Deltoria Kincaid v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedAugust 29, 2025
Docket2024-CA-1187
StatusUnpublished

This text of Deltoria Kincaid v. Commonwealth of Kentucky (Deltoria Kincaid 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
Deltoria Kincaid v. Commonwealth of Kentucky, (Ky. Ct. App. 2025).

Opinion

RENDERED: AUGUST 29, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-1187-MR

DELTORIA KINCAID APPELLANT

APPEAL FROM FAYETTE CIRCUIT COURT v. HONORABLE KIMBERLY N. BUNNELL, JUDGE ACTION NO. 23-CR-00684-002

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: COMBS, EASTON, AND LAMBERT, JUDGES.

COMBS, JUDGE: The Appellant, Deltoria Kincaid, was charged with first-degree

strangulation; third-degree assault on a police officer; and resisting arrest. The

Fayette Circuit Court denied her motion to dismiss the indictment; it also denied

her motion to suppress police officers’ testimony as well as the video evidence

captured on their bodycams. She then pleaded guilty. She made her plea pursuant

to the holding of North Carolina v. Alford, 400 U.S. 25, 91 S. Ct. 160, 27 L. Ed. 2d 162 (1970), reserving the right to appeal her conviction. The circuit court

sentenced Kincaid to twelve-months’ incarceration, probated for two years. After

reviewing the record and considering the arguments of counsel, we affirm the

conviction.

On May 21, 2023, officers from the Lexington Police Department

responded to a call concerning a disturbance at Gatewood Court in Lexington.

This was the second call concerning this address on this same night regarding what

the officer’s uniform citation referred to as “subjects being involved in an active

fight.” Following a melee that began at the front door of the residence, both

Kincaid, and her son, Terry Philon, Jr., were arrested. On July 24, 2023, Kincaid

and Philon were indicted by the grand jury in Fayette Circuit Court.

On January 24, 2024, Kincaid filed a motion to dismiss the

indictment. She argued that she was immune from prosecution pursuant to the

provisions of KRS1 503.085. In pertinent part, KRS 503.085 provides immunity

from criminal prosecution to persons who use force in defense of self or others --

unless there is probable cause to believe that the use of force was unlawful.

Immunity from prosecution under this provision is not available where the person

against whom the force was used is a peace officer who identified himself and was

acting in the performance of his official duties.

1 Kentucky Revised Statutes.

-2- The Commonwealth argued that Kincaid was not entitled to immunity

from prosecution under this provision because there was probable cause to believe

that her use of force was unlawful; i.e., because she had indeed used force against a

peace officer who was acting in the performance of his official duties and had

identified himself. Although not specifically relevant to the finding of probable

cause, the Commonwealth denied that the police officers acted unreasonably at any

point and observed that even where arrest of another is unlawful, a defendant is not

entitled to use force against a police officer. The circuit court determined that

there was probable cause to believe that Kincaid’s use of force was unlawful and

denied her motion to dismiss the indictment in an order entered on February 6,

2024.

Kincaid also joined Philon in a motion to suppress evidence. In

response, the Commonwealth noted that no evidence was seized as a result of the

disturbance call. It also argued that police officers did not seek to collect evidence

of the assaults against them by making unlawful entry into Kincaid’s residence;

therefore, their testimony and body-cam video should not be suppressed. It argued

that the trial court was bound by our decision in Commonwealth v. Johnson, 245

S.W.3d 821, 825 (Ky. App. 2008). In Johnson, we held that even where a police

officer made illegal entry into a residence, evidence of a subsequent assault against

the officer could not be ruled inadmissible under the exclusionary rule. Kincaid’s

-3- motion to suppress was denied by the trial court by order entered on March 25,

After the trial court denied her motion to suppress evidence, Kincaid

entered her guilty plea on July 1, 2024. The circuit court’s final judgment of

conviction was entered on August 8, 2024. Kincaid’s sentence was suspended, and

she was placed on probation for two years. This appeal followed.

On appeal, Kincaid argues that the trial court erred by failing to

dismiss the indictment against her because she is immune from prosecution. We

disagree.

Following a hearing, the trial court concluded that Kincaid was not

entitled to immunity from criminal prosecution pursuant to KRS 503.085 because

there was probable cause to believe that her use of force was not legally justified.

When reviewing cases involving claims of immunity under this provision, we must

consider whether there was a substantial basis for the trial court’s conclusion

concerning probable cause. Commonwealth v. Lemons, 437 S.W.3d 708, 712–13

(Ky. 2014).

The Commonwealth presented evidence to show that Lexington police

officers William Gonzales and Myles Foster knocked at the door of Kincaid’s

residence and announced their presence. They were in full uniform and arrived in

a police cruiser. Officer Gonzales reported that when the door was opened, he

-4- explained to the occupants why he and Officer Foster were there. In response,

Kincaid’s son, Philon, immediately made provocative statements and approached

Officer Gonzales in a threatening manner. In order to secure the scene and to

prevent escalation, Officer Gonzales attempted to restrain Philon, who began to

resist. Kincaid intervened. Philon was eventually restrained and was removed

from the residence. However, he continued to resist officers. At this point,

Kincaid jumped on Officer Foster’s back and choked him until he began to lose

consciousness. Other officers responded to the scene and were able to gain control

both of Philon and of his mother.

According to Kincaid, after Philon pulled away from Officer Foster,

Foster entered her home, and “to protect [Philon] from further injury,” she lay

down on top of him. “At the assurance of no further harm to her son, [Kincaid]

allowed officers to arrest [Philon.]” Kincaid explains that “[t]here is some

ambiguity as to how they ended up on the ground, but after [Philon] was arrested

and in cuffs, he fell with two officers landing on top of him.” That is when

Kincaid admits she began to strangle Officer Foster.

Kincaid argues that she is entitled to immunity because Officer Foster

was acting “outside the color of official authority and used more force than

reasonably necessary” after her son was handcuffed -- “at which point [she] acted

in defense of her son.” However, when she sought dismissal of the indictment, that

-5- was not the issue before the court. The single issue before the trial court was

whether there was probable cause to believe that Kincaid’s use of force was not

legally justified. “Probable cause has . . . been defined as ‘reasonable grounds for

belief, supported by less than prima facie proof but more than mere suspicion.’”

Lemons, 437 S.W.3d at 715 (Ky.

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Related

North Carolina v. Alford
400 U.S. 25 (Supreme Court, 1970)
Commonwealth v. Jones
217 S.W.3d 190 (Kentucky Supreme Court, 2006)
Commonwealth v. Johnson
245 S.W.3d 821 (Court of Appeals of Kentucky, 2008)
Commonwealth v. Lemons
437 S.W.3d 708 (Kentucky Supreme Court, 2014)
Pulley v. Commonwealth
481 S.W.3d 520 (Court of Appeals of Kentucky, 2016)

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