Commonwealth of Kentucky v. Eric L. Gibson

CourtKentucky Supreme Court
DecidedJune 15, 2021
Docket2020 SC 0041
StatusUnknown

This text of Commonwealth of Kentucky v. Eric L. Gibson (Commonwealth of Kentucky v. Eric L. Gibson) 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
Commonwealth of Kentucky v. Eric L. Gibson, (Ky. 2021).

Opinion

IMPORTANT NOTICE NOT TO BE PUBLISHED OPINION

THIS OPINION IS DESIGNATED “NOT TO BE PUBLISHED.” PURSUANT TO THE RULES OF CIVIL PROCEDURE PROMULGATED BY THE SUPREME COURT, CR 76.28(4)(C), THIS OPINION IS NOT TO BE PUBLISHED AND SHALL NOT BE CITED OR USED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE; HOWEVER, UNPUBLISHED KENTUCKY APPELLATE DECISIONS, RENDERED AFTER JANUARY 1, 2003, MAY BE CITED FOR CONSIDERATION BY THE COURT IF THERE IS NO PUBLISHED OPINION THAT WOULD ADEQUATELY ADDRESS THE ISSUE BEFORE THE COURT. OPINIONS CITED FOR CONSIDERATION BY THE COURT SHALL BE SET OUT AS AN UNPUBLISHED DECISION IN THE FILED DOCUMENT AND A COPY OF THE ENTIRE DECISION SHALL BE TENDERED ALONG WITH THE DOCUMENT TO THE COURT AND ALL PARTIES TO THE ACTION. RENDERED: JUNE 17, 2021 NOT TO BE PUBLISHED

Supreme Court of Kentucky 2020-SC-0041-DG

COMMONWEALTH OF KENTUCKY APPELLANT

ON REVIEW FROM COURT OF APPEALS V. NO. 2019-CA-0525 JEFFERSON CIRCUIT COURT NO. 16-CR-000661

ERIC L. GIBSON APPELLEE

MEMORANDUM OPINION OF THE COURT

REVERSING

The Commonwealth appeals the Court of Appeals’ reversal of the

Jefferson Circuit Court’s denial of Eric L. Gibson’s (Gibson) pro se motion to

vacate, set aside, or correct his sentence pursuant to RCr1 11.42. After review,

we reverse.

I. FACTUAL AND PROCEDURAL BACKGROUND

Gibson’s underlying convictions are the result of two separate

indictments, 16-CR-0661 and 17-CR-1799.

The first, 16-CR-0661, charged Gibson with being a convicted felon in

possession of a firearm, receiving a stolen firearm, and being a first-degree

persistent felony offender (PFO I). Gibson was arrested outside The Executive

1 Kentucky Rule of Criminal Procedure. Club, a nightclub, in the early morning hours of January 24, 2016. Gibson, a

convicted felon, was in possession of a firearm upon his arrest. Subsequently,

the firearm was discovered to have been reported stolen. A trial on those

charges was scheduled for February 14, 2017. However, in October of 2016,

Gibson failed to return to the Jefferson County Jail after being released as a

work aide. He was apprehended five months later at which time he was

charged with second-degree escape under indictment 17-CR-1799.

