James Douglas Young v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedDecember 11, 2020
Docket2019 SC 0285
StatusUnknown

This text of James Douglas Young v. Commonwealth of Kentucky (James Douglas Young 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 Douglas Young v. Commonwealth of Kentucky, (Ky. 2020).

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IMPORTANT NOTICE NOT TO BE PUBLISHED OPINION

THIS OPINION IS DESIGNATED “NOT TO BE PUBLISHED.” PURSUANT TO THE RULES OF CIVIL PROCEDURE PROMULGATED BY THE SUPREME COURT, CR 76.28(4)(C), THIS OPINION IS NOT TO BE PUBLISHED AND SHALL NOT BE CITED OR USED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE; HOWEVER, UNPUBLISHED KENTUCKY APPELLATE DECISIONS, RENDERED AFTER JANUARY 1, 2003, MAY BE CITED FOR CONSIDERATION BY THE COURT IF THERE IS NO PUBLISHED OPINION THAT WOULD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 OPINIONS CITED FOR CONSIDERATION BY THE COURT SHALL BE SET OUT AS AN UNPUBLISHED DECISION IN THE FILED DOCUMENT AND A COPY OF THE ENTIRE DECISION SHALL BE TENDERED ALONG WITH THE DOCUMENT TO THE COURT AND ALL PARTIES TO THE ACTION. RENDERED: DECEMBER 17, 2020 NOT TO BE PUBLISHED

Supreme Court of Kentucky 2019-SC-0285-MR

JAMES DOUGLAS YOUNG APPELLANT

ON APPEAL FROM WARREN CIRCUIT COURT HONORABLE STEVE ALAN WILSON, JUDGE V. NO. 18-CR-00479-001

COMMONWEALTH OF KENTUCKY APPELLEE

MEMORANDUM OPINION OF THE COURT

REVERSING AND REMANDING

A circuit court jury convicted James Douglas Young on nine counts of

trafficking various illicit drugs and controlled substances, one count of

receiving stolen property, and one count of possession of drug paraphernalia.

Young was sentenced to twenty years’ imprisonment. He appeals from the

resulting judgment as a matter of right.1

Young asserts three claims of reversible error: (1) the trial court

erroneously denied him the right to participate in his case as “hybrid counsel,”

(2) the Commonwealth failed timely to disclose exculpatory information in

1 Ky. Const. § 110(2)(b). violation of the Brady Rule,2 and (3) the trial court failed to direct a verdict of

acquittal on several counts of drug possession with intent to distribute.

Because, as the Commonwealth concedes, the trial court committed

structural error as to the first claim of error, we reverse the judgment and

remand the case to the trial court for further proceedings consistent with this

opinion. We analyze Young’s remaining claims of error as they may arise in

the event of a retrial. We find no error in the remaining claims.

I. FACTUAL BACKGROUND

While working as a confidential informant for the local drug task force,

Tyler Poole suggested Young to a detective and showed him the apartment

where Young lived. The task force then investigated Young for trafficking drugs

out of his apartment. The detective set Poole up to perform a controlled buy.

He put a wire on Poole, gave him $390 in marked bills, and directed him to

Young’s apartment. Poole engaged with Young at his apartment, negotiated a

deal for a quantity of methamphetamine, then returned to the detective with

$90 and 4.487 grams of methamphetamine. Poole also reported that while he

did not see the drugs himself Young told him he was also selling heroin,

Adderall, and Oxycontin.

The detective obtained a warrant to search Young’s apartment. The

search produced twelve baggies of methamphetamine, five baggies of

2 Brady v. Maryland, 373 U.S. 83 (1963) (requiring prosecutors to disclose to

the defense materially exculpatory evidence in the government’s possession).

2 heroin-Fentanyl mixture, one baggie of cocaine, Suboxone strips, Adderall in

20 mg and 30 mg doses, Oxycodone, and seventeen baggies of marijuana,

along with $674 in Young’s wallet and $250 of marked money from the

controlled buy.

The grand jury returned a fourteen-count indictment against Young,

including multiple counts for trafficking in a controlled substance, trafficking

in marijuana, receiving a stolen firearm, and possession of drug paraphernalia.

Following a three-day trial, the jury convicted Young on the twelve counts

presented to it. II. ANALYSIS

A. The trial court committed structural error when it refused to hold a Faretta hearing upon Young’s request for hybrid representation, requiring reversal.

