Donovan Pitmon v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedSeptember 19, 2025
Docket2024-CA-0692
StatusUnpublished

This text of Donovan Pitmon v. Commonwealth of Kentucky (Donovan Pitmon 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
Donovan Pitmon v. Commonwealth of Kentucky, (Ky. Ct. App. 2025).

Opinion

RENDERED: SEPTEMBER 19, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-0692-MR

DONOVAN PITMON APPELLANT

APPEAL FROM NELSON CIRCUIT COURT v. HONORABLE CHARLES C. SIMMS, III, JUDGE ACTION NO. 23-CR-00249

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: CETRULO, KAREM, AND MCNEILL, JUDGES.

MCNEILL, JUDGE: Donovan Pitmon (“Pitmon”) appeals from a Nelson Circuit

Court judgment convicting him of first-degree strangulation and first-degree

persistent felony offender and sentencing him to twelve years in prison. For the

reasons below, we affirm. BACKGROUND

Pitmon and Samantha Doolin (“Doolin”) began a romantic

relationship in 2021 that, according to both parties, became “toxic.” In June 2023,

Doolin reported to police that Pitmon had strangled and raped her. Pitmon was

arrested and charged with first-degree strangulation and first-degree rape.

Following a jury trial, Pitmon was acquitted of the rape charge but convicted of

strangulation and sentenced to twelve years in prison. This appeal followed.

ANALYSIS

1. KRE1 404(b) Evidence

Pitmon first argues he was deprived of a fair trial due to the

prosecutor’s introduction of KRE 404(b) evidence in violation of the court’s

pretrial ruling. Before trial, the Commonwealth filed a KRE 404(c) notice of intent

to introduce evidence of Pitmon’s prior domestic assault conviction. Pitmon filed

a motion in limine to exclude the conviction, arguing the notice was untimely and

the evidence was irrelevant and unduly prejudicial. The circuit court partially

granted the motion, holding the Commonwealth could offer proof that Pitmon was

arrested on a misdemeanor charge in Fayette County but could not identify the

charge or conviction.

1 Kentucky Rules of Evidence.

-2- On appeal, Pitmon has identified nine statements which he contends

violate this ruling. Pitmon concedes he did not object to the statements at trial but

claims the errors are preserved for our review by his motion in limine.

Alternatively, he requests palpable error review under RCr2 10.26. “Motions in

limine can preserve issues for appellate review, provided they are sufficiently

detailed about what the moving party intends to exclude.” Montgomery v.

Commonwealth, 505 S.W.3d 274, 280 (Ky. App. 2016). “[F]or a motion in limine

to preserve an issue for appeal, it must bring the particular error argued on appeal

to the attention of the trial court ‘both as to the matter objected to and as to the

grounds of the objection.’” Jenkins v. Commonwealth, 607 S.W.3d 601, 612 (Ky.

2020) (citation omitted).

Here, Pitmon moved to exclude evidence of his past criminal charges

and convictions as unduly prejudicial, citing KRE 403. Of the challenged

statements, only two explicitly mention Pitmon’s prior conviction for fourth-

degree assault. Many statements only hint at a possible charge or conviction.

Others reference Pitmon’s violence towards women. Thus, we find some of

Pitmon’s challenges preserved and others unpreserved. We will address each

statement individually below.

Statement 1

2 Kentucky Rules of Criminal Procedure.

-3- Pitmon first challenges the prosecutor’s statement during opening

argument that in June 2023 Pitmon was living with Savannah Lester (the mother of

one of his children) and he “found out that Savannah had another relationship . . .

[and] Mr. Pitmon was arrested, and he was jailed in the Fayette County

Correctional Center.” Arguably, this statement would qualify as identifying

Pitmon’s prior charge, so we find the alleged error preserved for review. However,

we find no error in the prosecutor’s comment during opening argument. Opening

and closing arguments are simply that—arguments. They are not evidence.

Newcomb v. Commonwealth, 410 S.W.3d 63, 88 (Ky. 2013) (citation omitted).

The court told the jury that opening statements were not evidence and the only

evidence to be considered was testimony from the witness stand. Furthermore, the

statement only hinted at a possible charge, and that was in passing.

