Commonwealth of Kentucky v. Robert W McDowell

CourtCourt of Appeals of Kentucky
DecidedFebruary 14, 2024
Docket2023 CA 000323
StatusUnknown

This text of Commonwealth of Kentucky v. Robert W McDowell (Commonwealth of Kentucky v. Robert W McDowell) 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. Robert W McDowell, (Ky. Ct. App. 2024).

Opinion

RENDERED: FEBRUARY 16, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2023-CA-0323-MR

COMMONWEALTH OF KENTUCKY APPELLANT

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE BRIAN C. EDWARDS, JUDGE ACTION NO. 21-CR-001166

ROBERT MCDOWELL APPELLEE

OPINION VACATING AND REMANDING

** ** ** ** **

BEFORE: EASTON, KAREM, AND TAYLOR, JUDGES.

KAREM, JUDGE: The Commonwealth of Kentucky appeals from an opinion and

order of the Jefferson Circuit Court granting Robert W. McDowell Jr.’s motion to

exclude statements and identifications made by a shooting victim identifying

McDowell as the perpetrator. The Commonwealth argues that the trial court

abused its discretion in ruling that the statements were not admissible under the dying declaration exception to the hearsay rule.1 Upon careful review, we vacate

and remand for further findings.

FACTUAL AND PROCEDURAL BACKGROUND

On the afternoon of February 24, 2021, Rayshaun Peyton was shot

eleven times as he walked down the sidewalk in Louisville. Peyton, who was

twenty-two years of age, suffered gunshot wounds to his left chest wall, his right

eye and mouth, his left inner thigh, his right inner thigh, his testicles, and his penis.

He was transported to the University of Louisville Hospital where he was placed in

the Intensive Care Unit. CT scans showed the bullets had fractured his ribs and

vertebrae, causing a spinal cord injury that rendered him quadriplegic. Surgery

was performed to repair his right superficial femoral artery and the injuries to his

penis and scrotum, and he was put in a medically-induced coma and placed on

mechanical ventilation. Peyton’s parents were allowed to stay with their son 24

hours per day, against COVID-19 protocols in place at the time. Peyton’s father,

Rolando, testified, this was “due to the situation; they didn’t know if he was going

to make it or not.”

On March 12, 2021, Peyton was removed from the medically-induced

coma. At that time the doctors removed the ventilator and replaced it with a

1 We note that McDowell’s motion asserted a violation of his 6th Amendment Confrontation Right even if the statements qualified as dying declarations. The circuit court and the parties on this appeal did not address this, which remains an open question under Kentucky law. Lewis v. Commonwealth, 475 S.W.3d 26, 37 n.6 (Ky. 2015).

-2- tracheostomy tube, which allowed him to speak for the first time since the

shooting. On that day, and the days that immediately followed, Peyton made the

statements and identifications that are at issue in the case sub judice. The trial

court described Peyton’s first statement as follows:

During this period of improvement, Mr. Peyton’s father testified that on March 12, 2021, he asked Mr. Peyton “who did this to you[?]” to which Mr. Peyton responded, “Bobby shot me.”

Rolando, hoping to discover the identity of “Bobby,” enlisted the help of his niece.

She found a social media post relating to Peyton’s shooting which Rolando, in turn

showed to Peyton, at some point after March 12, 2021, but before March 15, 2021.

Rolando testified that, upon seeing the post, Peyton was reluctant to name the

shooter. However, he further testified that although his son didn’t want to name

the shooter, “we were going to do this today because I didn’t know if my son

would be here tomorrow.” Ultimately, Peyton identified his shooter and Rolando

passed the name along to the lead detective on the case.

On March 15, 2021, two detectives visited Peyton and presented him

with a six-person photo pack. Peyton’s condition ebbed and flowed during this

time, and on March 15, 2021, he was not capable of speaking. But he selected

McDowell from the photo pack by nodding his head and raising his eyebrows.

Dr. Daniel Dierfeldt, a palliative care physician, testified that on

March 19, 2021, he was notified that Peyton was one step from a code blue, a

-3- medical term for death. Dr. Dierfeldt explained that his role was to support the

patient and his family. Dr. Dierfeldt described the prognosis at that time as “very,

very dire.” He told Peyton’s mother that Peyton was having difficulty making a

recovery and that he might not survive. Dr. Dierfeldt testified that Peyton was

unable to breathe without the machines and he was unable to move because he was

quadriplegic. He told Peyton’s mother that if care was withdrawn Peyton would

live for minutes or hours, and if care continued, he would live for weeks or

months. Peyton’s parents ultimately decided not to withdraw care.

Peyton was discharged from the hospital on April 10, 2021. He was

transferred to several facilities over the following months. Peyton died on January

25, 2022, approximately ten months after he identified McDowell as the shooter.

On June 7, 2021, McDowell was indicted for criminal attempted

murder, assault in the first degree, and possession of a handgun by a convicted

felon. His attorney moved to exclude all statements made by Peyton to Rolando

and the police as inadmissible hearsay. The Commonwealth filed a response,

arguing in part that the statements were admissible as a dying declaration. After

hearing testimony from Dr. Dierfeldt and Peyton’s parents, the trial court entered

an order granting McDowell’s motion. The trial court based its decision on two

factors: first, that a lengthy period elapsed between the time the statements were

made and Peyton’s death, and second, that Peyton’s condition had improved at the

-4- time he made the statements incriminating McDowell. This appeal by the

Commonwealth followed.

STANDARD OF REVIEW

“[W]e may reverse a trial court’s decision to admit evidence only if

that decision represents an abuse of discretion.” Clark v. Commonwealth, 223

S.W.3d 90, 95 (Ky. 2007). An abuse of the court’s discretion only occurs if its

ruling is “arbitrary, unreasonable, unfair, or unsupported by sound legal

principles.” Commonwealth v. English, 993 S.W.2d 941, 945 (Ky. 1999). When,

as in this case, the trial court conducted a lengthy evidentiary hearing, its findings

of fact are reviewed for clear error. Kentucky Rules of Civil Procedure (CR)

52.01; Turner v. Commonwealth, 5 S.W.3d 119, 122 (Ky. 1999), as modified (Dec.

16, 1999). A finding is not clearly erroneous if it is supported by substantial

evidence. Owens-Corning Fiberglas Corp. v. Golightly, 976 S.W.2d 409, 414 (Ky.

1998).

ANALYSIS

Hearsay is “a statement, other than one made by the declarant while

testifying at the trial or hearing, offered in evidence to prove the truth of the matter

asserted.” Kentucky Rules of Evidence (KRE) 801(c). A statement is defined as

“[a]n oral or written assertion; or . . . [n]onverbal conduct of a person, if it is

intended by the person as an assertion.” KRE 801(a). The parties agree that

-5- Peyton’s verbal identifications of McDowell as the shooter to his father and his

subsequent nonverbal identification of McDowell in the photo pack qualify as

hearsay prompting McDowell to ask the court to exclude the statements.

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Related

Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
Turner v. Commonwealth
5 S.W.3d 119 (Kentucky Supreme Court, 1999)
Clark v. Commonwealth
223 S.W.3d 90 (Kentucky Supreme Court, 2007)
Owens-Corning Fiberglas Corp. v. Golightly
976 S.W.2d 409 (Kentucky Supreme Court, 1998)
Lewis v. Commonwealth
475 S.W.3d 26 (Kentucky Supreme Court, 2015)

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