Brian Marcum v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedMay 8, 2026
Docket2024-CA-1235
StatusUnpublished

This text of Brian Marcum v. Commonwealth of Kentucky (Brian Marcum 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
Brian Marcum v. Commonwealth of Kentucky, (Ky. Ct. App. 2026).

Opinion

RENDERED: MAY 8, 2026; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-1235-MR

BRIAN MARCUM APPELLANT

APPEAL FROM CLINTON CIRCUIT COURT v. HONORABLE DAVID L. WILLIAMS, JUDGE ACTION NO. 23-CR-00050

COMMONWEALTH OF KENTUCKY APPELLEE

AND

NO. 2024-CA-1236-MR

APPEAL FROM CLINTON CIRCUIT COURT v. HONORABLE DAVID L. WILLIAMS, JUDGE ACTION NO. 23-CR-00050

COMMONWEALTH OF KENTUCKY APPELLEE OPINION AFFIRMING IN PART, REVERSING IN PART, AND REMANDING APPEAL NO. 2024-CA-1235-MR AND AFFIRMING APPEAL NO. 2024-CA-1236-MR

** ** ** ** **

BEFORE: CETRULO, A. JONES, AND TAYLOR, JUDGES.

TAYLOR, JUDGE: Brian Marcum brings Appeal No. 2024-CA-1235-MR from a

June 18, 2024, judgment of the Clinton Circuit Court sentencing Marcum to a total

of ten-years’ imprisonment. Marcum also brings Appeal No. 2024-CA-1236-MR

from a September 4, 2024, order of the Clinton Circuit Court denying Marcum’s

motion for judgment of acquittal. We affirm in part, reverse in part, and remand

Appeal No. 2024-CA-1235-MR, and we affirm Appeal No. 2024-CA-1236-MR.

On July 30, 2023, the Clinton County Sheriff received a request for a

welfare check of a residence located at 55 Cecil Way, as the residence’s windows

and doors had been open for a day or more. A deputy was dispatched to perform

the check. Upon arrival, the deputy observed that the front door and a window

were open, so he proceeded to knock on the front door. No one responded.

Thereupon, the deputy entered the home and observed a large marijuana plant in

the shower, a grow light, and drug paraphernalia. He then exited the house, and

the next day, a warrant was obtained and executed to search the residence. At the

time of the search, Marcum was at the house. A search of the house yielded a

-2- marijuana plant in a shower, a marijuana plant on the back deck, a planting tray

with small seedlings, a large quantity of plastic bags, and liquid growth hormone

for plants.

On August 1, 2023, the Clinton County Grand Jury indicted Marcum

upon the offenses of marijuana cultivation, possession of drug paraphernalia,

trafficking in marijuana (more than eight ounces), and with being a second-degree

persistent felony offender. A jury trial ensued. The jury found Marcum guilty of

marijuana cultivation, possession of drug paraphernalia, and trafficking in

marijuana. However, the jury left the verdict form blank upon whether Marcum

was guilty of being a second-degree persistent felony offender. The jury then

recommended a sentence of five-years’ imprisonment for marijuana cultivation,

twelve months for trafficking in marijuana, and twelve months for possession of

drug paraphernalia. And, although the jury left a blank on the instruction

adjudicating the guilt/innocence of being a second-degree persistent felony

offender, the jury inexplicably recommended a sentence of ten years for being a

second-degree persistent felony offender. By Judgment and Sentence on Pleas of

Not Guilty (Judgment) entered June 18, 2024, the circuit court sentenced Marcum

to a total of ten-years’ imprisonment upon the offenses of cultivation of marijuana,

trafficking in marijuana, possession of drug paraphernalia, and with being a

second-degree persistent felony offender. Nonetheless, by another order entered

-3- the same day (June 18, 2024), the circuit court dismissed the charge of second-

degree felony offender “[p]ursuant to a jury trial.” Record at 111. Marcum then

filed a motion for judgment of acquittal, which was denied by order entered on

September 4, 2024.

