Commonwealth of Kentucky v. Jessica Skaggs

CourtCourt of Appeals of Kentucky
DecidedJanuary 7, 2021
Docket2020 CA 000441
StatusUnknown

This text of Commonwealth of Kentucky v. Jessica Skaggs (Commonwealth of Kentucky v. Jessica Skaggs) 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. Jessica Skaggs, (Ky. Ct. App. 2021).

Opinion

RENDERED: JANUARY 8, 2021; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2020-CA-0441-MR

COMMONWEALTH OF KENTUCKY APPELLANT

APPEAL FROM ROWAN CIRCUIT COURT v. HONORABLE ROBERT W. MCGINNIS, JUDGE ACTION NO. 19-CR-00149

JESSICA SKAGGS APPELLEE

OPINION VACATING AND REMANDING

** ** ** ** **

BEFORE: CLAYTON, CHIEF JUDGE; GOODWINE AND KRAMER, JUDGES.

KRAMER, JUDGE: The Commonwealth appeals from an order of the Rowan

Circuit Court suppressing all evidence from what it determined was an unlawful

seizure of Jessica Skaggs by Sergeant Chris Waltz of the Morehead Police

Department. Upon review, we vacate and remand. Factual and Procedural Background

On the night of May 24, 2019, Sgt. Waltz received a dispatch that the

owner of the Valero gas station noticed a suspicious vehicle in front of the store

after hours. Although it is unclear from the record before us what time the store

closed, there were still employees inside cleaning when Sgt. Waltz arrived at 12:48

a.m. He saw a man at the front window of the store waving in what he assumed

was an attempt to get the attention of the employees.1 Sgt. Waltz instructed the

man to have a seat on the curb and asked for his identification. There was also a

vehicle parked in front of the doors at the entrance of the store. Skaggs was in the

driver’s seat with the window down and, according to Sgt. Waltz, appeared to be

scratching lottery tickets. The passenger’s side door of her vehicle was open. Sgt.

Waltz approached Skaggs. He testified that she appeared very nervous. He

instructed her to exit the vehicle. Sgt. Waltz further testified that Skaggs grabbed a

black velvet bag from the center console and placed it in her pocket prior to exiting

the vehicle. He then obtained Skaggs’ identification. After running her

information through dispatch, he discovered that Skaggs had an outstanding

warrant from Boyd Circuit Court.

Once Sgt. Waltz learned of the arrest warrant, he patted down Skaggs.

He removed the black velvet bag from her pocket, which held five smaller bags.

1 The man was later identified as Brian Nance, who had been a passenger in Skaggs’ vehicle.

-2- Skaggs eventually admitted the bag contained methamphetamine; twenty white

pills identified as gabapentin; a bag of marijuana; and numerous small, empty

baggies. Sgt. Waltz informed Skaggs that he was arresting her for trafficking

methamphetamine in addition to the warrant. At that time, Skaggs stated she sold

the drug only to support her own habit. Sgt. Waltz testified that Skaggs gave him

permission to search her vehicle and informed him that he would find a scale in the

center console, which he did.

Skaggs was indicted by a Rowan County grand jury on one count of

trafficking methamphetamine, first degree, two or more grams; one count of

trafficking in a controlled substance, third degree (gabapentin); possession of

marijuana; and being a persistent felony offender, first degree. Skaggs filed a

motion to suppress evidence resulting from the search of her person and vehicle as

well as the statements she made while in custody. The circuit court held a hearing

and subsequently entered an order suppressing all evidence seized and all

statements made by Skaggs. The Commonwealth filed the instant appeal.

Standard of Review

Our standard of review applicable to a decision on a motion to

suppress requires that we first determine whether the circuit court’s findings of fact

are supported by substantial evidence. If so, we must then conduct a de novo

review of the circuit court’s application of the law to determine whether its

-3- decision is correct as a matter of law. Commonwealth v. Neal, 84 S.W.3d 920, 923

(Ky. App. 2002). The presence or absence of “reasonable suspicion” is also

reviewed de novo on appeal. Gray v. Commonwealth, 150 S.W.3d 71, 74 (Ky.

