Erin Helm v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedAugust 23, 2023
Docket2022 CA 001232
StatusUnknown

This text of Erin Helm v. Commonwealth of Kentucky (Erin Helm 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
Erin Helm v. Commonwealth of Kentucky, (Ky. Ct. App. 2023).

Opinion

RENDERED: AUGUST 25, 2023; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2022-CA-1232-MR

ERIN HELM APPELLANT

APPEAL FROM HARDIN CIRCUIT COURT v. HONORABLE KELLY MARK EASTON, JUDGE ACTION NO. 13-CR-00581

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, JONES, AND TAYLOR, JUDGES.

JONES, JUDGE: Erin Helm appeals from the Hardin Circuit Court’s order

sentencing her to an alternate term of twelve months’ incarceration after she

absconded from pretrial diversion. Helm now contends the trial court did not have

authority to modify her diversion because the diversionary period had expired.

After considering the facts and the law, we affirm the judgment of the trial court. I. BACKGROUND

On October 8, 2013, the Hardin County Commonwealth’s Attorney,

proceeding by information, charged Helm for nine counts of second-degree

criminal possession of a forged instrument.1 Helm had forged and cashed checks

belonging to Betty Hawk, with the total amount drawn on the forged checks

amounting to $221.46. Helm entered a negotiated guilty plea on the counts in the

indictment. Upon the Commonwealth’s recommendation, the trial court thereafter

sentenced Helm to a term of two years’ imprisonment, diverted for five years

under the state’s pretrial diversion program outlined in KRS 533.250. As part of

her conditions for pretrial diversion, Helm agreed to pay restitution of $221.46.

She also acknowledged that her diversion period would be supervised by the

Division of Probation and Parole. Helm agreed to the terms for diversion in both

her signed agreement with the Commonwealth and during her plea colloquy with

the trial court on October 15, 2013. If Helm completed the five-year diversionary

period successfully, her charges would be dismissed-diverted and would not

constitute a criminal conviction pursuant to KRS 533.258.

Unfortunately, within two weeks, the trial court received an affidavit

from Helm’s probation officer indicating that she had absconded from supervision.

The trial court ordered a bench warrant for Helm’s arrest on October 31, 2013, but

1 Kentucky Revised Statute (KRS) 516.060, a Class D felony.

-2- Helm was not arrested until April 9, 2015. The Commonwealth moved to void

Helm’s pretrial diversion based on the violation. In a hearing on the motion, Helm

acknowledged her wrongdoing. After ordering an evaluation, and in lieu of

revocation, the trial court added a condition that Helm must complete mental

health court to successfully complete her diversion.

A little over one year later, on June 6, 2016, Helm reported to her

probation officer and listed her address as 105 Blackburn Road, Rineyville,

Kentucky. However, when the officer contacted the resident of 105 Blackburn

Road, the resident indicated that Helm had not lived there for approximately ten

days. This meant that Helm had filed a false report of her current address on June

6, and her whereabouts were once again unknown. Furthermore, the program

supervisor at mental health court filed an affidavit indicating that Helm had

absconded from the program on June 8, 2016. The trial court thereafter terminated

Helm from the mental health court program and issued another bench warrant for

her arrest. The bench warrant, entered on June 14, 2016, would not be executed

until August 29, 2022, when Helm turned herself in. The Commonwealth moved

to void Helm’s diversion on September 6, 2022, the same day Helm was brought

before the trial court on the warrant. The trial court explained to Helm that she had

violated her diversion and, with her permission, the diversion would be extended

-3- for another week so she and her lawyer could prepare for a hearing on the

violation. Helm agreed.

On September 13, 2022, the trial court heard testimony from a

probation and parole officer outlining Helm’s history of noncompliance with the

terms of her diversion. The officer finished by pointing out that Helm had

effectively disappeared for six years, and probation and parole had no idea what

she had been doing in the meantime. Helm testified in her defense, stating how

mental health court had given her the tools to maintain sobriety, but she

acknowledged that absconding was a poor decision. She also stated that she turned

herself in because she wanted to do the right thing. Helm then testified that she

just made a payment on her restitution. The trial court, unimpressed, pointed out

that this payment, over nine years later, was the first time she had made any

payments toward her restitution. In response to her testimony that she was now

maintaining sobriety, the trial court also pointed out that she tested positive for

marijuana when she was arrested. Helm then admitted she had smoked marijuana.

In the hearing’s final arguments, Helm’s counsel argued that the trial

court no longer had jurisdiction over the case because the diversionary period had

expired, and the Commonwealth had not filed a timely motion to void diversion.

As a result, Helm’s counsel asserted that the trial court had no option other than to

order the charges dismissed-diverted. The Commonwealth, citing the number and

-4- length of the times Helm had absconded, argued that Helm had shown no respect

for the trial court. The Commonwealth then asked the trial court to impose an

alternate sentence. The trial court agreed and ultimately declined to void Helm’s

diversion, instead ordering her to serve twelve months as an alternate sentence.

The trial court followed up on its order with a written memorandum explaining its

ruling. This appeal followed.

II. ANALYSIS

Pretrial diversion is conducted under the auspices of RCr2 8.04 and

KRS 533.250 et seq. A trial court’s decisions regarding pretrial diversion are

reviewed using the same criteria as decisions to revoke probation. Richardson v.

Commonwealth, 494 S.W.3d 495, 498 (Ky. App. 2015). “A decision to revoke

probation is reviewed for an abuse of discretion.” Commonwealth v. Andrews, 448

S.W.3d 773, 780 (Ky. 2014) (citation omitted). “Under our abuse of discretion

standard of review, we will disturb a ruling only upon finding that ‘the trial judge’s

decision was arbitrary, unreasonable, unfair, or unsupported by sound legal

principles.’” Id. (quoting Commonwealth v. English, 993 S.W.2d 941, 945 (Ky.

1999)).

In her sole argument on appeal, Helm contends the trial court

incorrectly ruled that it had the authority to impose a sanction after the

2 Kentucky Rule of Criminal Procedure.

-5- diversionary period had expired. Helm asserts “[t]he only action the trial court was

authorized to take was to enter a final disposition of the case as diverted-

dismissed.” (Appellant’s Brief at 6.) For support, she cites as authority Ballard v.

Commonwealth,

Related

Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
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)
Shawnee Telecom Resources, Inc. v. Brown
354 S.W.3d 542 (Kentucky Supreme Court, 2011)
Commonwealth v. Wright
415 S.W.3d 606 (Kentucky Supreme Court, 2013)
Whitcomb v. Commonwealth
424 S.W.3d 417 (Kentucky Supreme Court, 2014)
Commonwealth v. Andrews
448 S.W.3d 773 (Kentucky Supreme Court, 2014)
Richardson v. Commonwealth
494 S.W.3d 495 (Court of Appeals of Kentucky, 2015)
Commonwealth v. Tapp
497 S.W.3d 239 (Kentucky Supreme Court, 2016)

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Erin Helm v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/erin-helm-v-commonwealth-of-kentucky-kyctapp-2023.