Marcum filed the notice of appeal (Appeal No. 2024-CA-1235-MR)

from the June 18, 2024, judgment and later filed another notice of appeal (Appeal

No. 2024-CA-1236-MR) from the September 4, 2024, order. We have

consolidated the appeals for review.1

DIRECTED VERDICT – CULTIVATING MARIJUANA

1. Standard of Review

Our review of a directed verdict is succinctly set forth as follows:

On motion for directed verdict, the trial court must draw all fair and reasonable inferences from the evidence in favor of the Commonwealth. If the evidence is sufficient to induce a reasonable juror to believe beyond a reasonable doubt that the defendant is guilty, a directed verdict should not be given. For the purpose of ruling on the motion, the trial court must assume that the evidence for the Commonwealth is true, but reserving to the jury questions as to the credibility and weight to be given to such testimony.

Commonwealth v. Benham, 816 S.W.2d 186, 187 (Ky. 1991). Our review shall

proceed accordingly.

1 The Court of Appeals consolidated for review Appeal Nos. 2024-CA-1235-MR and 2024-CA- 1236-MR by order entered February 24, 2025.

-4- 2. Analysis

Marcum contends the circuit court erred by denying his motion for

directed verdict upon the offense of cultivating marijuana. Marcum asserts that

only samples of two of the eight plants seized were sent to a laboratory for testing;

thus, no samples were taken for testing on six remaining plants. Although samples

from two plants were sent to the laboratory, Marcum further alleges that the

laboratory only tested one sample, and on that one sample, the laboratory failed to

perform a THC concentration test. Without such test, Marcum asserts that the

Commonwealth could not establish that the tested plant was actually a marijuana

plant as opposed to a hemp plant. At trial, Marcum points out that the

Commonwealth’s laboratory analyst was unable to testify that the test sample was

marijuana because testing was not performed to determine the level of THC in the

plant. Additionally, Marcum cites to the testimony of the Clinton County Sheriff

Ricky Marcum, who testified that marijuana plants must have a THC concentration

of at least 0.3%. Marcum maintains that the Commonwealth failed to establish

such THC concentration in any of the eight plants. Marcum also alleges that the

Commonwealth only introduced sufficient evidence of two viable plants seized

from his home, as the other six plants were mere saplings and were dead.

To be guilty of a Class D Felony for cultivating marijuana under

Kentucky Revised Statutes (KRS) 218A.1423(1), Marcum alleges that the

-5- Commonwealth must introduce evidence proving beyond a reasonable doubt that

he cultivated five or more plants. As six of the eight plants were mere saplings,

were clearly dead, and were not tested, Marcum urges this Court to conclude that

the Commonwealth failed to prove that he cultivated five plants or more per KRS

218A.1423, thus entitling him to a directed verdict of acquittal.

Under Kentucky’s penal statutes, marijuana is defined, in relevant

part:

“Marijuana” means all parts of the plant Cannabis sp., whether growing or not; the seeds thereof; the resin extracted from any part of the plant; and every compound, manufacture, salt, derivative, mixture, or preparation of the plant, its seeds or resin or any compound, mixture, or preparation which contains any quantity of these substances. The term “marijuana” does not include:

(a) Industrial hemp that is in the possession, custody, or control of a person who holds a license issued by the Department of Agriculture permitting that person to cultivate, handle, or process industrial hemp;

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Related

Blockburger v. United States
284 U.S. 299 (Supreme Court, 1931)
Graves v. Commonwealth
17 S.W.3d 858 (Kentucky Supreme Court, 2000)
Commonwealth v. Benham
816 S.W.2d 186 (Kentucky Supreme Court, 1991)
Martin v. Commonwealth
207 S.W.3d 1 (Kentucky Supreme Court, 2006)
Cumberland Valley Contractors, Inc. v. Bell County Coal Corp.
238 S.W.3d 644 (Kentucky Supreme Court, 2007)
Taylor v. Commonwealth
984 S.W.2d 482 (Court of Appeals of Kentucky, 1998)
Turner v. Commonwealth
345 S.W.3d 844 (Kentucky Supreme Court, 2011)
Turner v. Begley
39 S.W.2d 504 (Court of Appeals of Kentucky (pre-1976), 1931)
Board of Education of Campbellsville Independent School District v. Faulkner
433 S.W.2d 853 (Court of Appeals of Kentucky, 1968)
Elery v. Commonwealth
368 S.W.3d 78 (Kentucky Supreme Court, 2012)
Kiper v. Commonwealth
399 S.W.3d 736 (Kentucky Supreme Court, 2012)
Lundy v. Commonwealth
511 S.W.3d 398 (Court of Appeals of Kentucky, 2017)

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Bluebook (online)
Brian Marcum v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brian-marcum-v-commonwealth-of-kentucky-kyctapp-2026.