Statement 2

Pitmon next challenges the prosecutor’s statement, also during

opening argument, that Doolin and Pitmon started fighting because “it was a

violation of his bond condition to go see Savannah Lester and it could have cost

her the money that she posted for the bond.” Again, this challenge is arguably

preserved. But as above, we find no error. Again, this statement was not evidence.

It also did not identify Pitmon’s charge. It only revealed that Pitmon could have

no contact with Savannah Lester. Further, Pitmon did not object to (and has not

-4- contested on appeal) a similar statement by Doolin that she “had the paperwork

from the jail that [Pitmon] was not supposed to have any contact with [Savannah

Lester].”

Statement 3

The next alleged violation comes from Doolin’s direct examination:

Commonwealth: Well, was there an issue with what [Pitmon] discovered on Savannah Lester’s phone?

Doolin: Yes.

Commonwealth: All right. Tell the jury about that.

Doolin: He was using her old phone, and he, I guess she didn’t re-clear it all out, and he went through it and saw pictures of him or her and this guy Jalen.

Commonwealth: Another man.

Commonwealth: Okay.

Doolin: And that is why he— . Commonwealth: Ultimately, after the blow-up of that, he ended up in jail.

Commonwealth: And you said that he got his new phone June 5th, and this all occurred, and he was arrested late on the night of June 5th. Is that right?

-5- We find Pitmon’s challenge to this statement preserved by his motion

in limine. This statement gets a little closer to violating the court’s pretrial ruling,

even if it does not explicitly identify Pitmon’s prior charge and conviction for

fourth-degree assault. Assuming the statement was admitted in error, we find the

error harmless. An error is harmless “if the reviewing court can say with fair

assurance that the judgment was not substantially swayed by the error.” Winstead

v. Commonwealth, 283 S.W.3d 678, 689 (Ky. 2009) (citation omitted). “The

inquiry is not simply whether there was enough [evidence] to support the result,

apart from the phase affected by the error. It is rather, even so, whether the error

itself had substantial influence. If so, or if one is left in grave doubt, the conviction

cannot stand.” Id. (internal quotation marks and citation omitted).

Doolin testified in graphic detail to Pitmon’s assault, specifically his

strangulation of her. She said that Pitmon grabbed her by the throat and took her to

the ground. With both hands around her throat, he began squeezing tighter and

shaking her. Everything started to go black, and she saw white spots. She thought

she was going to die.

Her testimony was supported by that of her friend, Rochelle Johnson,

who took photos of her injuries and testified that Doolin had bruises on her neck

shaped like fingermarks. Pictures of these injuries were introduced into evidence.

Pitmon admitted that these injuries were not present before June 8 (the day of the

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Related

Brewer v. Commonwealth
206 S.W.3d 343 (Kentucky Supreme Court, 2006)
Matheney v. Commonwealth
191 S.W.3d 599 (Kentucky Supreme Court, 2006)
Barnes v. Commonwealth
91 S.W.3d 564 (Kentucky Supreme Court, 2002)
Morgan v. Scott
291 S.W.3d 622 (Kentucky Supreme Court, 2009)
Allen v. Commonwealth
286 S.W.3d 221 (Kentucky Supreme Court, 2009)
Winstead v. Commonwealth
283 S.W.3d 678 (Kentucky Supreme Court, 2009)
Brown v. Commonwealth
313 S.W.3d 577 (Kentucky Supreme Court, 2010)
Mayo v. Commonwealth
322 S.W.3d 41 (Kentucky Supreme Court, 2010)
Alford v. Commonwealth
338 S.W.3d 240 (Kentucky Supreme Court, 2011)
Smith v. Commonwealth
920 S.W.2d 514 (Kentucky Supreme Court, 1996)
Stringer v. Commonwealth
956 S.W.2d 883 (Kentucky Supreme Court, 1997)
Belt v. Commonwealth
2 S.W.3d 790 (Court of Appeals of Kentucky, 1999)
Chavies v. Commonwealth
374 S.W.3d 313 (Kentucky Supreme Court, 2012)
Kerr v. Commonwealth
400 S.W.3d 250 (Kentucky Supreme Court, 2013)
Newcomb v. Commonwealth
410 S.W.3d 63 (Kentucky Supreme Court, 2013)
Montgomery v. Commonwealth
505 S.W.3d 274 (Court of Appeals of Kentucky, 2016)

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