Donte Little v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedAugust 16, 2018
Docket2017-SC-0112
StatusUnpublished

This text of Donte Little v. Commonwealth of Kentucky (Donte Little v. Commonwealth of Kentucky) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Donte Little v. Commonwealth of Kentucky, (Ky. 2018).

Opinion

RENDERED: AUGUST 16, 2018 TO BE PUBLISHED

of

2017-SC-000112-MR

DONTE LITTLE APPELLANT

ON APPEAL FROM KENTON CIRCUIT COURT V. HONORABLE KATHLEEN S. LAPE, JUDGE NO. 15-CR-00742

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION OF THE COURT BY JUSTICE VANMETER

AFFIRMING

Donte Little appeals as a matter of right^ from the Kenton Circuit Court’s

judgment convicting him of two counts of trafficking in a controlled substance

in the first degree (less than two grams of heroin), two counts of trafficking in a

controlled substance in the first degree (more than two grams of heroin), one

count of complicity to trafficking in a controlled substance in the first degree

(more than two grams of heroin), and sentencing him to 20 years’

imprisonment. For the following reasons, we affirm.

I. BACKGROUND.

Ky. Const. § 115; Ky. Const. § 10. The undercover narcotics investigation in this case was conducted by

Detective David Hoyle and confidential informant D.N., who was working for

the Covington Police Department making undercover heroin buys to “work off’

her prior drug charges. D.N. was familiar with Little because she had bought

heroin from him previously. With respect to this case, D.N. made a total of five

undercover buys from Little, each transaction being recorded by a concealed

audio and video recording equipment with which D.N. was outfitted, and a

transmitter that allowed police to monitor the transaction in real time. After a

three-day trial, the jury convicted Little on all five counts for which he had

been indicted. This appeal followed.

IL ANALYSIS.

a. Commonwealth's KRE 508 Disclosure of Confidential Informant’s Identity.

Little asserts that the Commonwealth violated the notice requirement set

forth in KRE^ 508 by waiting until 40 hours prior to trial to disclose D.N.’s

identity, in violation of the trial court’s order directing the Commonwealth to

disclose the informant’s identity 48 hours before trial. Little had filed a pre­

trial motion asking the court to direct the Commonwealth to provide him with

the name of the informant at least 30 days prior to trial, and for transcripts of

the informant’s prior testimony from any case in which she had testified in

Kenton County in the past three years. The court denied his motion, but did

order the Commonwealth to disclose the informant’s name to Little 48 hours

2 Kentucky Rules of Evidence. prior to trial, which the Commonwealth stated was its typical practice. The

court further found that since Little had not been declared indigent, he could

obtain a copy of the recording of any testimony of public record in Kenton

County through the Clerk’s office.

On the morning of trial, December 14, 2016, Little moved to exclude the

informant’s testimony due to the late disclosure. The Commonwealth informed

the court that it had attempted to contact Little’s counsel numerous times by

phone during business hours on December 12, 2016 to provide the informant’s

name and, when unable to reach counsel by phone, emailed him the name of

the informant around 4:20 p.m. that afternoon, approximately eight hours later

than the 48-hour disclosure time ordered by the court. Little’s counsel

conceded that he did not expect the Commonwealth to leave the informant’s

name on a voicemail, but questioned why the Commonwealth waited until 4:20

p.m. to email him when it could have done so earlier. The trial court denied

Little’s motion to exclude. Little now argues on appeal that he was prejudiced

as a result, and deprived of his due process right to prepare a defense, since

the eight-hour delay reduced the time he had to go to the Kenton County

Clerk’s office and search through three years of drug trial cases to find those in

which D.N. had been a confidential informant, and watch the pre-trial and trial

CDs. Little also challenges the trial court’s imposition of the 48-hour

disclosure period to begin with, instead of the 30-day disclosure period he

requested. This Court reviews a trial court’s evidentiary rulings for an abuse of

discretion. Dunlap v. Commonwealth, 435 S.W.3d 537, 553 (Ky. 2013).

