Christopher Alexander Pope v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedFebruary 16, 2021
Docket2019 SC 0522
StatusUnknown

This text of Christopher Alexander Pope v. Commonwealth of Kentucky (Christopher Alexander Pope 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
Christopher Alexander Pope v. Commonwealth of Kentucky, (Ky. 2021).

Opinion

RENDERED: FEBRUARY 18, 2021 TO BE PUBLISHED

Supreme Court of Kentucky 2019-SC-0522-MR

CHRISTOPHER ALEXANDER POPE APPELLANT

ON APPEAL FROM LINCOLN CIRCUIT COURT v. HONORABLE DAVID A. TAPP, JUDGE NO. 18-CR-00152

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION OF THE COURT BY JUSTICE HUGHES

AFFIRMING

After a Lincoln County jury found Appellant Christopher Pope guilty of

trafficking in a controlled substance (heroin) in the first degree, he pled guilty

to being a persistent felony offender in the first degree (PFO I). The jury

recommended a twenty-year prison sentence and the trial court sentenced him

accordingly. Pope argues on appeal that the circuit court erred in two ways: 1)

by denying his pretrial motion to either suppress the evidence from an

undercover drug buy or dismiss the indictment for lack of jurisdiction, and 2)

by admitting into evidence clearer copies of Snapchat messages than the ones

provided to him in discovery. Upon review, we affirm the Lincoln Circuit

Court’s judgment. FACTUAL AND PROCEDURAL BACKGROUND

Pope was indicted by a Lincoln County grand jury for trafficking in a

controlled substance and being a first-degree PFO. The charges stemmed from

Pope selling heroin to a confidential informant during a controlled buy. The

controlled buy was arranged by deputies from the Boyle County Sheriff’s

Department who apparently anticipated that it would occur in Boyle County.

However, when the buy was set in motion Pope told the confidential informant

that he would not make the sale in Boyle County. Instead Pope instructed the

informant to meet him at a fast-food restaurant in adjoining Lincoln County.

The Boyle County deputies followed the informant to that location and

surveilled the drug transaction. Notably, the deputies received prior verbal

approval from the Lincoln County Sheriff’s Department for their investigative

activities in Lincoln County.

Pope communicated with the confidential informant via Snapchat. At

one point, Pope instructed the informant to leave his vehicle unlocked when he

went into the restaurant. When the informant met with Pope inside the

restaurant, Pope told him that the heroin had already been placed in the glove

compartment of his vehicle. The informant then paid Pope and returned to

Boyle County.

The Boyle County deputies later testified that they surveilled the entire

transaction. One officer observed Pope arrive, approach the passenger door of

the informant’s vehicle, and then enter the restaurant where he had a

2 discussion with the informant. Afterward, the officers met the confidential

informant in Boyle County where he gave them the purchased heroin.

Following the Lincoln County grand jury’s indictment of Pope, a Boyle

County officer arrested him in Boyle County. As noted, a Lincoln County jury

found Pope guilty of trafficking in a controlled substance, first degree and,

following his guilty plea to the charge of PFO I, recommended a sentence of

twenty years. The trial court sentenced Pope accordingly and entered

judgment. Pope appeals as a matter of right.

Other facts pertinent to Pope’s claims of error are set forth below.

ANALYSIS

I. The Circuit Court Properly Denied the Motion to Suppress and Motion to Dismiss Indictment.

Pope moved the circuit court to suppress the deputies’ testimony and

any evidence gathered by the Boyle County Sheriff’s Department or,

alternatively, to dismiss the indictment altogether on the grounds that the

Boyle County deputies lacked jurisdiction to conduct an investigation in

Lincoln County. The circuit court denied both motions. Generally, when

reviewing a denial of a suppression motion, “we first review the trial court’s

findings of fact under the clearly erroneous standard.” Davis v.

Commonwealth, 484 S.W.3d 288, 290 (Ky. 2016). Here, Pope does not

challenge the circuit court’s findings of fact, so we proceed directly to a de novo

review of the circuit court’s application of the law to the facts. Id. Upon

review, we agree with the circuit court’s ultimate conclusion of law that Pope’s

3 jurisdictional argument fails and thus cannot be a legal basis for either

suppression of the evidence or dismissal of the indictment. Moreover, even if

Pope’s jurisdictional challenge had merit, a motion to suppress, excluding the

evidence, would not be the proper remedy.

Pertinently, the circuit court’s findings of fact and conclusions of law

stated:

On or about September 1, 2018, the Boyle County Sheriff’s Office conducted a controlled buy from the Defendant. The buy occurred in Lincoln County through the use of a confidential informant. The confidential informant was recording the transactions and the events were observed by the officers with the Boyle County Sheriff’s Office. The Boyle County Officers received verbal authorization from [the Lincoln County Sheriff] before the transaction occurred to conduct an investigation. The Defendant was not arrested after the transaction but was instead directly indicted by the Lincoln County Grand Jury in January 2019.

The defendant claims KRS 431.007 applies in this case. Since the Defendant was not arrested during the investigation, it does not apply.

To the extent that any authority is need[ed] [by the Boyle County Officers] to act outside their jurisdiction . . . , it was granted by the Sheriff of Lincoln County. . . .

The Kentucky Court of Appeals has held that officers have a right to be or act as any other private citizen. Fischer v. Commonwealth, 506 S.W.3d 329 (Ky. App. 2016). The jurisdictional issue is not an issue since all the actions performed by law enforcement and their proxy were the same actions any citizen could lawfully perform.

Pope primarily relies on Kentucky Revised Statute (KRS) 431.007(1) to

support his argument that the Boyle County deputies did not have authority to

conduct the investigation in Lincoln County which led to his indictment and

arrest. KRS 431.007(1) provides:

4 [A] sheriff, or deputy sheriff . . . who is officially requested by a law enforcement agency in another county in Kentucky to assist in any matter within the jurisdiction of the requesting agency shall possess, while responding to and for the duration of the matter for which the request was made, the same powers of arrest in the requesting county as he possesses in the county in which he is a police officer.

Pope stresses that pursuant to this statute’s plain language and statutory

interpretation principles, the Lincoln County Sheriff must have “requested” the

Boyle County officers’ assistance, not vice versa, in order for the Boyle County

officers to have investigatory jurisdiction in Lincoln County. He contends the

investigation and the evidence obtained from it are unlawful because they

contravene the statute, regardless of the fact that the Boyle County officers

requested permission from the Lincoln County Sheriff to pursue the undercover

heroin buy in Lincoln County. He also argues Fischer, a case relied on by the

circuit court, is distinguishable from his case because in contrast to the police

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