Eric Straub v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedNovember 17, 2022
Docket2022 CA 000056
StatusUnknown

This text of Eric Straub v. Commonwealth of Kentucky (Eric Straub 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 Straub v. Commonwealth of Kentucky, (Ky. Ct. App. 2022).

Opinion

RENDERED: NOVEMBER 18, 2022; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2022-CA-0056-MR

ERIC STRAUB APPELLANT

APPEAL FROM CAMPBELL CIRCUIT COURT v. HONORABLE DANIEL J. ZALLA, JUDGE ACTION NO. 20-CR-00342

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION VACATING AND REMANDING

** ** ** ** **

BEFORE: DIXON, GOODWINE, AND L. THOMPSON, JUDGES.

THOMPSON, L., JUDGE: Eric Straub appeals from his conviction of possession

of a firearm by a convicted felon and for violating a domestic violence order.

Appellant argues on appeal that he was not a felon when charged with possessing

the firearm and should not have been convicted of that charge. We believe that

Appellant has raised enough questions about the validity of his conviction that

additional proceedings are required; therefore, we vacate Appellant’s conviction

and remand. FACTS AND PROCEDURAL HISTORY

On May 26, 2015, Appellant pleaded guilty to first-degree possession

of a controlled substance,1 a Class D felony, and entered into a felony diversion

program pursuant to KRS 533.250. The diversion program was to last three years.

On July 8, 2020, Appellant was arrested and charged with violating a

domestic violence order2 and being a convicted felon in possession of a handgun.3

The felony conviction used for the handgun charge was from his possession of a

controlled substance charge in 2015. Appellant ultimately accepted a plea

agreement. In exchange for pleading guilty, the possession of a handgun by a

convicted felon would be amended to a charge of possession of a firearm by a

convicted felon.4 Nothing would change regarding the violation of the domestic

violence order. At Appellant’s sentencing hearing, defense counsel discussed the

prior diversion arrangement with the court, but believed because Appellant did not

move to have his prior conviction dismissed after completing his diversion term, he

was still considered a convicted felon. Appellant was sentenced in accordance

with the plea agreement. This appeal followed.

1 Kentucky Revised Statutes (KRS) 218A.1415. 2 KRS 403.763. 3 KRS 527.040. 4 KRS 527.040(2)(a) states that the possession of a firearm by a convicted felon is a Class D felony unless the firearm is a handgun, in which case it is a Class C felony.

-2- ANALYSIS

On appeal, Appellant argues that because he completed his diversion

program for the prior felony, he was not a convicted felon when he was charged

with possession of the firearm; therefore, his conviction and sentence for

possession of a firearm by a convicted felon is illegal and contrary to statute. The

Commonwealth argues that Appellant waived all issues on appeal when he made

an unconditional guilty plea.

While an unconditional guilty plea waives the right to appeal many constitutional protections as well as the right to appeal a finding of guilt on the sufficiency of the evidence, there are some remaining issues that can be raised in an appeal. These include competency to plead guilty; whether the plea complied with the requirements of Boykin v. Alabama, 395 U.S. 238, 244, 89 S. Ct. 1709, 23 L. Ed. 2d 274 (1969); subject matter jurisdiction and failure to charge a public offense; and sentencing issues. In Roe v. Flores-Ortega, the United States Supreme Court recognized that “a guilty plea reduces the scope of potentially appealable issues.” 528 U.S. 470, 480, 120 S. Ct. 1029, 145 L. Ed. 2d 985 (2000) (emphasis added).

Windsor v. Commonwealth, 250 S.W.3d 306, 307 (Ky. 2008) (footnotes and

citations omitted). Such sentencing issues that can still be raised on appeal are that

the sentence is illegal and that the plea agreement violated the law. McClanahan v.

Commonwealth, 308 S.W.3d 694, 701 (Ky. 2010).

-3- Here, Appellant entered into a diversion program pursuant to KRS

533.250. KRS 533.250(1)(f) requires a person to enter a guilty plea as part of the

diversion program. KRS 533.256 states in relevant part:

(1) If the defendant fails to complete the provisions of the pretrial diversion agreement within the time specified, or is not making satisfactory progress toward the completion of the provisions of the agreement, the Division of Probation and Parole, the victim, or a peace officer may inform the attorney for the Commonwealth of the alleged violation or noncompliance, and the attorney for the Commonwealth may apply to the court for a hearing to determine whether or not the pretrial diversion agreement should be voided and the court should proceed on the defendant’s plea of guilty in accordance with the law.

KRS 533.258 states:

(1) If the defendant successfully completes the provisions of the pretrial diversion agreement, the charges against the defendant shall be listed as “dismissed-diverted” and shall not constitute a criminal conviction.

(2) The defendant shall not be required to list this disposition on any application for employment, licensure, or otherwise unless required to do so by federal law.

(3) Pretrial diversion records shall not be introduced as evidence in any court in a civil, criminal, or other matter without the consent of the defendant.

In the case at hand, Appellant argues that his diversion ended in 2018;

therefore, his previous felony charge should have been dismissed and he should not

-4- have been considered a convicted felon for purposes of the convicted felon in

possession of a handgun/firearm charge.

In Thomas v. Commonwealth, 95 S.W.3d 828 (Ky. 2003), the

Kentucky Supreme Court held that when a defendant pleads guilty and enters into

a felony diversion program, as occurred here with Appellant, that defendant is

considered a convicted felon until the diversion program is completed. Id. at 829-

30. In addition, a defendant is entitled to have his conviction dismissed, pursuant

to the diversion agreement, if the defendant has completed the diversion, the

diversion period has expired, and the Commonwealth has not moved to void or

terminate the diversion agreement for noncompliance before the diversion period

expired. Ballard v. Commonwealth, 320 S.W.3d 69, 74 (Ky. 2010).

Here, the Commonwealth has argued that Appellant did not complete

the diversion program; however, it does not explain how Appellant failed to

complete the program or what else Appellant was required to do. In addition, the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Boykin v. Alabama
395 U.S. 238 (Supreme Court, 1969)
Roe v. Flores-Ortega
528 U.S. 470 (Supreme Court, 2000)
McClanahan v. Commonwealth
308 S.W.3d 694 (Kentucky Supreme Court, 2010)
Tucker v. Commonwealth
295 S.W.3d 455 (Court of Appeals of Kentucky, 2009)
Ballard v. Commonwealth
320 S.W.3d 69 (Kentucky Supreme Court, 2010)
Thomas v. Commonwealth
95 S.W.3d 828 (Kentucky Supreme Court, 2003)
Windsor v. Commonwealth
250 S.W.3d 306 (Kentucky Supreme Court, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
Eric Straub v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/eric-straub-v-commonwealth-of-kentucky-kyctapp-2022.