Approximately forty days before trial, Young sent a letter to the trial

court expressing not only his displeasure with his counsel’s performance but

also his desire to call and cross-examine witnesses himself. Ten days before

trial, Young sent a similar letter that was received the day of trial. After the

jury was selected, Young again asserted his desire to cross-examine certain

witnesses himself. The trial court nonetheless denied the request for a hearing

and denied Young the option to proceed unrepresented, even for the limited

purpose of cross-examining witnesses. The trial court stated that the law did

not recognize the right to hybrid counsel and that Young would either proceed

completely pro se or Young would exercise his right to present his defense,

including the right to cross-examine witnesses, solely through counsel.

3 Whether the trial court erred as a matter of law on this point is a legal

question we review de novo.

Young first asserts a right to “hybrid counsel” under both the United

States and Kentucky Constitutions. He follows this assertion by arguing the

trial court committed reversible error when it refused to hold a Faretta hearing

and when it told him that Kentucky did not recognize a right to hybrid counsel,

effectively forcing Young to accept his counsel and his counsel’s decision-

making. The Commonwealth concedes that under Kentucky precedent the trial

court committed reversible error. We agree with both parties that the trial

court committed reversible error on this point alone, despite a clear lack of

prejudice.

Of course, criminal defendants have a right to competent legal

representation in criminal proceedings under the Sixth Amendment of the

United States Constitution3 and under Section 11 of the Kentucky

Constitution.4 But criminal defendants also have the right to proceed

unrepresented if they properly waive their right to counsel and are guaranteed

procedural safeguards in that process.5 The primary safeguard is a Faretta

hearing, which is mandated whenever a defendant timely and unequivocally6

3 Gideon v. Wainwright, 372 U.S. 335 (1963). 4 Ky. Const. § 11 guarantees a criminal defendant the right “to be heard by himself and counsel.” Deno v. Commonwealth, 177 S.W.3d 753, 757 (Ky. 2005); Jenkins v. Commonwealth, 491 S.W.2d 636, 638 (Ky. 1973). 5 Faretta v. California, 422 U.S. 806, 817 (1975) (“We confront here a nearly universal conviction, on the part of our people as well as our courts, that forcing a lawyer upon an unwilling defendant is contrary to his basic right to defend himself if he truly wants to do so.”). See Deno, at 758. 6 Deno, at 758 (citing Moore v. Commonwealth, 634 S.W.2d 426, 430 (Ky. 1982)).

4 requests to proceed unrepresented to any extent.7 Under Faretta, to deny this

hearing after a defendant properly requests it amounts to a violation of the

federal constitution.

Further, criminal defendants can request and shall be afforded the

option of what is sometimes called “hybrid counsel,”8 which refers to a

defendant’s proceeding unrepresented as to chosen, pre-defined aspects of a

trial or proceeding, while counsel’s representation is confined to other aspects.9

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

Related

Napue v. Illinois
360 U.S. 264 (Supreme Court, 1959)
Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Faretta v. California
422 U.S. 806 (Supreme Court, 1975)
United States v. Agurs
427 U.S. 97 (Supreme Court, 1976)
Olden v. Kentucky
488 U.S. 227 (Supreme Court, 1988)
Kyles v. Whitley
514 U.S. 419 (Supreme Court, 1995)
United States v. Dwayne Dolan
544 F.2d 1219 (Fourth Circuit, 1976)
Hill v. Commonwealth
125 S.W.3d 221 (Kentucky Supreme Court, 2004)
Baucom v. Commonwealth
134 S.W.3d 591 (Kentucky Supreme Court, 2004)
Major v. Commonwealth
275 S.W.3d 706 (Kentucky Supreme Court, 2009)
Schrimsher v. Commonwealth
190 S.W.3d 318 (Kentucky Supreme Court, 2006)
Moore v. Commonwealth
634 S.W.2d 426 (Kentucky Supreme Court, 1982)
Howard v. Commonwealth
787 S.W.2d 264 (Court of Appeals of Kentucky, 1989)
Wake v. Barker
514 S.W.2d 692 (Court of Appeals of Kentucky (pre-1976), 1974)
Commonwealth v. Benham
816 S.W.2d 186 (Kentucky Supreme Court, 1991)
Bowling v. Commonwealth
80 S.W.3d 405 (Kentucky Supreme Court, 2002)
Deno v. Commonwealth
177 S.W.3d 753 (Kentucky Supreme Court, 2005)
Finnell v. Commonwealth
295 S.W.3d 829 (Kentucky Supreme Court, 2009)
Commonwealth v. Bussell
226 S.W.3d 96 (Kentucky Supreme Court, 2007)
Jones v. Commonwealth
331 S.W.3d 249 (Kentucky Supreme Court, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
James Douglas Young v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-douglas-young-v-commonwealth-of-kentucky-ky-2020.