Cody S. Patrick v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedApril 11, 2024
Docket2023 CA 000079
StatusUnknown

This text of Cody S. Patrick v. Commonwealth of Kentucky (Cody S. Patrick 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
Cody S. Patrick v. Commonwealth of Kentucky, (Ky. Ct. App. 2024).

Opinion

RENDERED: APRIL 12, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-0079-MR

CODY S. PATRICK APPELLANT

APPEAL FROM PERRY CIRCUIT COURT v. HONORABLE ALISON C. WELLS, JUDGE ACTION NO. 22-CR-00057

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: GOODWINE, KAREM, AND MCNEILL, JUDGES.

GOODWINE, JUDGE: The Appellant, Cody S. Patrick (“Patrick”), appeals the

Perry Circuit Court’s final judgment and sentence of imprisonment entered on

December 28, 2022, after the denial of his motion to suppress evidence and the

entry of a conditional guilty plea. After a careful review of the record, we affirm.

BACKGROUND

On February 25, 2022, Patrick was indicted on the charges of first-

degree possession of a controlled substance and possession of drug paraphernalia based on evidence seized from a vehicular search. Patrick filed a motion to

suppress, alleging he had been unlawfully seized before the search and the

evidence recovered should have been excluded as fruit of the poisonous tree.

A suppression hearing was held on June 17, 2022. The

Commonwealth called Hazard Police Officers Assistant Chief James Whitaker

(“Whitaker”) and Lieutenant John Holbrook (“Holbrook”) to testify. The defense

recalled Whitaker for additional questioning and called Patrick and Hazard Police

Officer Michael Ritchie (“Ritchie”) to testify.

The exact sequencing of the events is in dispute. Still, testimony

established that during the evening of April 15, 2021, Kentucky State Police

(“KSP”) Post 13 dispatch received an anonymous tip concerning two unconscious

subjects inside a vehicle parked in a Wal-Mart public lot in Hazard, Kentucky.

KSP Post 13 dispatch contacted the Hazard Police Department and requested a

wellness check. Video Record (“VR”) 6/17/2022 at 10:06:48-10:07:05. Whitaker

and Ritchie responded to the call.

Upon arrival at the scene, the officers parked their patrol car behind a

vehicle matching the description in the call, and the officers observed Patrick and

his girlfriend, Makayla Rowlett (“Rowlett”), asleep inside. Whitaker tapped on the

driver’s side window where Patrick was seated, prompting him to awaken. The

officers made initial wellness inquiries, and Patrick indicated no assistance was

-2- needed. To ensure he was okay, Whitaker had Patrick exit the vehicle while

Ritchie had Rowlett exit from the passenger side. Id. at 10:07:00-40, 10:17:05-19,

10:18:54-10:19:10.

After exiting the vehicle, Patrick and Rowlett were questioned.

Whitaker asked if there was anything in the vehicle, and Patrick informed them

there was a fake soda can with methamphetamine hidden inside. Whitaker called

for Holbrook to be dispatched to the scene with a drug dog.

Patrick informed the officers they were homeless and sleeping in the

vehicle overnight. The officers asked for Patrick’s and Rowlett’s identification

and subsequently learned they had outstanding arrest warrants. Whitaker testified

it was at this point that Patrick was placed in handcuffs. Id. at 10:07:41-10:08:34,

10:36:10-25, 10:46:21-46. Patrick and Ritchie contradicted Whitaker’s testimony

and testified he was handcuffed immediately upon exiting the vehicle.

Sometime after this, Rowlett consented to the officers to search the

vehicle. Holbrook arrived ten minutes after the officers first approached and

performed a canine open-air sniff of the vehicle, resulting in an alert to the

presence of drugs. A subsequent vehicular search yielded the discovery of three

needles and six baggies of methamphetamine located in a fake soda can with a

screw-on top. Id. at 10:08:35-52, 10:11:00-46.

-3- The trial court denied the motion to suppress on July 12, 2022, and a

conditional guilty plea preserving the right to appeal was entered on November 29,

2022. Patrick received a two-year sentence of imprisonment. This appeal

followed.

STANDARD OF REVIEW

“Our standard of review of the trial court’s denial of a suppression

motion is twofold. First, the trial court’s findings of fact are conclusive if they are

supported by substantial evidence; and second, the trial court’s legal conclusions

are reviewed de novo.” Kavanaugh v. Commonwealth, 427 S.W.3d 178, 180 (Ky.

2014) (citations omitted). “Substantial evidence means evidence that when taken

alone or in light of all the evidence, . . . has sufficient probative value to induce

conviction in the minds of reasonable men.” Turley v. Commonwealth, 399

S.W.3d 412, 420 (Ky. 2013) (emphasis in original) (internal quotation marks and

citation omitted). “This does not mean the finding must include undisputed

evidence, but both parties must present adequate evidence to support their

position.” Brown v. Commonwealth, 253 S.W.3d 490, 500 (Ky. 2008) (emphasis

added) (citation omitted).

ANALYSIS

“The first step in determining whether there has been a Fourth

Amendment violation[] is finding whether and when a seizure or a search

-4- occurred.” Commonwealth v. Garrett, 585 S.W.3d 780, 790 (Ky. App. 2019).

“When police officers, by means of physical force or show of authority, in some

way restrain the liberty of a citizen, a ‘seizure’ of that person has occurred.”

Strange v. Commonwealth, 269 S.W.3d 847, 851 (Ky. 2008); see also Reynolds v.

Commonwealth, 393 S.W.3d 607, 610 (Ky. App. 2012) (“Factors indicative of

restraint on liberty include the threatening presence of several officers, physical

touching of the person, or use of a tone or language that might compel compliance

with the request of the police.”) (internal quotation marks and citation omitted);

United States v. Richardson, 385 F.3d 625, 629 (6th Cir. 2004) (“[W]e recognize

that words alone may be enough to make a reasonable person feel that he would

not be free to leave.”) (citations omitted). “[A] person has been seized in the

constitutional sense when, in view of all of the circumstances surrounding the

incident, a reasonable person would have believed that he or she was not free to

leave.” Strange, 269 S.W.3d at 851 (citation omitted). A “brief detention of a

person by a police officer . . . may properly be undertaken only if the police officer

has a reasonable suspicion based upon objective, articulable facts that criminal

activity is afoot.” Id. at 850 (citations omitted).

Before we delve into the merits of Patrick’s claims, we must first

address an issue of standing raised by the Commonwealth. “A defendant bears the

burden of establishing standing to challenge a Fourth Amendment search. That

-5- burden requires proof that the defendant had a legitimate expectation of privacy in

the premises.” Ordway v. Commonwealth, 352 S.W.3d 584, 592 (Ky. 2011)

(citations omitted).

The Commonwealth contends that Patrick lacked any legitimate

expectation of privacy in the vehicle because he failed to establish that he was the

owner or that the original owner granted him possession. Patrick testified at the

suppression hearing that the vehicle’s original owner was “some woman from

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