Farand Skinner v. Commonwealth of Kentucky

Court of Appeals of Kentucky·Decided September 4, 2026·No. 2024-CA-1469·Unpublished

Opinion

RENDERED: SEPTEMBER 4, 2026; 10:00 A.M.

NOT TO BE PUBLISHED

Commonwealth of Kentucky

Court of Appeals

NO. 2024-CA-1469-MR

FARAND SKINNER APPELLANT

APPEAL FROM BRECKINRIDGE CIRCUIT COURT v. HONORABLE KENNETH HAROLD GOFF, II, JUDGE ACTION NO. 18-CR-00012

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION

AFFIRMING

** ** ** ** **

BEFORE: KAREM, MCNEILL, AND TAYLOR, JUDGES. TAYLOR, JUDGE: Farand Skinner appeals from the November 13, 2024, Order of the Breckinridge Circuit Court which denied his Kentucky Rules of Criminal Procedure (RCr) 11.42 motion for post-conviction relief. We affirm.

BACKGROUND

In 2019, Skinner was convicted by a jury for murder and sentenced to twenty-three years in prison in accordance with the jury verdict. He appealed directly to the Kentucky Supreme Court which affirmed his conviction in an unpublished decision. Skinner v Commonwealth, No. 2019-SC-0589-MR, 2021 WL 732963 (Ky. Feb. 18, 2021) (unpublished). That decision sets forth the underlying facts as follows:

Farand Skinner, the victim, Paul Harrison, and the sole eyewitness, Timothy1 Day, were roommates. They had been friends for years, and Skinner allowed the other two men to stay at his home. According to Day, Skinner and Harrison frequently argued, and Skinner made Harrison move out.

Harrison’s moving out ignited an exchange of contentious text messages between Harrison and Skinner about when Harrison could retrieve his belongings from Skinner’s house. Harrison texted that he was “going to take things to the extreme,” “get physical,” “knock his teeth down his throat” and that Skinner was going to have to “end up killing him,” he was “ready to die,” and “[I’m] bring aload [sic] of my shit out[,] shoot me[,] or do whatever[,] but I’m going to get my shit.”

Day accompanied Harrison to Skinner’s house to help him move his belongings. How the events unfolded upon their arrival is disputed. Skinner’s residence was equipped with a home-surveillance camera, and footage from that camera—despite low-quality video and no audio—shows Skinner emerging from the house as Harrison and Day arrive, Harrison exiting the vehicle and

1 The eyewitness’ name was Theodore “Teddy” Day.

approaching Skinner, Skinner shooting Harrison once, and Harrison collapsing briefly before retreating to the vehicle. Once Harrison was inside the vehicle, Skinner shot at least twice into the vehicle, killing Harrison.

Skinner’s defense at trial was self-defense. He claimed that Harrison got out of the car, threatened to kill him, approached him aggressively with a knife, and in a manner that made Skinner fear for his life.

Day did not testify that Harrison threatened to kill Skinner. He could only testify that Harrison was angry and the two argued immediately upon arrival. But in Day’s initial interview with police, he indicated that Harrison may have threatened Skinner.

After the shooting, Skinner reentered the house and called 911. He identified himself, his address, and reported that he had shot Harrison. The grand jury indicted Skinner for Harrison’s murder.

Skinner v. Commonwealth, 2021 WL 732963, at *1.

Following the direct appeal, on January 27, 2023, Skinner, acting pro se, timely filed a motion pursuant to RCr 11.42 for post-judgment relief asserting ineffective assistance of counsel. The Department of Public Advocacy (DPA) was appointed to review and supplement the motion. The parties entered an Agreed Order on May 22, 2023, giving defense counsel ninety days to review the record and supplement the motion. Record at 672. Thereafter, an attorney from DPA filed a motion to withdraw pursuant to Kentucky Revised Statutes (KRS) 31.110(2)(c), and allow Skinner to pursue his claims pro se. The court granted the motion and gave Skinner additional time to hire counsel and file a supplemental

brief in support of his motion. On July 23, 2024, newly retained private counsel filed a supplemental brief in support of Skinner’s RCr 11.42 motion, which primarily argued that the allegations raised by Skinner required an evidentiary hearing. Although the filing of the supplemental brief fell outside of the three-year time limit provided for in RCr 11.42(10) to file a motion, the trial court determined that the supplemental brief would be considered since the original motion was timely and the supplemental brief was “based on multiple continuances agreed to by the Commonwealth[.]” November 13, 2024, Order, Record at 734. Additionally, the court denied the RCr 11.42 motion in the November 13, 2024, Order. This appeal followed.

