Brenda Porter v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedFebruary 14, 2024
Docket2023 SC 0107
StatusUnknown

This text of Brenda Porter v. Commonwealth of Kentucky (Brenda Porter 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
Brenda Porter v. Commonwealth of Kentucky, (Ky. 2024).

Opinion

IMPORTANT NOTICE NOT TO BE PUBLISHED OPINION

THIS OPINION IS DESIGNATED “NOT TO BE PUBLISHED.” PURSUANT TO THE RULES OF CIVIL PROCEDURE PROMULGATED BY THE SUPREME COURT, RAP 40(D), THIS OPINION IS NOT TO BE PUBLISHED AND SHALL NOT BE CITED OR USED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE; HOWEVER, UNPUBLISHED KENTUCKY APPELLATE DECISIONS, RENDERED AFTER JANUARY 1, 2003, MAY BE CITED FOR CONSIDERATION BY THE COURT IF THERE IS NO PUBLISHED OPINION THAT WOULD ADEQUATELY ADDRESS THE ISSUE BEFORE THE COURT. OPINIONS CITED FOR CONSIDERATION BY THE COURT SHALL BE SET OUT AS AN UNPUBLISHED DECISION IN THE FILED DOCUMENT AND A COPY OF THE ENTIRE DECISION SHALL BE TENDERED ALONG WITH THE DOCUMENT TO THE COURT AND ALL PARTIES TO THE ACTION. RENDERED: FEBRUARY 15, 2024 NOT TO BE PUBLISHED

Supreme Court of Kentucky 2023-SC-0107-MR

BRENDA PORTER APPELLANT

ON APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE ANNIE O’CONNELL, JUDGE NO. 18-CR-000220

COMMONWEALTH OF KENTUCKY APPELLEE

MEMORANDUM OPINION OF THE COURT

AFFIRMING

A Jefferson County jury found Appellant Brenda Porter (Porter) guilty of

murder, tampering with physical evidence, and abusing a corpse. In

accordance with the jury’s recommendation, the trial court sentenced her to a

total of forty years in prison. Porter brings two unpreserved issues on appeal.

Porter claims that (1) during voir dire, the Commonwealth made improper

comments upon her right to remain silent, and (2) the trial court failed to

confirm Porter’s continued desire to be absent from the courtroom during the

cross-examination of the medical examiner. We conclude palpable error relief

is not warranted.

FACTUAL AND PROCEDURAL BACKGROUND

On January 19, 2018, Porter killed David Burch (Burch). Two days later,

police were called to perform a welfare check at the residence shared by Burch and Porter. The caller informed the police that a “black female named Brenda

may have harmed or killed the owner of the vehicle that she is currently

driving.” The police found Burch’s body outside, wrapped in bedding and

plastic tarp. Porter was pulled over in a traffic stop. She voluntarily went to

the police station and gave a Mirandized 1 statement.

Porter described her long-term, sometime romantic, relationship with

Burch. She shared details of an on-going argument she and Burch had been

having and the fight that occurred when she returned home from work the

morning of January 19. Porter admitted that she lost control and that she hit

Burch on the head multiple times with a heavy statue. According to the

medical examiner’s testimony, Burch had multiple lacerations on his head from

blunt force trauma, resulting in Burch’s death. Porter explained in her

statement that she did not call 911 after the altercation because she did not

think she would be believed. Porter also stated in her interview that she did

not know Burch was dead until later that evening, and, after discovering his

death, did not know what to do. Porter described wrapping Burch’s body in

blankets, moving his body, and cleaning the room where the fight occurred.

Porter was indicted for committing murder, tampering with physical

evidence, and abusing a corpse. Porter was tried in a five-day trial. The

Commonwealth called fourteen witnesses. Porter testified on her own behalf,

claiming she acted in self-defense. The jury found Porter guilty of all three

1 Miranda v. Arizona, 384 U.S. 436 (1966).

2 crimes. The trial court imposed the sentence recommended by the jury: forty

(40) years for murder, five (5) years for tampering with physical evidence, and

twelve (12) months for abuse of a corpse, running concurrently. This appeal

followed.

ANALYSIS

Porter brings two issues on appeal. As noted above, Porter argues that

(1) during voir dire, the Commonwealth made improper comments upon her

right to remain silent, and (2) the trial court failed to confirm Porter’s continued

desire to be absent from the courtroom during the cross-examination of the

medical examiner. Because these issues are unpreserved, Porter requests

palpable error review under Kentucky Rule of Criminal Procedure (RCr) 10.26.

