Commonwealth of Kentucky v. Barbara Burke

CourtCourt of Appeals of Kentucky
DecidedSeptember 8, 2022
Docket2021 CA 001446
StatusUnknown

This text of Commonwealth of Kentucky v. Barbara Burke (Commonwealth of Kentucky v. Barbara Burke) 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
Commonwealth of Kentucky v. Barbara Burke, (Ky. Ct. App. 2022).

Opinion

RENDERED: SEPTEMBER 9, 2022; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2021-CA-1446-MR

COMMONWEALTH OF KENTUCKY APPELLANT

v. APPEAL FROM ROCKCASTLE CIRCUIT COURT HONORABLE JOHN G. PRATHER, JR., JUDGE ACTION NO. 19-CR-00171

BARBARA BURKE APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: DIXON, TAYLOR, AND L. THOMPSON, JUDGES.

THOMPSON, L., JUDGE: The Commonwealth of Kentucky (“Appellant”)

appeals from an interlocutory order of the Rockcastle Circuit Court granting the

motion of Barbara Burke (“Appellee”) to sever the charge of operating a motor

vehicle under the influence of alcohol from the remaining charges. Appellant

argues that Appellee failed to demonstrate prejudice sufficient to sever the charges,

that the offenses occurred in the course of a single act or transaction, and that the evidence supporting the charges is inextricably intertwined. Appellant requests an

opinion reversing the order severing the charges. After careful review, we affirm

the order on appeal.

FACTS AND PROCEDURAL HISTORY

On October 11, 2019, a Rockcastle County grand jury indicted

Appellee on one count of operating a motor vehicle under the influence of alcohol

(“DUI”), assault in the third degree, menacing, and disorderly conduct in the

second degree.1 The charges arose from an incident occurring on September 18,

2019, when Kentucky State Police troopers responded to a caller reporting a single

vehicle accident in Rockcastle County, Kentucky. Upon arrival, the troopers

observed an unoccupied truck in a ditch. Appellee was observed sitting in another

vehicle at the scene, which was not involved in the accident. Upon making contact

with Appellee, the officers suspected that she was under the influence of alcohol

and that she was the driver of the truck.

Trooper Brian Maupin would later testify that Appellee initially stated

that she was driving the truck and had to swerve to avoid oncoming traffic which

caused her to drive off the roadway. Appellee then changed her story and stated

that she was a passenger in the truck and the driver had fled on foot. Trooper

1 Kentucky Revised Statutes (“KRS”) 189A.010, KRS 508.025, KRS 508.050, and KRS 525.060.

-2- Derek Combs’ citation stated that Appellee failed the “one-leg stand” field sobriety

test. Though she initially cooperated with the troopers, Appellee became agitated

and struck Trooper Maupin in the chest with an open hand. Appellee was arrested

and transported to the Mount Vernon police department, where she refused to

submit to a breathalyzer test.

After the indictment, the matter proceeded in Rockcastle Circuit Court

whereupon Appellee filed a motion to sever the DUI charge from the assault

charge.2 In support of the motion, Appellee cited Kentucky Rules of Criminal

Procedure (“RCr”) 8.31 and Rearick v. Commonwealth, 858 S.W.2d 185, 187 (Ky.

1993). Appellee argued that the charges should be severed in part because “there

was never any DUI stop” and there was little or no evidence that she was driving

the truck. Appellant argued that the charges should not be severed because they

arose from one act or transaction, the facts supporting the charges are intertwined,

and Appellee showed no prejudice supporting severance.

At a pretrial conference on November 12, 2021, to consider whether

probable cause existed to support the DUI charge, the court noted that though it

was Appellant’s practice to try DUI charges in conjunction with other felony

charges, the court was not going to allow it in this instance because it did not want

to give Appellee a basis for appeal should she be found guilty on the felony assault

2 Appellee’s motion did not address the charges of menacing and disorderly conduct.

-3- charge. On November 23, 2021, the Rockcastle Circuit Court entered a motion

granting Appellee’s motion to sever, and this appeal followed.3

STANDARD OF REVIEW

Trial courts have broad discretion when making joinder decisions and

such decisions will not be reversed on appeal absent a showing of clear abuse of

discretion and prejudice. Jackson v Commonwealth, 20 S.W.3d 906, 908 (Ky.

2000). An abuse of discretion occurs if the trial court’s ruling is “arbitrary,

unreasonable, unfair, or unsupported by sound legal principles.” Commonwealth v.

English, 993 S.W.2d 941, 945 (Ky. 1999).

ARGUMENTS AND ANALYSIS

Appellant argues that the Rockcastle Circuit Court committed

reversible error in severing the DUI charge from the assault charge. It contends

that the offenses occurred in the course of a single act or transaction, and that the

evidence supporting the charges is inextricably intertwined. Appellant argues that

Appellee failed to demonstrate that joinder of the charges would prejudice the

proceedings against her. After directing our attention to the Civil Rules and case

law, Appellant argues that there is no basis for requiring it to conduct separate

3 If certain elements are met, the Commonwealth may bring an appeal from an interlocutory order in a criminal proceeding. See KRS 22A.020(4) and Evans v. Commonwealth, 645 S.W.2d 346, 347 (Ky. 1982), wherein the Kentucky Supreme Court recognized that “KRS 22A.020(4) authorizes the Commonwealth to appeal from an interlocutory order[.]”

-4- trials on the DUI and assault charges, as the alleged assault occurred in the midst

of the DUI investigation. It requests an opinion reversing the order on appeal so

that the charges may be tried together.

Two (2) or more offenses may be charged in the same complaint or two (2) or more offenses whether felonies or misdemeanors, or both, may be charged in the same indictment or information in a separate count for each offense, if the offenses are of the same or similar character or are based on the same acts or transactions connected together or constituting parts of a common scheme or plan.

RCr 6.18. Further,

[i]f it appears that a defendant or the Commonwealth is or will be prejudiced by a joinder of offenses or of defendants in an indictment, information, complaint or uniform citation or by joinder for trial, the court shall order separate trials of counts, grant separate trials of defendants or provide whatever other relief justice requires. A motion for such relief must be made before the jury is sworn or, if there is no jury, before any evidence is received.

RCr 8.31.

The circuit court’s ruling on Appellee’s motion to sever is presumed

to be correct, and the duty to prove it was not correct rests with Appellant.

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Related

Jackson v. Commonwealth
20 S.W.3d 906 (Kentucky Supreme Court, 2000)
Rearick v. Commonwealth
858 S.W.2d 185 (Kentucky Supreme Court, 1993)
Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
Jerard Garrett v. Commonwealth of Kentucky
534 S.W.3d 217 (Kentucky Supreme Court, 2017)
Evans v. Commonwealth
645 S.W.2d 346 (Kentucky Supreme Court, 1982)
Oakes v. Oakes
264 S.W. 752 (Court of Appeals of Kentucky, 1924)

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Commonwealth of Kentucky v. Barbara Burke, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-of-kentucky-v-barbara-burke-kyctapp-2022.