James Anthony Gray v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedJune 12, 2024
Docket2021 SC 0492
StatusUnknown

This text of James Anthony Gray v. Commonwealth of Kentucky (James Anthony Gray 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
James Anthony Gray v. Commonwealth of Kentucky, (Ky. 2024).

Opinion

IMPORTANT NOTICE NOT TO BE PUBLISHED OPINION

THIS OPINION IS DESIGNATED “NOT TO BE PUBLISHED.” PURSUANT TO THE RULES OF CIVIL PROCEDURE PROMULGATED BY THE SUPREME COURT, RAP 40(D), THIS OPINION IS NOT TO BE PUBLISHED AND SHALL NOT BE CITED OR USED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE; HOWEVER, UNPUBLISHED KENTUCKY APPELLATE DECISIONS, RENDERED AFTER JANUARY 1, 2003, MAY BE CITED FOR CONSIDERATION BY THE COURT IF THERE IS NO PUBLISHED OPINION THAT WOULD ADEQUATELY ADDRESS THE ISSUE BEFORE THE COURT. OPINIONS CITED FOR CONSIDERATION BY THE COURT SHALL BE SET OUT AS AN UNPUBLISHED DECISION IN THE FILED DOCUMENT AND A COPY OF THE ENTIRE DECISION SHALL BE TENDERED ALONG WITH THE DOCUMENT TO THE COURT AND ALL PARTIES TO THE ACTION. NOT TO BE PUBLISHED

Supreme Court of Kentucky 2021-SC-0492-MR

JAMES ANTHONY GRAY APPELLANT

ON APPEAL FROM SCOTT CIRCUIT COURT V. HONORABLE THOMAS CLARK, SPECIAL JUDGE NO. 07-CR-00211

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AND ORDER

James Anthony Gray was convicted by the Scott Circuit Court after a

jury trial of two counts of murder for intentionally killing his parents, James

Gray and Vivian Gray (collectively Gray’s parents), and one count of tampering

with physical evidence. This Court reversed and remanded, and on retrial the

jury again found Gray guilty of the same crimes. 1 Gray received consecutive

sentences for a total of fifty-five years’ as follows: Count 1, Murder: twenty

years’; Count 2, Murder: thirty-years’; and Count 3, Tampering: five years’.

Gray again appeals as a matter of right, alleging multiple trial errors. Gray’s

1 The final judgment before us is the result of Gray’s third trial. The first trial

ended in a hung jury. Our Court reversed the result of Gray’s second trial on the basis that Gray’s confession, procured after a lengthy police interrogation which included the use of a fabricated DNA report tying him to the murders should have been suppressed and constituted a reversible error. Gray v. Commonwealth, 480 S.W.3d 253, 259-65 (Ky. 2016). Our Court also ruled that Gray’s alternative perpetrator evidence regarding Peter Hafer should have been admitted. Id. at 266-68. murder convictions are affirmed because the Court was equally split in its

voting and the tampering conviction is reversed by a majority of the Court.

I. THE MURDER CONVICTIONS

As to the two murder convictions, the vote of the six members of this

Court participating in the determination of this appeal is equally divided.

Therefore, pursuant to Supreme Court Rule (SCR) 1.020(1)(a), the judgment of

the Scott Circuit Court on these convictions stands affirmed.

Bisig, Keller, and Lambert, JJ., would affirm the judgment of the Scott

Circuit Court; Conley, Nickell, and Thompson, JJ., would reverse the judgment

of the Scott Circuit Court. VanMeter, C.J., not sitting.

II. THE TAMPERING CONVICTION

As to the tampering conviction, the vote of the six members of this Court

participating, Bisig, Conley, Keller, Lambert, Nickell, and Thompson, JJ., is to

reverse and remand for the trial court to vacate that conviction.

Gray argues that the mere fact that the gun used to commit the murders

was never recovered was insufficient to allow the jury to infer that Gray

intended to impair the availability of the evidence while believing an official

proceeding may be instituted. Relying on Mullins v. Commonwealth, 350 S.W.3d

434, 443-44 (Ky. 2011), Gray argues that the fact that the perpetrator leaves

the scene with evidence is not enough to establish a tampering charge when

insufficient steps were taken to locate that evidence and no proof is provided

that the defendant acted to prevent the evidence from being available at trial.

2 Gray argues that no evidence was presented at trial regarding what steps the

police took to recover the gun.

The Commonwealth argues that in construing the evidence in the light

most favorable to the Commonwealth, it was not clearly unreasonable for the

jury to find Gray guilty of tampering after the jury found beyond a reasonable

doubt that Gray had murdered his parents. There was evidence Gray had a .45

caliber pistol, and the jury heard evidence that the police engaged in an

extensive search for the murder weapon. The Commonwealth cites various

portions of testimony from Detective Rodger Persley and states that the search

for the murder weapon included Gray’s parents’ home and surrounding areas,

Gray’s home, cars, and work van. Having reviewed such testimony, Detective

Persley did not testify that Gray’s home was searched for the murder weapon.

Instead, he testified that police sought a search warrant to seize Gray’s work

clothes to test them for gunshot residue, but this warrant was denied.

KRS 524.100(1) states in relevant part:

A person is guilty of tampering with physical evidence when, believing that an official proceeding is pending or may be instituted, he:

(a) Destroys, mutilates, conceals, removes or alters physical evidence which he believes is about to be produced or used in the official proceeding with intent to impair its verity or availability in the official proceeding[.]

In Mullins, 350 S.W.3d at 442, our Court established that evidence that

the defendant must have left the scene with the firearm “is not enough to

support a tampering charge without evidence of some additional act

demonstrating an intent to conceal.” The Court explained: 3 When a crime takes place, it will almost always be the case that the perpetrator leaves the scene with evidence. If this amounted to a charge of tampering, the result would be an impermissible “piling on.”

Instead, intent to impair availability of evidence, believing that an official proceeding may be instituted, is the standard required under KRS 524.100. . . . [W]here the person charged is the defendant, it is reasonable to infer that the primary intent when a defendant leaves the scene of a crime is to get himself away from the scene and that carrying away evidence that is on his person is not necessarily an additional step, or an active attempt to impair the availability of evidence.

Id. at 443. When there are “conventional” locations where a firearm could have

been found after being carried away, but there is no evidence that the police

searched those places, rather than just searching the murder scene, this is

insufficient to establish a tampering charge. Id. at 444.

The Commonwealth cannot bootstrap a tampering charge onto another charge simply because a woefully inadequate effort to locate the evidence was made by the police. It is often the case that evidence will not be found. However, it is insufficient to bring a charge of tampering based solely on the fact evidence was not found when there were insufficient steps to locate that evidence, and there is no proof that the defendant acted with the intent to prevent evidence from being available at trial.

Id.

This same reasoning was applied in McAtee v. Commonwealth, 413

S.W.3d 608, 616-17 (Ky. 2013), to require a directed verdict on the tampering

charge where the firearm was never located and a search was never made of

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Related

Speiser v. Randall
357 U.S. 513 (Supreme Court, 1958)
Mullins v. Commonwealth
350 S.W.3d 434 (Kentucky Supreme Court, 2011)
McAtee v. Commonwealth
413 S.W.3d 608 (Kentucky Supreme Court, 2013)
Gray v. Commonwealth
480 S.W.3d 253 (Kentucky Supreme Court, 2016)

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James Anthony Gray v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-anthony-gray-v-commonwealth-of-kentucky-ky-2024.