“The test for abuse of discretion is whether the trial [court’s] decision was

arbitrary, unreasonable, unfair, or unsupported by sound legal principles.” Id.

at 554 (internal quotations and citation omitted).

KRE 508 creates a privilege by which the Commonwealth may properly

refuse to disclose the identity of an informant, and KRE 508(c) delineates

exceptions to the privilege. One of those exceptions is when the informant is a

witness for the state. Here, since D.N. was a witness for the Commonwealth,

disclosure of her identity was required. KRE 508(c)(1). Notably, KRE 508

places no time constraint on the disclosure. This Court has held, “KRE 508

reflects the decision of the United States Supreme Court in Roviaro v. United

States, 353 U.S. 53, 77 S. Ct. 623, 1 L. Ed. 2d 639 (1957), which indicates that

a proper balance regarding nondisclosure must depend on the particular

circumstances of each case, taking into consideration the crimes charged, the

possible defenses, the possible significance of the informer's testimony and

other relevant factors.” Taylor v. Commonwealth, 987 S.W.2d 302, 304 (Ky.

1998). In Roviaro, the Court eschewed rigid rules dictating disclosure,

explaining “[t]he problem is one that calls for balancing the public interest in

protecting the flow of information against the individual’s right to prepare his

defense.” 353 U.S. at 62, 77 S. Ct. at 628-29.

In this case, withholding the identity of a material witness until less than

two days before a trial was unacceptable. Competent lawyering places demands upon trial attorneys in the days immediately preceding a trial; given

the final tasks of trial preparation that can only be done immediately before the

trial, a lawyer has no business spending hours researching the background of

a material witness to assure effective cross-examination. Forcing a criminal

defense lawyer into that position was an abuse of a trial court’s discretion.

This Court cannot imagine a scenario in which a plaintiff in a slip-and-fall or

car wreck case would be allowed to withhold the identity of a material witness

until the second day before trial: criminal cases should be no different.

Further, if concern for the safety of the material witness was a factor, the late

disclosure of critical information is totally ineffective. The guilty drug dealer

generally knows his customers and knows who the informant is soon after

charges are filed. Only the innocent and falsely-accused defendants are

prejudiced by the late disclosure.

That said. Little is unable to articulate any specific prejudice from the

late disclosure, and although some measure of prejudice can surely be

presumed, this Court does not regard the lack of timely information in this

instance as substantial enough to compel a new trial. The Commonwealth

provided Little with all the audio and video recordings of the controlled buys

with D.N. eleven months before trial. With respect to D.N.’s identity, the record

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Related

Roviaro v. United States
353 U.S. 53 (Supreme Court, 1957)
United States v. Enrique M. Salinas
654 F.2d 319 (Fifth Circuit, 1981)
United States v. John R. Adamson, III
700 F.2d 953 (Fifth Circuit, 1983)
Taylor v. Commonwealth
987 S.W.2d 302 (Kentucky Supreme Court, 1998)
Seay v. Commonwealth
609 S.W.2d 128 (Kentucky Supreme Court, 1980)
Cantrell v. Commonwealth
288 S.W.3d 291 (Kentucky Supreme Court, 2009)
Harp v. Commonwealth
266 S.W.3d 813 (Kentucky Supreme Court, 2008)
Pollini v. Commonwealth
172 S.W.3d 418 (Kentucky Supreme Court, 2005)
Potts v. Commonwealth
172 S.W.3d 345 (Kentucky Supreme Court, 2005)
Love v. Commonwealth
55 S.W.3d 816 (Kentucky Supreme Court, 2001)
Dunlap v. Commonwealth
435 S.W.3d 537 (Kentucky Supreme Court, 2013)
Crabtree v. Commonwealth
455 S.W.3d 390 (Kentucky Supreme Court, 2014)
Lewis v. Commonwealth
475 S.W.3d 26 (Kentucky Supreme Court, 2015)

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