A plea colloquy on both indictments was held in November of 2017. In

exchange for Gibson’s guilty plea on all the outstanding charges, the

Commonwealth offered to amend the PFO I charge down to a second-degree

persistent felony offender charge (PFO II). In addition, it would recommend five

years each on the charges of receiving a stolen firearm and felon in possession

of a firearm—both enhanced to ten years each by virtue of the PFO II charge—

to run concurrently for a total of ten years. It would also recommend five years

on the second-degree escape charge, which had to run consecutively to the

other charges by law. Gibson’s guilty plea would therefore result in a fifteen-

year sentence with parole eligibility after he had served 20% of his sentence

due to the PFO II charge, as opposed to serving a minimum of ten years which

would have been the result of a PFO I conviction.2

Before accepting Gibson’s guilty plea, the trial court established that

Gibson had a twelfth-grade education and could read and write. The court

2 See Kentucky Revised Statute (KRS) 532.080(6)(b).

2 then placed Gibson under oath and conducted a typical Boykin3 line of

questioning. Gibson represented to the court that he was satisfied with his

attorney’s advice, that he had all the time he needed to talk to his attorney,

and that as far as he knew his attorney had done all that Gibson had asked

him to do. Gibson further affirmed that he read, understood, and went over

the plea agreements with counsel before signing them. Gibson was not under

the influence of anything during the plea colloquy and had never been treated

for mental health issues, nor had he ever been found to be incompetent by a

court. The court explained Gibson’s rights as a criminal defendant to him, and

he acknowledged that he was giving up those rights, save for his right to an

attorney, by pleading guilty. Gibson further agreed that he knew what he was

doing by pleading guilty, and felt that doing so was in his best interest. And,

no one had coerced him into pleading guilty or made any promises to him for

pleading guilty.

The trial court accepted Gibson’s pleas of guilty to receiving a stolen

handgun, being a felon in possession of a handgun, second-degree escape, and

being a PFO II. The court scheduled final sentencing for January of 2018. No

motion to withdraw the plea was filed in the interim.4 At sentencing, the trial

court sentenced Gibson in accordance with the Commonwealth’s

recommendations: a total of fifteen years imprisonment, with parole eligibility

3 Boykin v. Alabama, 395 U.S. 238, (1969). 4 See RCr 8.10 (“At any time before judgment the court may permit the plea of

guilty or guilty but mentally ill, to be withdrawn and a plea of not guilty substituted.”).

3 after serving 20% of his sentence. The trial court noted Gibson already had

accumulated 571 days of time served.

Eight months later, in September of 2018, Gibson filed a pro se motion to

vacate, set aside, or correct his sentence under RCr 11.42. The trial court

denied the motion without holding an evidentiary hearing. A divided Court of

Appeals reversed the trial court and held that an evidentiary hearing on

Gibson’s motion was necessary. The Commonwealth now appeals that ruling

to this Court.

Additional facts are discussed below as necessary.

II. ANALYSIS

Gibson asserts that the trial court erred by denying his RCr 11.42

motion. Specifically, he alleges that his counsel’s performance was ineffective

to the point of rendering his guilty plea invalid, and that his plea should

therefore be vacated. The United States Supreme Court ruled in Strickland v.

Washington that

[a] convicted defendant's claim that counsel's assistance was so defective as to require reversal of a conviction or death sentence has two components. First, the defendant must show that counsel's performance was deficient. This requires showing that counsel made errors so serious that counsel was not functioning as the “counsel” guaranteed the defendant by the Sixth Amendment. Second, the defendant must show that the deficient performance prejudiced the defense.5

5 466 U.S. 668, 687, (1984).

4 When a defendant pleads guilty, he must satisfy the “prejudice prong” of the

Strickland test by showing “that there is a reasonable probability that, but for

counsel's errors, he would not have pleaded guilty and would have insisted on

going to trial.”6 When ruling on an RCr 11.42 motion, the trial court must

determine “whether the allegations in the motion can be resolved on the face of

the record, in which event an evidentiary hearing is not required.”7 An RCr

11.42 motion must “state specifically the grounds on which the sentence is

being challenged and the facts on which the movant relies in support of such

grounds.”8 A trial court must dismiss an RCr 11.42 motion that lacks this

requisite specificity.9 When addressing a trial court’s denial of an RCr 11.42

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Related

Boykin v. Alabama
395 U.S. 238 (Supreme Court, 1969)
Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Hill v. Lockhart
474 U.S. 52 (Supreme Court, 1985)
Fraser v. Commonwealth
59 S.W.3d 448 (Kentucky Supreme Court, 2001)
Commonwealth v. Elza
284 S.W.3d 118 (Kentucky Supreme Court, 2009)
Bronk v. Commonwealth
58 S.W.3d 482 (Kentucky Supreme Court, 2001)
Tamme v. Commonwealth
973 S.W.2d 13 (Kentucky Supreme Court, 1998)
David Stiger v. Commonwealth of Kentucky
381 S.W.3d 230 (Kentucky Supreme Court, 2012)
Roach v. Commonwealth
384 S.W.3d 131 (Kentucky Supreme Court, 2012)

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Commonwealth of Kentucky v. Eric L. Gibson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-of-kentucky-v-eric-l-gibson-ky-2021.