App. 2004).

Analysis

The Fourth Amendment to the United States Constitution, made

applicable to the states via the Fourteenth Amendment,2 provides, in relevant part,

that “the right of the people to be secure in their persons, houses, papers, and

effects, against unreasonable searches and seizures, shall not be violated[.]” In

defining what constitutes a seizure under the Fourth Amendment, the United States

Supreme Court has ruled that “whenever a police officer accosts an individual and

restrains his freedom to walk away, he has ‘seized’ that person.” Terry v. Ohio,

392 U.S. 1, 16, 88 S. Ct. 1868, 1877, 20 L. Ed. 2d 889 (1968). A court must

examine the totality of circumstances surrounding the incident to determine

whether a reasonable person believed he was free to walk away, which includes,

but is not limited to, “the use of language or tone of voice indicating that

compliance with the officer’s request might be compelled.” United States v.

Mendenhall, 446 U.S. 544, 554, 100 S. Ct. 1870, 1877, 64 L. Ed. 2d 497 (1980).

The exclusionary rule provides that “evidence obtained in violation of the Fourth

2 See also Section Ten of Kentucky’s Constitution (KY. CONST. §10).

-4- Amendment cannot be used in a criminal proceeding against the victim of the

illegal search and seizure.” United States v. Calandra, 414 U.S. 338, 347, 94 S.

Ct. 613, 619, 38 L. Ed. 2d 561 (1974) (citation omitted).

There are, however, exceptions to the exclusionary rule. The

attenuation doctrine is one of three such exceptions3 recognized by the United

States Supreme Court. It allows evidence to be admitted “when the connection

between unconstitutional police conduct and the evidence is remote or has been

interrupted by some intervening circumstance, so that the interest protected by the

constitutional guarantee that has been violated would not be served by suppression

of the evidence obtained.” Utah v. Strieff, ___U.S. ___, 136 S. Ct. 2056, 2061, 195

L. Ed. 2d 400 (2016) (internal quotations and citation omitted). In Strieff, the State

conceded that the officer did not have probable cause to seize Strieff; however,

once the officer discovered Strieff had an outstanding arrest warrant, the warrant

“broke the causal chain between the unconstitutional stop and the discovery of

evidence[.]” Id. at 2063.

Turning to the case at hand, we find no fault in the circuit court’s

determination that Sgt. Waltz’s initial seizure of Skaggs was not constitutionally

justified; indeed, the record contains evidence of substance supporting this

3 The other two exceptions are the independent source doctrine and the inevitable discovery doctrine. See Warick v. Commonwealth, 592 S.W.3d 276, 281 (Ky. 2019).

-5- decision. Sgt. Waltz could have briefly detained Skaggs, even without probable

cause to arrest her, if there was a reasonable suspicion that criminal activity was

afoot. Gray, 150 S.W.3d at 74 (citing Terry, 392 U.S. at 20-23). Sgt. Waltz

testified only that he “asked [Skaggs] to step out [of her vehicle] because she was

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Terry v. Ohio
392 U.S. 1 (Supreme Court, 1968)
United States v. Calandra
414 U.S. 338 (Supreme Court, 1974)
Brown v. Illinois
422 U.S. 590 (Supreme Court, 1975)
United States v. Mendenhall
446 U.S. 544 (Supreme Court, 1980)
Gray v. Commonwealth
150 S.W.3d 71 (Court of Appeals of Kentucky, 2004)
Commonwealth v. Neal
84 S.W.3d 920 (Court of Appeals of Kentucky, 2002)
Regional Jail Authority v. Tackett
770 S.W.2d 225 (Kentucky Supreme Court, 1989)
Commonwealth v. Mobley
160 S.W.3d 783 (Kentucky Supreme Court, 2005)
Elwell v. Stone
799 S.W.2d 46 (Court of Appeals of Kentucky, 1990)
Utah v. Strieff
579 U.S. 232 (Supreme Court, 2016)
Howard v. Spradlin
562 S.W.3d 281 (Court of Appeals of Kentucky, 2018)
Utah v. Strieff
579 U.S. 232 (Supreme Court, 2016)

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