Commonwealth of Kentucky v. James Harvey Hendron, Jr.

CourtCourt of Appeals of Kentucky
DecidedJune 13, 2025
Docket2024-CA-0836
StatusUnpublished

This text of Commonwealth of Kentucky v. James Harvey Hendron, Jr. (Commonwealth of Kentucky v. James Harvey Hendron, Jr.) 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. James Harvey Hendron, Jr., (Ky. Ct. App. 2025).

Opinion

RENDERED: JUNE 13, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-0836-MR

COMMONWEALTH OF KENTUCKY APPELLANT

APPEAL FROM FAYETTE CIRCUIT COURT v. HONORABLE JULIE M. GOODMAN, JUDGE ACTION NO. 18-CR-01084

JAMES HARVEY HENDRON, JR. APPELLEE

OPINION REVERSING AND REMANDING

** ** ** ** **

BEFORE: A. JONES, L. JONES, AND KAREM, JUDGES.

KAREM, JUDGE: After a jury found James Harvey Hendron, Jr. (“Hendron”)

guilty of murder, the Fayette Circuit Court granted him a new trial. The

Commonwealth of Kentucky (the “Commonwealth”) appeals from the Fayette

Circuit Court’s order granting Hendron’s motion for a new trial and has requested

this Court to reinstate the jury’s verdict.

We disagree with the circuit court’s finding of prosecutorial

misconduct that reached the level of palpable error. We further believe that the circuit court abused its discretion in ordering a new trial. Therefore, we reverse its

order, granting a new trial and remand with instructions to reinstate the jury’s

verdict.

FACTUAL AND PROCEDURAL BACKGROUND

On June 17, 2018, Hendron shot and killed his 23-year-old son,

Austin Hendron (“Austin”). Hendron admitted to committing the offense but

contended at trial that he killed Austin in self-defense.

The jury convicted Hendron of murder and recommended a sentence

of life imprisonment. Hendron subsequently filed a motion for a new trial based

on allegations of prosecutorial misconduct, most of which Hendron’s defense

counsel failed to object to at trial. The circuit court granted Hendron’s motion, set

aside the verdict, and ordered a new trial. This appeal followed.

We will discuss further facts as they become relevant.

ANALYSIS

1. Standard of Review

As discussed, Hendron failed to preserve almost all the issues he

raised in his motion for a new trial. Thus, he is requesting palpable error review.

In Commonwealth v. Jones, the Kentucky Supreme Court discussed the palpable

error rule of Kentucky Rule of Criminal Procedure (“RCr”) 10.26, stating:

An unpreserved error that is both palpable and prejudicial still does not justify relief unless the reviewing court

-2- further determines that it has resulted in a manifest injustice, unless, in other words, the error so seriously affected the fairness, integrity, or public reputation of the proceeding as to be “shocking or jurisprudentially intolerable.”

283 S.W.3d 665, 668 (Ky. 2009) (quoting Martin v. Commonwealth, 207 S.W.3d

1, 4 (Ky. 2006)). “A finding of palpable error must involve prejudice more

egregious than that occurring in reversible error, . . . and the error must have

resulted in manifest injustice.” Webb v. Commonwealth, 387 S.W.3d 319, 329

(Ky. 2012) (internal quotation marks and citation omitted).

This Court reviews the circuit court’s grant of a new trial for an abuse

of discretion. Rowe v. Commonwealth, 355 S.W.3d 480, 485 (Ky. App. 2011).

“The test for abuse of discretion is whether the trial judge’s decision was arbitrary,

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

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

2. Discussion

The circuit court granted Hendron’s motion for a new trial based on

his claim that prosecutorial misconduct occurred during the Commonwealth’s

closing argument and in its examination of certain witnesses. We will examine

each of these allegations in turn.

-3- a. Alleged Misconduct in the Commonwealth’s Closing Argument

1. Burden-Shifting

In this case, the circuit court determined that the prosecutor misstated

the law concerning self-defense during closing arguments and inappropriately

shifted the burden of proof to Hendron. “Prosecutorial misconduct is ‘[a]

prosecutor’s improper or illegal act involving an attempt to persuade the jury to

wrongly convict a defendant or assess an unjustified punishment.’”

Commonwealth v. McGorman, 489 S.W.3d 731, 741-42 (Ky. 2016) (quoting

Noakes v. Commonwealth, 354 S.W.3d 116, 121 (Ky. 2011)). Moreover, “[a]ny

allegation of misconduct must be viewed in the context of the overall fairness of

the trial.” Barrett v. Commonwealth, 677 S.W.3d 326, 332 (Ky. 2023) (citation

omitted). Indeed, “[t]o justify reversal, the Commonwealth’s misconduct must be

so serious as to render the entire trial fundamentally unfair.” Id. (internal quotation

marks and citation omitted).

