Eric E Taylor v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedSeptember 12, 2025
Docket2024-CA-0823
StatusPublished

This text of Eric E Taylor v. Commonwealth of Kentucky (Eric E Taylor 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
Eric E Taylor v. Commonwealth of Kentucky, (Ky. Ct. App. 2025).

Opinion

RENDERED: SEPTEMBER 12, 2025; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-0823-MR

ERIC E. TAYLOR APPELLANT

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE JESSICA E. GREEN, JUDGE ACTION NO. 23-CR-000173

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, CETRULO, AND ECKERLE, JUDGES.

ECKERLE, JUDGE: Appellant, Eric E. Taylor (“Taylor”), challenges a jury

verdict and judgment of the Jefferson Circuit Court convicting him of complicity

to assault in the first degree. He argues that the Trial Court improperly allowed a

police officer to narrate a surveillance video depicting the assault, and that he was

entitled to a directed verdict on the charge. After careful consideration, we

conclude that the officer’s testimony was not improper, and there was substantial evidence for the jury to find Taylor guilty of the crime of complicity to first-degree

assault. Hence, we affirm.

I. Factual and Procedural History

On the evening of August 3, 2022, three men assaulted John DeFrank

(“DeFrank”) in the parking lot of a Circle K convenience store, located at 219

West Florence Avenue in Louisville, Jefferson County, Kentucky. They robbed

DeFrank and shot him several times, hitting his head and chest. DeFrank suffered

severe injuries from the assault, including the loss of his left eye and part of his

brain.

Louisville Metro Police Department (“LMPD”) responded to the

scene and tended to DeFrank’s extensive injuries. They found Taylor’s cell phone

in the parking lot. They then found Taylor himself slumped on a bench at a bus

stop a few blocks away with gunshot wounds to his torso and leg. The police

found another cell phone at the scene but were unable to identify its owner or the

other two assailants.

LMPD cameras, located across the street from the store, captured

images of the incident. However, the video recording lacked audio, and it was not

of sufficient quality to confirm the identity of the victim or the assailants.

On January 24, 2023, a Jefferson County grand jury indicted Taylor

for assault in the first degree by complicity and robbery in the first degree by

-2- complicity of DeFrank. The matter proceeded to a three-day jury trial, beginning

March 19, 2024.

The Commonwealth called DeFrank as a witness at trial. He had

required extensive hospitalizations and multiple surgeries, and he suffered

permanent impairment. Due to his severe injuries, DeFrank could not remember

what had happened the night of the alleged crimes. DeFrank testified at trial that

his normal routine when he left home was to bring with him his wallet,

pocketknife, phone, cigarettes, lighter, and two pistols – a Sig Sauer 9 mm and a

Ruger LCP .380. These guns were stolen from DeFrank during the assault and

never recovered.

On the second day of trial, the Commonwealth called Detective

Abigail Christman (“Christman”) to testify about her investigation and to provide

context for the videotaped footage. Taylor’s counsel objected, arguing, inter alia,

that Christman’s testimony violated Kentucky Rules of Evidence (“KRE”) 602 and

KRE 701 by providing narrative testimony concerning the video recording about

which she lacked personal knowledge. The Trial Court overruled Taylor’s

objection in general, but it cautioned that it may sustain future objections to

specific portions of Christman’s testimony.

The Commonwealth then played the silent video footage for the jury

without any comment from Christman. It showed DeFrank sitting on a curb in

-3- front of the store with a man, who was wearing a red shirt and who was later

identified as Taylor. Two other men approached from behind. Taylor then

punched DeFrank, and the two other men immediately joined in the assault. They

robbed DeFrank and took his guns. One of the assailants shot DeFrank several

times. Taylor also sustained gunshot injuries to his torso and leg during the

assault.

After the video played, the Commonwealth asked Christman about her

observations on the night of the assault, both at the convenience store and at the

bus stop where Taylor was found. She commented that despite Taylor’s injuries,

he managed to ride his bicycle from the scene. LMPD would later find him a short

distance away where he had collapsed on the bench. The other two men escaped

into the night, and they have still not been identified.

The Commonwealth also asked Christman about how she used the

video in her investigation. Christman noted that Taylor was found wearing the

same type of red shirt as the initial assailant in the video.

On re-direct, the Commonwealth played the video again. During the

first 26 seconds of uninterrupted playback, the footage showed Taylor and

DeFrank standing next to each other. The Commonwealth paused playback and

asked Christman:

Commonwealth: At this point in the video, do you observe any altercation between the person you identified

-4- as the defendant and the person you identified as the victim?

Christman: No, Ma’am.

Video Record (“VR”) 3/20/24, at 11:55:00-11:55:26.

During the next 38 seconds of uninterrupted playback, the footage

showed two men approach DeFrank from behind, but in full view of Taylor. As

soon as the two men came near, Taylor punched DeFrank. While playback

continued the Commonwealth asked Christman:

Commonwealth: Is what we just observed what you believe to be the first strike?

Christman: Yes, Ma’am.

Commonwealth: How close are the other two unidentified individuals when that punch was thrown?

Christman: Very close.

Commonwealth: And how quickly did they, based on what you’re observing in the video, join that altercation?

Christman: Within seconds.

Id. at 11:55:26-11:56:23.

As the video played, Christman identified Taylor’s actions during the

assault, including being shot and ending with his escape on a bicycle. Christman

further testified that Taylor’s cell phone was found at the scene of the assault.

Although Christman could not identify the two other people involved with

-5- certainty, she further testified that Taylor had sent a text message to a woman

whose name was also on another cell phone that she believed belonged to one of

the other assailants. Christman did not opine that Taylor had shot DeFrank but

concluded that Taylor had acted in concert with the other men to commit the

Taylor testified in his own defense but admitted that he was present at

the scene and punched DeFrank as the other two men were approaching. Taylor

testified that he started a conversation with DeFrank and requested a cigarette.

Taylor testified that DeFrank appeared increasingly agitated as the conversation

continued. Taylor stated that he became concerned when he saw that DeFrank was

armed and then saw the other two men approach. Taylor, who had been shot

before by someone else, testified that he believed that DeFrank was going to shoot

him. After the other two men attacked DeFrank, Taylor heard gunshots and

realized that he had also been struck. He believed that DeFrank shot him. He then

fled the scene on his bicycle.

The defense had moved for a directed verdict at the close of the

Commonwealth’s case-in-chief, and it renewed the motion at the close of all of the

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