Curtis Snell v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedJuly 18, 2025
Docket2024-CA-0125
StatusUnpublished

This text of Curtis Snell v. Commonwealth of Kentucky (Curtis Snell v. Commonwealth of Kentucky) 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
Curtis Snell v. Commonwealth of Kentucky, (Ky. Ct. App. 2025).

Opinion

RENDERED: JULY 18, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2024-CA-0125-MR

CURTIS SNELL APPELLANT

APPEAL FROM KENTON CIRCUIT COURT v. HONORABLE MARY K. MOLLOY, JUDGE ACTION NO. 16-CR-00665

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

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

JONES, A., JUDGE: Curtis Snell appeals from the Kenton Circuit Court’s order

denying his motion for post-conviction relief pursuant to CR1 60.02. We affirm.

1 Kentucky Rule of Civil Procedure. I. BACKGROUND

A full history of this case may be found in the Kentucky Supreme

Court’s unpublished opinion stemming from Snell’s direct appeal. Snell v.

Commonwealth, No. 2018-SC-000219-MR, 2020 WL 1846852 (Ky. Mar. 26,

2020). Briefly stated, Snell and his then-girlfriend, Jennifer Konkright, were at a

Florence bar in 2016, when Konkright engaged in a physical confrontation with a

female acquaintance, Linsey Kidwell. After Snell attempted to intervene in this

dispute, he was attacked by four of Kidwell’s friends, who happened to be

members of the “Bad to the Bone” motorcycle gang. Bar bouncers eventually

removed all combatants from the premises.

Later that evening, Snell and Konkright were driving their vehicle

when they happened upon Kidwell’s vehicle and began to follow her. Kidwell and

Lamar Mills, one of the motorcycle gang members, were driving together; and

three of Mills’ fellow motorcycle gang members (Robert Smith, Willie

Washington, and Jonathan Griffin) were driving along with them in a separate

vehicle. At some point, Konkright’s vehicle pulled alongside Kidwell’s vehicle;

several gunshots were fired from the window of Konkright’s vehicle at the other

two vehicles at close range; and one of those shots struck Kidwell in the thigh and

abdomen. Snell claimed Konkright had fired the gun, but Kidwell and some of the

motorcycle gang members identified Snell as the shooter to investigating officers.

-2- Snell was ultimately indicted and tried in Kenton Circuit Court for

five offenses stemming from this incident. These included four counts of first-

degree wanton endangerment2 that related, respectively, to Mills, Smith,

Washington, and Griffin (who were inside the vehicles Snell allegedly shot at close

range); and one count of first-degree assault3 that solely related to Kidwell (whom

Snell allegedly shot). The jury found Snell guilty of each count, and of being a

first-degree persistent felony offender (PFO).4 It recommended a consecutive

sentence for all enhanced counts, totaling ninety years in prison, but the trial court

ultimately reduced this recommendation to a maximum statutory sentence of

seventy years’ imprisonment.5

Snell appealed to the Kentucky Supreme Court and asserted

sentencing errors, along with errors regarding the jury instructions, the denial of a

lesser-included-offense instruction, and the denial of his motion to suppress an out-

of-court identification. The Court affirmed. Snell, 2020 WL 1846852.

2 Kentucky Revised Statutes (KRS) KRS 508.060. 3 KRS 508.010. 4 KRS 532.080. 5 “In no event shall the aggregate of consecutive indeterminate terms exceed seventy (70) years[.]” KRS 532.110(1)(c)1.

-3- On August 21, 2020, Snell moved to vacate his conviction and

sentence pursuant to RCr6 11.42. He argued police had violated his right to remain

silent and that trial counsel was ineffective for failing to challenge a third-party

search warrant and for failing to object to the racial composition of the jury. The

circuit court denied his motion, Snell appealed to this Court, and we affirmed.

Snell v. Commonwealth, No. 2021-CA-1167-MR, 2022 WL 4391062 (Ky. App.

Sep. 23, 2022) (unpublished).

On March 14, 2023, Snell then filed what is now the subject of our

review, a motion pursuant to CR 60.02 seeking a sentence modification and a new

trial. He raised four issues. First, he claimed his convictions for first-degree

assault and first-degree wanton endangerment violated the prohibition against

double jeopardy. Second, he argued his punishment was cruel and unusual. Third,

Snell asserted he received inconsistent and erroneous verdicts due to alleged errors

in the jury instructions, and that both his trial and appellate counsel were

ineffective for failing to raise those issues. Fourth, he argued his trial counsel was

ineffective for failing to pursue an extreme emotional disturbance (“EED”) defense

on his behalf. Snell also moved for an evidentiary hearing.

The circuit court denied Snell’s motions in a final order of January 4,

2024. Its rationale, in sum, was that CR 60.02 afforded Snell no remedy because

6 Kentucky Rule of Criminal Procedure.

-4- Snell could have and should have asserted each of the issues set forth in his motion

during his direct appeal or RCr 11.42 proceedings. This appeal followed.

II. STANDARD OF REVIEW

We review the denial of CR 60.02 motions for abuse of discretion.

Young v. Richardson, 267 S.W.3d 690, 697-98 (Ky. App. 2008). “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).

III. ANALYSIS

Snell reasserts on appeal the substance of his CR 60.02 motion

summarized above. With respect to double jeopardy, there appear to be two facets

to his claim of error. First, he argues his convictions of first-degree assault and

first-degree wanton endangerment violated double jeopardy because they

constituted multiple punishments for a single course of conduct – in his words, the

conduct of “shooting blindly out the window.”7 Second, he argues his “Assault

conviction was inconsistent with the Wanton Endangerment conviction that

derived from the same act of a bullet hitting Kidwell while Mills was next to her.”8

7 Appellant Brief at 4. 8 Id.

-5- Snell misunderstands the law and ignores the facts underpinning his

convictions. Double jeopardy is not violated “when the single act or course of

conduct constitutes an offense against more than one person.” Alexander v.

Commonwealth, 766 S.W.2d 631, 632 (Ky. 1988). Thus, if a single act of a

defendant causes the death of two persons, the defendant can be convicted of two

murders without triggering double jeopardy. Id. If a defendant’s single gunshot

into an occupied house kills one occupant and wantonly endangers another, the

defendant can be convicted of the murder of the one occupant and the wanton

endangerment of the other. Id. Indeed, three gunshots into a home occupied by

nine people can warrant nine counts of wanton endangerment. See Paulley v.

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Related

Riley v. Commonwealth
120 S.W.3d 622 (Kentucky Supreme Court, 2003)
Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
Young v. Richardson
267 S.W.3d 690 (Court of Appeals of Kentucky, 2008)
Paulley v. Commonwealth
323 S.W.3d 715 (Kentucky Supreme Court, 2010)
Gross v. Commonwealth
648 S.W.2d 853 (Kentucky Supreme Court, 1983)
Barnett v. Commonwealth
979 S.W.2d 98 (Kentucky Supreme Court, 1998)
Alexander v. Commonwealth
766 S.W.2d 631 (Kentucky Supreme Court, 1988)

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