficking in methamphetamine and separately indicted for each

charge in Johnson Circuit Court. Blair was arraigned on all charges during

one court appearance and the trial court set the same $5,000 bond in each

case. A separate bond form was executed in each case which set forth

conditions, including a requirement to participate in a drug treatment program

and Blair’s promise to appear at subsequent proceedings. When Blair failed to

appear at his scheduled court date, he was charged in five separate

indictments of first-degree bail jumping—one bail jumping charge for each

underlying indictment scheduled to be heard that day—and charged with being

a persistent felony offender (PFO) in the second degree.

Following the bail jumping indictments, Blair moved to dismiss four of

the five bail jumping charges. He argued he only committed a single act of bail

jumping because he missed one court date, and further asserted that the latter

four indictments violated double jeopardy for punishing the same act of

nonappearance as the first indictment. The Commonwealth argued that Blair

committed five acts of nonappearance by missing a court date in each case.

The trial court agreed with the Commonwealth and denied Blair’s motion to

dismiss. Blair ultimately entered a plea agreement, specifically reserving his

right to appeal the double jeopardy issue, and was sentenced to five years in

2 prison. In the underlying trafficking cases, Blair also entered a plea agreement

to serve five years in prison for a total sentence of ten years. 1

On appeal, the Court of Appeals unanimously affirmed the trial court,

reasoning that the “unit of prosecution” for first-degree bail jumping is each

felony charge for which a defendant fails to appear. 2 The appellate court

pointed to the bail jumping statute, Kentucky Revised Statute (KRS)

520.070(1), which provides that

[a] person is guilty of bail jumping in the first degree when, having been released from custody by court order, with or without bail, upon condition that he will subsequently appear at a specified time and place in connection with a charge of having committed a felony, he intentionally fails to appear at that time and place.

The Court of Appeals noted that the legislature used “a charge” rather than

“one or more charges” and interpreted that language to express the legislature’s

intent to punish a defendant for failing to appear to answer a specific charge.

This Court granted discretionary review and heard oral arguments.

ANALYSIS

The sole issue presented in this appeal is whether five bail jumping

convictions, resulting from the singular failure to appear at one court

appearance, constitutes a violation of double jeopardy. Following careful

review, we conclude it does not.

1 The plea agreement dictated that Blair received one year on each of the

trafficking and bail jumping charges, all to run consecutively for a total sentence of ten years in prison. The PFO charges were dismissed.

2 Blair v. Commonwealth, 2021-CA-0490-MR, WL 3767202, at *3 (Ky. App. June

2, 2023). 3 The Double Jeopardy Clause of the Fifth Amendment to the United

States Constitution and Section 13 of the Kentucky Constitution preclude

multiple convictions for the same offense. It is inherent in the double jeopardy

prohibition that the multiple convictions must arise from the same act. When

a defendant is convicted of violating one statute multiple times, we must

determine the unit of prosecution intended by the legislature to ensure each

conviction passes constitutional muster. This Court reviews questions of

statutory interpretation de novo, granting no deference to the lower courts.

Louisville & Jefferson Cnty. Metro. Sewer Dist. v. Bischoff, 248 S.W.3d 533, 535

(Ky. 2007).

“Our goal in statutory interpretation is to carry out the intent of the

legislature.” Bloyer v. Commonwealth, 647 S.W.3d 219, 224 (Ky. 2022). When

interpreting a statute,

we must look first to the plain language of a statute and, if the language is clear, our inquiry ends. We hold fast to the rule of construction that the plain meaning of the statutory language is presumed to be what the legislature intended, and if the meaning is plain, then the court cannot base its interpretation on any other method or source.

Univ. of Louisville v. Rothstein, 532 S.W.3d 644, 648 (Ky. 2017) (citations and

quotations omitted).

Blair argues that the pertinent statutory language is the condition

requiring a defendant to appear at a “specified time and place,” and thus the

unit of prosecution of the bail jumping statute is the missed court appearance.

We disagree. This position would allow the unit of prosecution for the bail

jumping statute to turn on administrative decisions regarding case scheduling 4 and whether to combine criminal indictments into one court date. Such an

interpretation based on administrative convenience is misplaced, and plainly

prioritizes court scheduling over the purpose of the bail jumping statute—to

hold defendants accountable for avoiding court processes and disrupting the

orderly administration of justice.

Blair was released on five separate bond orders, each of which

constituted a separate promise to appear in court to answer that particular

charge. His failure to appear resulted in five distinct injuries to the

administration of justice, despite missing a single court appearance.

Scheduling court appearances is an administrative matter and should certainly

yield to upholding the integrity of the legal process. If the unit of prosecution

were the single missed court appearance, it would thwart the authority to

require a defendant to answer for each crime, penalize the Commonwealth and

the courts for attempting to minimize appearances for attorneys and their

clients, and effectively remove accountability for multiple alleged criminal

offenses.

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