Christopher Smith v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedApril 11, 2024
Docket2022 CA 000686
StatusUnknown

This text of Christopher Smith v. Commonwealth of Kentucky (Christopher Smith 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
Christopher Smith v. Commonwealth of Kentucky, (Ky. Ct. App. 2024).

Opinion

RENDERED: APRIL 12, 2024; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-0686-MR

CHRISTOPHER SMITH APPELLANT

APPEAL FROM HENDERSON CIRCUIT COURT v. HONORABLE KAREN LYNN WILSON, JUDGE ACTION NO. 16-CR-00166

COMMONWEALTH OF KENTUCKY APPELLEE

AND

NO. 2022-CA-0687-MR

APPEAL FROM HENDERSON CIRCUIT COURT v. HONORABLE KAREN LYNN WILSON, JUDGE ACTION NO. 16-CR-00271

OPINION AFFIRMING IN PART, REVERSING IN PART, AND REMANDING

** ** ** ** ** BEFORE: ACREE, CALDWELL, AND LAMBERT, JUDGES.

CALDWELL, JUDGE: Christopher Smith (Smith) appeals from the Henderson

Circuit Court order finding him competent, revoking his probation, and imposing a

ten (10) year sentence of imprisonment. We affirm in part, reverse in part, and

remand for proceedings consistent with this Opinion.

FACTS

In April of 2016, Smith was indicted by the Henderson County Grand

Jury on various drug offenses and being a persistent felony offender (PFO) in the

first degree. At arraignment, counsel raised the question of whether Smith was

competent to stand trial as he had previously been found to be incompetent

pursuant to a court order for a competency evaluation. This competency

evaluation determination counsel was referring to also came with a determination

that Smith would likely not be able to gain competency in the future.

As the most recent evaluation provided to the court was completed

several years earlier, the trial court desired a more current evaluation be conducted

and ordered Smith evaluated once more. Smith was then evaluated by Dr. Steven

Sparks (Dr. Sparks) of the Kentucky Correctional Psychiatric Center (KCPC). Dr.

Sparks’ report stated he was not able to come to a conclusion about whether Smith

was competent to stand trial because he believed Smith was malingering.

Regardless, Dr. Sparks opined Smith was likely competent.

-2- Smith ultimately entered a guilty plea to various drug offenses in

exchange for dismissal of the PFO charge and was sentenced to ten (10) years’

imprisonment. Contemporaneously, he entered a guilty plea to unrelated third-

degree assault case and was sentenced to five (5) years, to run concurrently with

the ten (10) year sentence for a total sentence of ten (10) years. At the time of the

entry of this plea, counsel stated having no concerns about Smith’s competency.

Shortly thereafter, his sentence was suspended by the court and he was placed on

five (5) years’ probation.

Approximately one year later, Smith was indicted on new drug

charges. His probation officer also informed the court Smith violated his probation

by failing to complete drug treatment and by using synthetic marijuana. Smith

admitted the violations and his probation was revoked, though he was soon granted

five (5) years’ shock probation. The trial court ordered Smith to remain

incarcerated until a bed could be found for him in a drug rehabilitation facility.

When no bed could be located because there were other charges pending against

Smith, he was released on home incarceration in November of 2018.

Four months later a warrant was issued for Smith’s arrest for

probation violation when he failed a drug test, testing positive for marijuana. The

trial court ordered Smith be again evaluated for competency. Following evaluation

-3- both at KCPC and by a defense expert, a competency hearing was held. The

matter was dismissed after the trial court found Smith not competent to stand trial.

In August of 2019, Smith again picked up new charges – a DUI and

possession of a controlled substance, cocaine – in Hopkins County. A motion was

filed seeking revocation of probation in Henderson County based upon the fact

Smith was criminally charged in Hopkins County. The Henderson Circuit Court

opted to wait until competency proceedings had been conducted in Hopkins

County before taking any action as to the revocation.

In July of 2020, the Henderson Circuit Court, relying upon

evaluations and actions taken as part of the Hopkins County case, found Smith

competent. Counsel filed a motion to reconsider, which was denied. However in

May of 2021, as Hopkins County had not yet held a competency hearing despite

the completion of the KCPC evaluation, the Henderson Circuit Court ordered

Smith to be again evaluated for competency.

Following evaluations by Dr. Sparks of KCPC and defense expert Dr.

Eric Drogin (Dr. Drogin), a competency hearing was conducted in March of 2022.

