Brenda Hardin v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedOctober 19, 2023
Docket2022 CA 001096
StatusUnknown

This text of Brenda Hardin v. Commonwealth of Kentucky (Brenda Hardin 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
Brenda Hardin v. Commonwealth of Kentucky, (Ky. Ct. App. 2023).

Opinion

RENDERED: OCTOBER 20, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-1096-MR

BRENDA HARDIN APPELLANT

APPEAL FROM MUHLENBERG CIRCUIT COURT v. HONORABLE BRIAN WIGGINS, JUDGE ACTION NO. 14-CR-00156

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: DIXON, GOODWINE, AND TAYLOR, JUDGES.

GOODWINE, JUDGE: Brenda Hardin (“Hardin”), proceeding pro se, appeals an

order of the Muhlenberg Circuit Court denying her request for post-conviction

relief under CR1 60.02. After careful review, finding no error, we affirm.

On August 11, 2015, Hardin was convicted of murdering her ex-

husband and was sentenced to life in prison. Hardin v. Commonwealth, No. 2015-

1 Kentucky Rules of Civil Procedure. SC-000614-MR, 2016 WL 7665872, at *1 (Ky. Dec. 15, 2016). Her conviction

and sentence were affirmed on direct appeal. Id. at *4.

On August 8, 2022, Hardin filed a pro se motion under CR 60.02(a),

(e), and (f); CR 60.03;2 and multiple constitutional provisions. This was Hardin’s

first post-conviction motion challenging her conviction. The circuit court denied

her motion finding all but one of the issues raised in her motion were addressed “at

numerous pretrial hearings and during the actual trial of this matter (i.e., concerns

regarding Defendant’s purported mental illness, suicide attempt, and her

conversations with the investigating officer while Defendant was in the hospital).

These matters were addressed by the Supreme Court of Kentucky, which affirmed

[Hardin’s] judgment.” Record (R.) at 29. Additionally, the circuit court rejected

Hardin’s argument that the court held her decision not to testify against her in

sentencing her. The circuit court found Hardin’s claim was “in no way supported

by the record. This Court imposed the lawful punishment recommended by the

jury.” R. at 30. The circuit court also found the “jury was clearly instructed in

writing by this Court that Defendant’s decision not to testify ‘cannot be used as an

2 Though not addressed by the circuit court, Hardin did not file an independent action as CR 60.03 requires. Hardin only mentions CR 60.03 in the caption of her motion, and the body of her motion only raises arguments under CR 60.02. Thus, the circuit court treated Hardin’s motion purely as one brought under CR 60.02.

-2- inference of guilt and should not prejudice her in any way.’” Id.; Trial Record at

273, 285. This appeal followed.

On appeal, Hardin argues the circuit court abused its discretion in

denying her CR 60.02 motion because: (1) vital information about her mental

health, lack of criminal history, and emotional distress was not provided to the jury

before sentencing; (2) the circuit court should have instructed the jury on lesser

included offenses; and (3) these errors amount to cumulative error. Hardin’s brief

also includes vague ineffective assistance of counsel arguments throughout, and

her discussion of the standard of review is solely about ineffective assistance of

counsel without referencing RCr3 11.42.

“We review the denial of a CR 60.02 motion under an abuse of

discretion standard.” Foley v. Commonwealth, 425 S.W.3d 880, 886 (Ky. 2014)

(citing Brown v. Commonwealth, 932 S.W.2d 359, 361 (Ky. 1996)). “The test for

abuse of discretion is whether the trial judge’s decision was arbitrary,

unreasonable, unfair, or unsupported by sound legal principles.” Commonwealth v.

English, 993 S.W.2d 941, 945 (Ky. 1999).

The purpose of CR 60.02 is to provide “for relief that is not available

by direct appeal and not available under RCr 11.42. The movant must demonstrate

why he is entitled to this special, extraordinary relief. ” Gross v. Commonwealth,

3 Kentucky Rules of Criminal Procedure.

-3- 648 S.W.2d 853, 856 (Ky. 1983). Relief under CR 60.02 “is an extraordinary and

residual remedy to correct or vacate a judgment upon facts or grounds, not

appearing on the face of the record and not available by appeal or otherwise, which

were not discovered until after rendition of judgment without fault of the party

seeking relief.” Id. (quoting Harris v. Commonwealth, 296 S.W.2d 700 (Ky.

1956)). “In summary, CR 60.02 is not a separate avenue of appeal to be pursued in

addition to other remedies, but is available only to raise issues which cannot be

raised in other proceedings.” McQueen v. Commonwealth, 948 S.W.2d 415, 416

(Ky. 1997).

Before addressing Hardin’s enumerated arguments, we will address

the ineffective assistance of counsel standard of review and arguments woven

throughout her brief. To the extent Hardin makes ineffective assistance of counsel

claims, they are unpreserved as she did not raise them in her underlying motion.

Hardin’s brief seems to commingle elements of a motion for relief under CR 60.02

and ineffective assistance of counsel under RCr 11.42. As noted above, these are

two separate mechanisms for relief that may be pursued after a conviction is

affirmed on direct appeal. Hardin failed to raise her ineffective assistance of

counsel arguments below and does not request review for palpable error. Id. As

the Supreme Court of Kentucky has stated, “appellants will not be permitted to

feed one can of worms to the trial judge and another to the appellate court.” Elery

-4- v. Commonwealth, 368 S.W.3d 78, 97 (Ky. 2012). Thus, we decline to address any

ineffective assistance of counsel arguments further.

Regarding the 60.02 motion, first, Hardin argues the circuit court

abused its discretion in denying her motion because vital information about her

mental health, lack of criminal history, and emotional distress was not provided to

the jury before sentencing. The record clearly refutes Hardin’s claim. During the

trial, evidence was presented regarding her erratic behavior, that she was not able

to move on after her divorce, that she was jealous of her ex-husband’s new

relationship, her mental health issues, her suicide attempt, and her lack of criminal

history. This evidence was presented in coordination with her extreme emotional

disturbance defense.

Additionally, the Supreme Court of Kentucky discussed evidence of

Hardin’s suicide attempt. Testimony regarding “pill bottles and their connection to

[Hardin’s] attempted suicide” and “suicide notes to various family members” were

presented at trial. Hardin, 2016 WL 7665872, at *3.

As the record shows this evidence was not withheld and was

presented to the jury prior to sentencing, Hardin’s claim lacks merit. Additionally,

her argument is procedurally barred because the issues raised were or should have

been raised on direct appeal. Thus, the circuit court did not abuse its discretion in

rejecting Hardin’s argument.

-5- Second, Hardin argues the circuit court should have instructed the jury

on a lesser included offense. The Commonwealth notes Hardin’s argument is

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Related

Harris v. Commonwealth
296 S.W.2d 700 (Court of Appeals of Kentucky (pre-1976), 1956)
McQueen v. Commonwealth
948 S.W.2d 415 (Kentucky Supreme Court, 1997)
Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
Brown v. Commonwealth
932 S.W.2d 359 (Kentucky Supreme Court, 1996)
Gross v. Commonwealth
648 S.W.2d 853 (Kentucky Supreme Court, 1983)
Elery v. Commonwealth
368 S.W.3d 78 (Kentucky Supreme Court, 2012)
Foley v. Commonwealth
425 S.W.3d 880 (Kentucky Supreme Court, 2014)

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