Declan J McAuley v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedJuly 3, 2025
Docket2024-CA-0113
StatusUnpublished

This text of Declan J McAuley v. Commonwealth of Kentucky (Declan J McAuley 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
Declan J McAuley v. Commonwealth of Kentucky, (Ky. Ct. App. 2025).

Opinion

RENDERED: JULY 3, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-0113-MR

DECLAN J. MCAULEY APPELLANT

APPEAL FROM OLDHAM CIRCUIT COURT v. HONORABLE JERRY CROSBY, II, JUDGE ACTION NO. 18-CR-00184

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: COMBS, ECKERLE, AND L. JONES, JUDGES.

ECKERLE, JUDGE: Appellant, Declan J. McAuley (“McAuley”), seeks review

of a judgment of the Oldham Circuit Court sentencing him to a total of 12-years’

imprisonment after a jury found him guilty of two counts of first-degree unlawful

transaction with a minor, use of a minor in a sexual performance, three counts of

third-degree sodomy, complicity to first-degree sexual abuse, tampering with

physical evidence, and possession of matter portraying a sexual performance by a

minor. We affirm. I. Factual and Procedural History

McAuley and his wife operated a dance studio, where Victim1 was a

student of dance. Eventually, Victim also taught dance classes at the studio. It is

uncontested that Victim was 17 years old at the time of the events in question.

McAuley did not teach dance lessons but handled the studio’s business affairs and

had business cards referring to himself as the studio’s executive director.

After Victim alleged that she had engaged in sexual conduct with

McAuley, an Oldham County grand jury indicted McAuley for eight counts of

unlawful transaction with a minor in the first degree, six counts of use of a minor

in a sexual performance, eight counts of sodomy in the third degree, rape in the

third degree, sexual abuse in the first degree, complicity to sexual abuse in the first

degree, and tampering with physical evidence.

In pretrial proceedings, the Commonwealth dismissed many of those

charges, and the Trial Court denied McAuley’s motion to declare Kentucky

Revised Statute (“KRS”) 532.045 unconstitutional. That statute, which will be

discussed below, defines the types of persons and roles of those who occupy a

position of authority or position of special trust. As it pertains here, a person

holding such a position may commit certain offenses, such as sodomy in the third

1 Though she is above the age of majority now, we identify her as “Victim” to protect her privacy. She was a minor at the time of the relevant, underlying events.

-2- degree (KRS 510.090(1)(d)), against a 17-year-old minor2 even though the age of

consent in Kentucky generally is 16. See KRS 510.020(3)(a). The Trial Court

concluded that the issue of whether McAuley held one of those positions in

relation to Victim was a factual question for the jury to resolve. Caldwell v.

Commonwealth, 554 S.W.3d 874, 876 (Ky. App. 2018) (“The determination of

whether Caldwell’s relationship with the victim amounted to a position of special

authority or trust with the victim was a question of fact, and therefore a matter for

the jury to determine.”).

The charges against McAuley that the Trial Court had not dismissed

eventually proceeded to a multi-day jury trial. Victim testified that, during a trip to

England, McAuley began speaking with her about sexual matters and asked her if

she wanted to watch him and his wife have sex. Victim agreed to do so. Victim

then began spending some weekends at McAuley’s home, purportedly to learn

more about the business side of the dance studio. According to Victim, she

engaged in sexual conduct with both McAuley and his wife at their home.

Victim testified about five sexual encounters. On one occasion,

Victim alleged that McAuley dressed her in a corset, then manually and orally

stimulated his wife’s vagina while Victim watched, and then McAuley induced

2 KRS 2.015 provides that, with limited exceptions not at issue here, “[p]ersons of the age of eighteen (18) years are of the age of majority for all purposes in this Commonwealth . . . .”

-3- Victim to perform similar acts on his wife. On another occasion, McAuley gave a

massage to both Victim and his wife on a bed. During the massage, McAuley

inserted his fingers into Victim’s vagina. On a third occasion, Victim was in bed

with McAuley and his wife, and McAuley inserted his fingers into Victim’s vagina

and performed oral sex on her. Victim alleges that McAuley tried to insert his

penis into her vagina but stopped when Victim said she did not want him to do so.

McAuley and his wife then had sex next to a crying Victim.

The final two incidents related by Victim occurred on the same day.

In the first, McAuley blindfolded Victim and then performed oral sex on her and

inserted his fingers into her vagina. At one point, a blindfolded Victim felt more

pressure in her vaginal area, but McAuley assured her he was only using his

fingers. McAuley then encouraged Victim to perform oral sex on him, which she

did. Later that day, McAuley had Victim perform oral sex on him a second time,

while his wife was present.

During the trial, the Trial Court held a roughly two-hour conference

about potential jury instructions with the parties and outside the jury’s presence.

The main point of the lengthy conference was to ascertain the particular acts that

formed the basis of each specific charge against McAuley. The jury instructions

were obviously still being drafted during the conference and unquestionably were

not yet in their final form. During the conference, which at times was very

-4- informal, the Trial Court accurately cautioned the parties that under Kentucky law,

the final instructions must contain identifying information to enable the jury to

ascertain the particular, alleged conduct that formed the basis of each count of the

same offense.

As our Supreme Court has held in this regard:

We again instruct the bench and bar of the Commonwealth that in a case involving multiple counts of the same offense, a trial court is obliged to include some sort of identifying characteristic in each instruction that will require the jury to determine whether it is satisfied from the evidence the existence of facts proving that each of the separately charged offenses occurred.

Harp v. Commonwealth, 266 S.W.3d 813, 818 (Ky. 2008). Despite the Trial

Court’s warnings, the final jury instructions it gave did not expressly comply with

Harp.

The Trial Court submitted the following charges to the jury: four

counts of unlawful transaction with a minor in the first degree; two counts of use of

a minor in a sexual performance; three counts of sodomy in the first degree; one

count of rape in the third degree; one count of complicity to sexual abuse in the

first degree; one count of tampering with physical evidence; and one count of

possession of matter portraying a sexual performance by a minor. The jury

acquitted McAuley of two counts of unlawful transaction with a minor, one count

of use of a minor in a sexual performance, and rape in the third degree, but found

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