STANDARD OF REVIEW

The Kentucky Supreme Court has set forth the following standard for review of RCr 11.42 ineffective assistance of counsel claims:

We evaluate ineffective assistance of counsel claims under the standard set forth in Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984), adopted by this Court in Gall v. Commonwealth, 702 S.W.2d 37 (Ky. 1985). Under the Strickland framework, an appellant must first show that counsel’s performance was deficient. Strickland, 466 U.S. at 687, 104 S. Ct.

2052. A “deficient performance” contains errors “so serious that counsel was not functioning as the ‘counsel’

guaranteed the defendant by the Sixth Amendment.” Id.

Second, the appellant must show that counsel’s deficient performance prejudiced his defense at trial. Id. “This requires showing that counsel’s errors were so serious as to deprive the defendant of a fair trial, a trial whose result

is reliable.” Id. An appellant must satisfy both elements of the Strickland test in order to merit relief. Id.

When faced with an ineffective assistance of counsel claim in an RCr 11.42 appeal, a reviewing court first presumes that counsel’s performance was reasonable. Commonwealth v. Bussell, 226 S.W.3d 96, 103 (Ky. 2007) (quoting Haight v. Commonwealth, 41 S.W.3d 436, 442 (Ky. 2001), overruled on other grounds by Leonard v. Commonwealth, 279 S.W.3d 151 (Ky.

2009)). We must analyze counsel’s overall performance and the totality of circumstances therein in order to determine if the challenged conduct can overcome the strong presumption that counsel’s performance was reasonable. Haight, 41 S.W.3d at 441-42. In addition, the trial court’s factual findings and determinations of witness credibility are granted deference by the reviewing court. Id. Finally, we apply the de novo standard when reviewing counsel’s performance under Strickland. Bussell, 226 S.W.3d at 100.

Commonwealth v. McGorman, 489 S.W.3d 731, 736 (Ky. 2016).

An evidentiary hearing is required if there is a material issue of fact that cannot be conclusively proved or disproved by an examination of the record. Fraser v. Commonwealth, 59 S.W.3d 448, 452 (Ky. 2001); see also RCr 11.42(5). If an evidentiary hearing is not held, as here, our review is limited to “whether the motion on its face states grounds that are not conclusively refuted by the record and which, if true, would invalidate the conviction.” McGaha v. Commonwealth, 469 S.W.3d 841, 846 (Ky. App. 2015) (quoting Lewis v. Commonwealth, 411 S.W.2d 321, 322 (Ky. 1967)). Our review proceeds accordingly.

ANALYSIS

Skinner makes seven claims of ineffective assistance of trial counsel in this appeal: (1) counsel misadvised him as to what facts he could have testified to, which affected his decision not to testify, (2) counsel should have called Skinner’s doctor to testify about the effects of his recent stroke, (3) counsel should have sought DNA testing of drug paraphernalia allegedly belonging to the victim, (4) counsel should have called an expert witness to describe the effects of methamphetamine use by the victim, (5) counsel failed to fully review the video evidence, (6) counsel ineffectively cross-examined the eyewitness, and (7) counsel failed to object to false statements in the prosecution’s closing arguments. We will discuss each as follows.

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Farand Skinner v. Commonwealth of Kentucky, (Ky. Ct. App. 2026).

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Related

Strickland v. Washington
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Fraser v. Commonwealth
59 S.W.3d 448 (Kentucky Supreme Court, 2001)
Lewis v. Commonwealth
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Gall v. Commonwealth
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Bowling v. Commonwealth
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