“If the misconduct is objected to, we will reverse on that ground if

proof of the defendant’s guilt was not such as to render the misconduct harmless,

and if the trial court failed to cure the misconduct with a sufficient admonition to

the jury.” Duncan v. Commonwealth, 322 S.W.3d 81, 87 (Ky. 2010). Otherwise,

if the defense fails to object, “we will reverse only where the misconduct was

-4- flagrant and was such as to render the trial fundamentally unfair.” Id. (citations

omitted).

In the case sub judice, defense counsel did not object at trial to any of

the statements Hendron alleges constituted unauthorized burden-shifting.

Therefore, we must determine whether the Commonwealth’s alleged misconduct

was “flagrant” to warrant reversal.

We utilize four factors to determine whether misconduct is flagrant:

(1) whether the remarks tended to mislead the jury or to prejudice the accused; (2) whether they were isolated or extensive; (3) whether they were deliberately or accidentally placed before the jury; and (4) the strength of the evidence against the accused.

Bowling v. Commonwealth, 553 S.W.3d 231, 242-43 (Ky. 2018) (citation omitted).

And again, even if Hendron shows flagrant misconduct, because

defense counsel failed to object at trial, we would also have to find that he suffered

“manifest injustice” before granting any relief. See Matheney v. Commonwealth,

191 S.W.3d 599, 606-07 n.4 (Ky. 2006).

In this case, the circuit court found that the prosecutor erred by

stating:

But it’s very important to point out that if you convict him under Manslaughter Second or Reckless, you must believe beyond a reasonable doubt that when he committed the offense, he truly believed, in his heart of hearts, that this amount of force was necessary in order to protect himself from death or serious physical injury.

-5- You all have to believe that he believed that, at that time. Alright. Didn’t occur to him that he could just lock the door, didn’t occur to him that he could just stay in the house, didn’t occur to him he could just call the police, he didn’t think of any of those things. That’s what you have to believe. Beyond a reasonable doubt.

Additionally, the circuit court pointed to a PowerPoint presentation

shown to the jury by the Commonwealth stating the following:

To get there . . .

You have to believe BEYOND A REASONABLE DOUBT that Defendant believed he had to use deadly force to protect himself from his son . . . .

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

Related

Matheney v. Commonwealth
191 S.W.3d 599 (Kentucky Supreme Court, 2006)
Padgett v. Commonwealth
312 S.W.3d 336 (Kentucky Supreme Court, 2010)
Commonwealth v. Spaulding
991 S.W.2d 651 (Kentucky Supreme Court, 1999)
Caudill v. Commonwealth
120 S.W.3d 635 (Kentucky Supreme Court, 2003)
Morgan v. Scott
291 S.W.3d 622 (Kentucky Supreme Court, 2009)
Wallen v. Commonwealth
657 S.W.2d 232 (Kentucky Supreme Court, 1983)
Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
Commonwealth v. Jones
283 S.W.3d 665 (Kentucky Supreme Court, 2009)
Estep v. Commonwealth
64 S.W.3d 805 (Kentucky Supreme Court, 2002)
Martin v. Commonwealth
207 S.W.3d 1 (Kentucky Supreme Court, 2006)
Mayo v. Commonwealth
322 S.W.3d 41 (Kentucky Supreme Court, 2010)
Duncan v. Commonwealth
322 S.W.3d 81 (Kentucky Supreme Court, 2010)
Stanley v. Ellegood
382 S.W.2d 572 (Court of Appeals of Kentucky (pre-1976), 1964)
Lycans v. Commonwealth
562 S.W.2d 303 (Kentucky Supreme Court, 1978)
St. Clair v. Commonwealth
54 S.W.2d 1 (Court of Appeals of Kentucky (pre-1976), 1932)
Jason Dickerson v. Commonwealth of Kentucky
485 S.W.3d 310 (Kentucky Supreme Court, 2016)
Beatrice Foods Co. v. Chatham
371 S.W.2d 17 (Court of Appeals of Kentucky, 1963)
Johnson v. Commonwealth
292 S.W.3d 889 (Kentucky Supreme Court, 2009)
Noakes v. Commonwealth
354 S.W.3d 116 (Kentucky Supreme Court, 2011)
Rowe v. Commonwealth
355 S.W.3d 480 (Court of Appeals of Kentucky, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
Commonwealth of Kentucky v. James Harvey Hendron, Jr., Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-of-kentucky-v-james-harvey-hendron-jr-kyctapp-2025.