Commonwealth of Kentucky v. Phillip Brent Kirby

CourtCourt of Appeals of Kentucky
DecidedMarch 28, 2025
Docket2024-CA-0161
StatusUnpublished

This text of Commonwealth of Kentucky v. Phillip Brent Kirby (Commonwealth of Kentucky v. Phillip Brent Kirby) 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. Phillip Brent Kirby, (Ky. Ct. App. 2025).

Opinion

RENDERED: MARCH 28, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-0161-MR

COMMONWEALTH OF KENTUCKY APPELLANT

APPEAL FROM BARREN CIRCUIT COURT v. HONORABLE JOHN T. ALEXANDER, JUDGE ACTION NO. 21-CR-00015

PHILLIP BRENT KIRBY APPELLEE

OPINION REVERSING AND REMANDING

** ** ** ** **

BEFORE: ACREE, KAREM, AND LAMBERT, JUDGES.

KAREM, JUDGE: The Commonwealth of Kentucky appeals from the Barren

Circuit Court’s order granting Phillip Brent Kirby (“Kirby”) relief pursuant to

Kentucky Rule of Civil Procedure (“CR”) 60.02. Kirby sought CR 60.02 relief

based on the claim that his total aggregate sentence violated the statutory cap in

Kentucky Revised Statute (“KRS”) 532.110(1)(c). Upon careful review, we reverse the circuit court’s order amending Kirby’s sentence and remand this matter

for reinstatement of the original judgment and sentence.

FACTUAL AND PROCEDURAL BACKGROUND

In January 2021, Kirby was indicted by the Barren County Grand Jury

for one (1) count of trafficking in a controlled substance (methamphetamine two

(2) grams or more), two (2) counts of receiving stolen property ($500 or more but

less than $10,000), possession of drug paraphernalia, and being a persistent felony

offender (“PFO”) in the first degree.

In December 2022, Kirby accepted the Commonwealth’s offer on a

plea of guilty. In its offer, the Commonwealth recommended five (5) years’

imprisonment for the amended charge of first-degree trafficking in a controlled

substance (methamphetamine less than two (2) grams), three (3) years’

imprisonment for both counts of receiving stolen property, and twelve (12)

months’ imprisonment for the possession of drug paraphernalia charge. The

Commonwealth also agreed to dismiss the first-degree PFO enhancement.

Moreover, the Commonwealth recommended that the sentences in

Kirby’s Barren County case run concurrently for a total of five (5) years’

imprisonment. However, the Commonwealth’s offer expressly indicated that

Kirby’s sentence in the Barren County case would run consecutively to sentences

he had received in prior cases in other counties. On December 5, 2022, the circuit

-2- court sentenced Kirby to five (5) years’ imprisonment in accordance with his plea

deal and entered final judgment on December 9, 2022.

As noted, Kirby had various convictions in multiple jurisdictions over

the four (4) years preceding his sentencing in Barren County, including:

- Four Allen County convictions on August 21, 2020, for first-degree

possession of a controlled substance (methamphetamine), theft by unlawful

taking (automobile), theft by unlawful taking (firearm), and possession of a

firearm by a convicted felon, for which he received an aggregate sentence of

five (5) years’ imprisonment (Case Number 19-CR-00115);

- Two Warren County convictions on October 29, 2020, for first-degree

possession of a controlled substance and possession of a firearm by a

convicted felon, for which he received an aggregate sentence of three (3)

years’ imprisonment (Case Numbers 18-CR-01225 and 18-CR-01226); and

- Two Warren County convictions on November 16, 2022, for first-degree

trafficking in a controlled substance (methamphetamine) and first-degree

bail jumping, with an enhancement for being a second-degree PFO, for

which he received an aggregate sentence of eleven (11) years’ imprisonment

(Case Numbers 21-CR-00467 and 22-CR-00901).

Thus, including his sentence in Barren County, Kirby’s total imprisonment time

was twenty-four (24) years.

-3- On October 5, 2023, Kirby filed a post-conviction motion under CR

60.02(f), arguing that his aggregate sentence was illegal under the Kentucky

Supreme Court’s decision in Kimmel v. Commonwealth, 671 S.W.3d 230 (Ky.

2023). The circuit court concluded that Kirby’s sentence was invalid to the extent

that the sentence imposed in Barren County, when run consecutively to Kirby’s

prior sentences, caused his resulting sentence to exceed twenty (20) years in

violation of the sentencing cap outlined in KRS 532.110(1)(c). Thus, the circuit

court granted Kirby’s request and amended his aggregate sentence to twenty (20)

years rather than twenty-four (24) years. This appeal followed.

We will discuss further facts as they become relevant.

ANALYSIS

Before conducting our analysis, we first note that Kirby failed to file

an appellee brief. Therefore, under Kentucky Rule of Appellate Procedure

(“RAP”) 31(H)(3), we may: “(a) accept the appellant’s statement of the facts and

issues as correct; (b) reverse the judgment if appellant’s brief reasonably appears to

sustain such action; or (c) regard the appellee’s failure as a confession of error and

reverse the judgment without considering the merits of the case.” Here, we will

accept the Commonwealth’s statement of the facts and issues as correct.

-4- 1. Standard of Review

“The standard of review of an appeal involving a CR 60.02 motion is

whether the trial court abused its discretion.” White v. Commonwealth, 32 S.W.3d

83, 86 (Ky. App. 2000) (citation omitted). “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). With this standard in mind, we examine

the Commonwealth’s arguments.

2. Discussion

The Commonwealth argues that the circuit court erred in granting

Kirby CR 60.02 relief and amending his sentence. As discussed by a panel of this

Court:

The decision as to whether to grant or to deny a motion filed pursuant to the provisions of CR 60.02 lies within the sound discretion of the trial court. The rule provides that a court may grant relief from its final judgment or order upon various grounds. Moreover, the law favors the finality of judgments. Therefore, relief may be granted under CR 60.02 only with extreme caution and only under the most unusual and compelling circumstances.

Age v. Age, 340 S.W.3d 88, 94 (Ky. App. 2011) (citations omitted).

Having reviewed the record and applicable law, we find the circuit

court’s exercise of discretion in this case to be “unsupported by sound legal

-5- principles” and do not find the circumstances to be “most unusual and compelling”

to justify relief from the final judgment under CR 60.02. English, 993 S.W.2d at

945; Id.

Under KRS 532.110(1), a circuit court may “determine at the time of

sentence” whether “multiple sentences shall run concurrently or consecutively,”

subject to certain exceptions. One of those exceptions is that “the aggregate of

consecutive indeterminate terms shall not exceed in maximum length the longest

extended term which would be authorized by KRS 532.080 for the highest class of

crime for which any of the sentences is imposed[.]” See KRS 532.110(1)(c).1 In

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Related

Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
White v. Commonwealth
32 S.W.3d 83 (Court of Appeals of Kentucky, 2000)
Age v. Age
340 S.W.3d 88 (Court of Appeals of Kentucky, 2011)
Johnson v. Commonwealth
553 S.W.3d 213 (Missouri Court of Appeals, 2018)

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Commonwealth of Kentucky v. Phillip Brent Kirby, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-of-kentucky-v-phillip-brent-kirby-kyctapp-2025.