Though Dr. Sparks performed an evaluation of Smith, he was once again unable to

provide the court with an opinion as to Smith’s competency. Dr. Drogin, citing

with particularity Smith’s limited intellectual functioning and the intractable nature

-4- of his chronic developmental disability, provided his professional opinion Smith

was not competent and unlikely to regain competency.

Following the hearing, the Henderson Circuit Court found Smith

competent. The court later revoked his probation. It is from this latest

determination of his competency and the subsequent revocation of probation Smith

now appeals.1 We affirm in part and reverse in part and remand this matter back to

the Henderson Circuit Court.

1 Smith also argues he was not criminally responsible for the offenses charged, due again to his mental health and developmental disabilities. We need not reach this argument at the present time, due to our holding as explained herein. Criminal responsibility is a defense to a criminal prosecution and is a jury question, not a threshold question for the court, as is competency. See Powell v. Graham, 185 S.W.3d 624, 632 (Ky. 2006). Should Smith face revocation after proceedings consistent with this Opinion, he could forward the defense again at that time. As this Court observed in Smith’s prior appeal concerning a previous probation revocation:

If, however, the court determines that Smith was not criminally responsible for his probation violations, it should consider whether the lack of criminal responsibility, under the circumstances of this case, is a defense to his probation violations, is not a defense to his probation violations, or is simply a mitigating factor to be considered in the revocation determination, and issue a revocation determination accordingly.

Smith v. Commonwealth, No. 2006-CA-002206-MR, 2007 WL 2745378, at *5 (Ky. App. Sep. 21, 2007).

Smith also claims the trial court did not comply with Kentucky Revised Statute (KRS) 439.3106 in revoking probation. Again, as we are reversing for competency procedures, it is not necessary to determine whether the trial court complied with the statute in revoking as we hold herein the trial court erred in conducting the probation revocation hearing without properly considering competency.

-5- STANDARD OF REVIEW

A trial court’s determination as to the competency of an accused must

be supported by substantial evidence.

“A competency determination is based on the preponderance of the evidence standard.” Chapman v. Commonwealth, 265 S.W.3d 156, 174 (Ky. 2007). We review a trial court’s finding of competency for clear error and will reverse only if it is not supported by substantial evidence. Id. Jackson v. Commonwealth, 319 S.W.3d 347, 349 (Ky. 2010). “Since the trial

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Dusky v. United States
362 U.S. 402 (Supreme Court, 1960)
Morrissey v. Brewer
408 U.S. 471 (Supreme Court, 1972)
Gagnon v. Scarpelli
411 U.S. 778 (Supreme Court, 1973)
Drope v. Missouri
420 U.S. 162 (Supreme Court, 1975)
Medina v. California
505 U.S. 437 (Supreme Court, 1992)
Fugate v. Commonwealth
62 S.W.3d 15 (Kentucky Supreme Court, 2001)
Chapman v. Commonwealth
265 S.W.3d 156 (Kentucky Supreme Court, 2008)
Padgett v. Commonwealth
312 S.W.3d 336 (Kentucky Supreme Court, 2010)
Powell v. Graham
185 S.W.3d 624 (Kentucky Supreme Court, 2006)
Commonwealth v. Wooten
269 S.W.3d 857 (Kentucky Supreme Court, 2008)
Moore v. Asente
110 S.W.3d 336 (Kentucky Supreme Court, 2003)
Jackson v. Commonwealth
319 S.W.3d 347 (Kentucky Supreme Court, 2010)
Bishop v. Caudill
118 S.W.3d 159 (Kentucky Supreme Court, 2003)
Brown v. Commonwealth
564 S.W.2d 21 (Court of Appeals of Kentucky, 1977)
Land v. Commonwealth
986 S.W.2d 440 (Kentucky Supreme Court, 1999)
Marshall v. Commonwealth
638 S.W.2d 288 (Court of Appeals of Kentucky, 1982)
Tiryung v. Commonwealth
717 S.W.2d 503 (Court of Appeals of Kentucky, 1986)
Woolfolk v. Commonwealth
339 S.W.3d 411 (Kentucky Supreme Court, 2011)
Plumb v. Commonwealth
490 S.W.2d 729 (Court of Appeals of Kentucky, 1973)

Cite This Page — Counsel Stack

Bluebook (online)
Christopher Smith v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christopher-smith-v-commonwealth-of-kentucky-kyctapp-2024.