Donald Starks v. Kentucky Parole Board

Court of Appeals of Kentucky·Decided September 18, 2026·No. 2022-CA-1463·Unpublished

Opinion

RENDERED: SEPTEMBER 18, 2026; 10:00 A.M.

NOT TO BE PUBLISHED

Commonwealth of Kentucky

Court of Appeals

NO. 2022-CA-1463-MR

DONALD STARKS APPELLANT

APPEAL FROM PIKE CIRCUIT COURT v. HONORABLE EDDY COLEMAN, JUDGE ACTION NO. 22-CI-00778

KENTUCKY PAROLE BOARD APPELLEE

OPINION

REVERSING AND REMANDING

** ** ** ** **

BEFORE: CALDWELL, A. JONES, AND TAYLOR, JUDGES. CALDWELL, JUDGE: Appellant Donald Starks appeals from the Pike Circuit Court’s grant of summary judgment to the Kentucky Parole Board.1 Starks had

1 Prior to 2021, judicial review of decisions of the Kentucky Parole Board would find venue in Franklin Circuit Court, where the offices of the Board are located. However, in 2021, the General Assembly passed HB 3, and overrode a veto of the legislation. This new legislation was described by the Kentucky Supreme Court as follows:

Among other things, this new section provided that the venue for any civil suit challenging the constitutionality of a Kentucky

sought the circuit court’s review of the Kentucky Parole Board’s revocation of his supervised release. We reverse the circuit court and remand this matter back to the circuit court.

FACTS

Starks entered a guilty plea to two counts of sexual abuse in the first degree in Campbell Circuit Court in 2016. He was sentenced, in accordance with the plea agreement, to seven years’ imprisonment.2 Starks was released from incarceration in November of 2020,3 and was placed on Sex Offender Post-Incarceration Supervision (SOPS) in accordance with the law.4 At some point following his release from confinement, Starks was

statute, executive order, administrative regulation, or order of any cabinet that includes a claim for declaratory or injunctive relief and is brought against a state official in his or her official capacity is in any county where a plaintiff in the suit resides. This marked a significant change, as prior to the passage of H.B. 3, suits of this type were typically required to be brought in Franklin Circuit Court.

Beshear v. Goodwood Brewing Company, LLC, 635 S.W.3d 788, 794 (Ky. 2021), reh’g denied (Dec. 16, 2021).

2 Starks appealed as a matter of right from his conviction and sentence which we affirmed. Starks v. Commonwealth, No. 2016-CA-001535-MR, 2018 WL 671325 (Ky. App. Feb. 2, 2018). 3 In pleadings before this Court and the circuit court, Starks indicates his date of release on SOPS was November 4, 2020. The Administrative Law Judge (ALJ) who presided over his revocation probable cause hearing found he was released on November 14, 2020.

4 (1) In addition to the penalties authorized by law, any person convicted of, pleading guilty to, or entering an [North Carolina v.

Alford, 400 U.S. 25, 91 S. Ct. 160, 27 L. Ed. 2d 162 (1970)], plea to a felony offense under KRS Chapter 510, 529.100 involving

enrolled at WestCare, a facility run by a non-profit corporation with various locations throughout the Central and Eastern Kentucky regions.5 He was

commercial sexual activity, 530.020, 530.064(1)(a), 531.310, or 531.320 shall be subject to a period of postincarceration supervision following release from:

(a) Incarceration upon expiration of sentence; or (b) Completion of parole.

(2) The period of postincarceration supervision shall be five (5)

years.

(3) During the period of postincarceration supervision, the defendant shall:

(a) Be subject to all orders specified by the Department of Corrections; and

(b) Comply with all education, treatment, testing, or combination thereof required by the Department of Corrections.

(4) Persons under postincarceration supervision pursuant to this section shall be subject to the supervision of the Division of Probation and Parole and under the authority of the Parole Board.

(5) If a person violates a provision specified in subsection (3) of this section, the violation shall be reported in writing by the Division of Probation and Parole. Notice of the violation shall be sent to the Parole Board to determine whether probable cause exists to revoke the defendant’s postincarceration supervision and reincarcerate the defendant as set forth in KRS 532.060.

(6) The provisions of this section shall apply only to persons convicted, pleading guilty, or entering an Alford plea after July 15, 1998.

KRS 532.043 (declared unconstitutional on ex post facto application in Roach v. Commonwealth, 553 S.W.3d 791 (Ky. 2018)).

apparently discharged at some point and was living independently, it appears from the scant record before us.

In November of 2021, Starks made a request to his parole officer6 that he be allowed to return to WestCare for further treatment. This request was completely voluntary on Starks’ part and was not made as a stipulation of his continued supervision. Starks’ parole officer agreed to the request and Starks returned to WestCare.

In February of 2022, Starks was discharged from WestCare following an altercation. Starks alleges he became concerned due to lax COVID-19 protocols and the failure of the facility to ensure that patients were receiving necessary medications. Starks complained that he had not received a prescribed mood stabilizer for over a month. Starks also raised a concern that a fellow patient had not received blood pressure medications and was possibly at risk of suffering a stroke. Starks admitted that he cursed at the staff and threatened legal action over the treatment patients were receiving and was discharged.

5 According to the non-profit organization’s website: “In October 2004, WestCare incorporated as a nonprofit in the Commonwealth of Kentucky. WestCare provides substance abuse treatment services in eastern and central Kentucky.” 6 Even though SOPS is not “parole” in the traditional sense, the Department of Corrections supervises sex offenders using parole officers. “The Parole Board states that sex offender conditional discharge (now referred to as post-incarceration supervision) is treated as parole under the statute, so the parole revocation procedures apply here.” Jones v. Bailey, 576 S.W.3d 128, 139 (Ky. 2019).

Starks’ parole officer charged him with violating the terms of supervision. Starks received written notice of the following alleged violations:

1. Failure to abide by rules of Halfway House Mr. Starks has been discharged from Westcare (sic) for violating house rules according to discharge summary. Mr.

Starks is displaying violent and threatening communication towards staff and other residents.

2. Failure to cooperate with Probation/Parole Officer Mr. Starks has failed to cooperate with Probation and Parole as he has been discharged from halfway house. Dismas Owensboro has denied his placement, and he has no where (sic) to reside at this time.

A probable cause hearing was held on March 1, 2022, in front of a hearing officer who found probable cause for Starks’ supervision to be revoked. The final hearing, again conducted before an administrative hearing officer, was held on March 15, 2022. The Parole Board issued its Final Decision on March 31, 2022, relying upon the findings of the hearing officer. The Board determined that Starks’ parole should be revoked, and he should serve the remainder of his SOPS within a Department of Corrections institution.

Starks, through counsel, filed a complaint seeking declaratory and injunctive relief and/or a writ of mandamus.7 Specifically, Starks demanded an order declaring

7 We note that Starks provided notice by serving the Attorney General, as required by KRS 452.005(3) when alleging constitutional violations.

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