RCr 10.26 provides:

A palpable error which affects the substantial rights of a party may be considered by the court on motion for a new trial or by an appellate court on appeal, even though insufficiently raised or preserved for review, and appropriate relief may be granted upon a determination that manifest injustice has resulted from the error. An error is palpable when it is “easily perceptible, plain, obvious and readily

noticeable.” Brewer v. Commonwealth, 206 S.W.3d 343, 349 (Ky. 2006)

(quoting Burns v. Level, 957 S.W.2d 218, 222 (Ky. 1997)). To obtain relief, the

error must be “so manifest, fundamental and unambiguous that it threatens

the integrity of the judicial process.” Martin v. Commonwealth, 207 S.W.3d 1, 5

(Ky. 2006). Manifest injustice may be found to have occurred when, after

consideration of the record, the defect alleged “seriously affect[ed]

3 the fairness, integrity, or public reputation of the proceeding.” Id. at 4 (quoting

United States v. Cotton, 535 U.S. 625, 631 (2002)).

Porter’s claims are addressed in turn.

I. UNDER PALPABLE ERROR REVIEW, THE COMMONWEALTH’S VOIR DIRE COMMENTS DO NOT WARRANT RELIEF.

During voir dire, the Commonwealth asked the venire why the burden of

proof in a criminal case is “beyond a reasonable doubt.” After a juror

responded that the standard is meant to avoid a wrongful conviction, the

following exchange occurred between the Commonwealth and the venire.

Commonwealth Attorney: Yes. Um. So the burden or proof is beyond a reasonable doubt and the reason for that, yes, is the last thing we ever want is someone being wrongfully convicted. That is my nightmare. I do not want that. And with a criminal case, liberties are at stake. Right? Ms. Porter’s liberties are at stake. That is why we have such a high burden — beyond a reasonable doubt. That is my burden, and I accept that. And I want each and every one of you to hold me to that burden. Can everyone do that? Yes?

Venire: Yes.

Commonwealth Attorney: Okay. Thank you. Um. And so again, it is my burden to prove, it is my job to prove my case beyond a reasonable doubt. With that said, [the defense attorney] and the defense; they do not have to do anything. They can sit here throughout this entire trial and not say anything. And that is their right. Does everyone understand that? Is anyone going to hold that against them, if for some reason [the defense attorney] decides he doesn’t want to ask any questions, or throughout this trial he may not ask witnesses any questions? He may not put on any proof; any defense. He is entitled to that. Because again, the burden is on me.

Based upon the portion of the exchange highlighted in bold font, Porter

argues that the Commonwealth’s statements were an improper comment upon

4 her right to remain silent under the Fifth Amendment and Kentucky’s

procedural rules. Porter contends that the Commonwealth’s election to

comment on her right to remain silent during voir dire, and before defense

counsel had the opportunity to first address the issue, is substantial error.

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Related

Wilson v. United States
149 U.S. 60 (Supreme Court, 1893)
Malloy v. Hogan
378 U.S. 1 (Supreme Court, 1964)
Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Illinois v. Allen
397 U.S. 337 (Supreme Court, 1970)
United States v. Cotton
535 U.S. 625 (Supreme Court, 2002)
Tad R. Knowles v. United States
224 F.2d 168 (Tenth Circuit, 1955)
Robert C. Butler v. Jim Rose, Warden
686 F.2d 1163 (Sixth Circuit, 1982)
State v. Tribble
2012 VT 105 (Supreme Court of Vermont, 2012)
People v. Modesto
398 P.2d 753 (California Supreme Court, 1965)
Hanf v. State
1977 OK CR 41 (Court of Criminal Appeals of Oklahoma, 1977)
Girdner v. State
1973 OK CR 170 (Court of Criminal Appeals of Oklahoma, 1973)
Thompson v. Commonwealth
147 S.W.3d 22 (Kentucky Supreme Court, 2004)
Fugate v. Commonwealth
62 S.W.3d 15 (Kentucky Supreme Court, 2001)
Brewer v. Commonwealth
206 S.W.3d 343 (Kentucky Supreme Court, 2006)
Ragland v. Commonwealth
191 S.W.3d 569 (Kentucky Supreme Court, 2006)
Sanders v. State
963 S.W.2d 184 (Court of Appeals of Texas, 1998)
Cuevas v. State
742 S.W.2d 331 (Court of Criminal Appeals of Texas, 1987)

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Brenda Porter v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brenda-porter-v-commonwealth-of-kentucky-ky-2024.