James Harris v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedMay 4, 2023
Docket2022 CA 000698
StatusUnknown

This text of James Harris v. Commonwealth of Kentucky (James Harris 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
James Harris v. Commonwealth of Kentucky, (Ky. Ct. App. 2023).

Opinion

RENDERED: MAY 5, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-0698-MR

JAMES HARRIS APPELLANT

APPEAL FROM LAUREL CIRCUIT COURT v. HONORABLE GREGORY A. LAY, JUDGE ACTION NO. 14-CR-00199-003

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: COMBS, EASTON, AND ECKERLE, JUDGES.

COMBS, JUDGE: Appellant, James Harris, appeals from an Order of the Laurel

Circuit Court denying his RCr1 11.42 motion to vacate his judgment of conviction

following an evidentiary hearing. After our review, we affirm.

1 Kentucky Rules of Criminal Procedure. The underlying facts are set forth in the direct appeal, Harris v.

Commonwealth, No. 2015-SC-000688-MR, 2016 WL 7665871 (Ky. Dec. 15,

2016), as follows in relevant part:

Stephen [a pseudonym for the victim] was five or six years old when his mother and stepfather first took him to James Harris’s home, where a course of sexual conduct would commence during the ensuing four years.

....

Harris, [Stephen’s mother, and stepfather] were all indicted. [Stephen’s mother and stepfather] were charged with multiple counts of human trafficking, in addition to first-degree complicity to sodomy. Harris was indicted on several counts of first-degree sodomy.

At trial, the Commonwealth offered testimony from Elvis Proffitt -- an inmate who shared a cell with Harris. After Proffitt’s attorney contacted law enforcement, Proffitt agreed to wear a wire, and recorded a conversation with Harris. In the conversation: Harris referred to Stephen by name; he confirmed that [the stepfather] would trade Stephen for drugs; that [the stepfather] would “shoot them up” and then they [Stephen and Harris] “would fuck.” Proffitt admitted at trial that he received assistance from the Commonwealth in his pending cases for agreeing to help, but denied any undue influence in obtaining Harris’s confession.

Harris contended at trial that Proffitt had drugged him and coerced him into making the incriminating statements and continued to deny the allegations levied against him. The jury ultimately convicted [Harris] on two counts of first-degree sodomy and sentenced him to fifty years’ imprisonment.

-2- Id. at *1-2. Harris appealed and contended that the trial court erred in allowing

testimony about his cross-dressing and by allowing the Commonwealth to

introduce evidence of charges of co-defendants, whose prosecution was severed

from his. The Kentucky Supreme Court affirmed.

On January 29, 2019, Harris, pro se, filed a motion to vacate his

sentence pursuant to RCr 11.42 alleging ineffectiveness of counsel. The circuit

court2 granted Harris’s request for an evidentiary hearing and appointed counsel.

Appointed counsel subsequently filed a supplemental motion to vacate. On

February 18, 2020, the circuit court conducted an evidentiary hearing. Defense

trial counsel, Harris’s sister, the DPA3 investigator, and Harris all testified.

The Circuit Court’s Order Denying Harris’s RCr 11.42 Motion

By Order entered on August 25, 2021, the circuit court denied

Harris’s motion as follows:

Movant claims that Hon. Cotha Hudson did not perform adequately as counsel. Movant brings forth seven (7) arguments as to why he was denied adequate counsel. These arguments include: (1) counsel failed to properly advise Movant during plea negotiations; (2) counsel failed to investigate and present witnesses in support of Movant’s defense; (3) counsel failed to attempt to neutralize the prejudicial effect of Movant’s cross-

2 References to the “circuit court” refer to the Laurel Circuit Court when it ruled on Harris’s RCr 11.42 motion. References to the “trial court” refer to the Laurel Circuit Court prior to the filing of said motion.

3 Department of Public Advocacy.

-3- dressing; (4) counsel failed to object to mentioning of severed co-defendants’ charges at trial; and (5) counsel failed to object to alleged prosecutorial misconduct during closing arguments; (6) counsel was unprepared for the penalty phase of trial; and (7) the cumulative effect of counsel’s errors rendered Movant’s proceedings fundamentally unfair.

The circuit court discussed the applicable law; i.e., that an RCr 11.42

movant has the burden of satisfying the two-pronged Strickland4 standard requiring

that he show that defense counsel’s representation fell below an objective measure

of reasonableness and that counsel’s errors prejudiced the outcome of the trial.

There is a strong presumption that counsel was effective and that the challenged

conduct may be sound trial strategy. The circuit court then addressed each of

Harris’s claims as follows:

1. Failure to properly advise during plea negotiations

The circuit court found Attorney Hudson’s testimony to be credible

and concluded that she acted competently in advising Harris of the plea offer.5

2. Failure to investigate and present witnesses in defense

The circuit court found no deficiency in Attorney Hudson’s

investigating and calling witnesses in Harris’s defense. The court explained that it

is duty of a lawyer to promptly investigate the circumstances of a case and attempt

4 Strickland v. Washington, 466 U.S. 668, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984).

5 Harris appears to have abandoned this issue on appeal.

-4- to find relevant facts, citing Rompilla v. Beard, 545 U.S. 374, 387, 125 S. Ct. 2456,

2466, 162 L. Ed. 2d 360 (2005). The circuit court noted that the DPA had assigned

an investigator to assist defense counsel with the case. The circuit court found that

Attorney Hudson investigated the victim’s siblings and determined that they were

of no assistance. It also found that Attorney Hudson considered calling the co-

defendants. However, their case was still pending, and their attorney advised that

if called as witnesses, they would invoke the privilege not to testify. She also

interviewed Harris’s brother, who offered no helpful information and made it clear

that he wanted no part of the trial. The court concluded that Attorney Hudson

performed her essential functions and acted reasonably.

3. Failure to neutralize prejudicial effect of movant’s cross-dressing

Harris alleged four separate instances where Attorney Hudson was

ineffective by failing to neutralize any prejudicial effect of his cross-dressing:

a. Voir Dire: Harris claimed that Attorney Hudson did not adequately

or effectively question the panel during voir dire. The circuit court explained that

Attorney Hudson had advised the jury that the Commonwealth would introduce

evidence that Harris was a cross-dresser. She then asked if that would cause a

juror to decide that Harris was guilty -- even if the Commonwealth failed to prove

guilt beyond a reasonable doubt. None of the jurors raised a hand in response. At

the evidentiary hearing, Attorney Hudson testified that she did not go into further

-5- detail because she thought it would only emphasize the issue and inflame the jury

against Harris. The circuit court concluded that the record and testimony at the

hearing showed that Attorney Hudson “consciously and intentionally considered

how to address the cross-dressing issue . . . [and] fulfilled her duty by asking the

question referred to above, and her decision to delve no further into the matter was

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Rompilla v. Beard
545 U.S. 374 (Supreme Court, 2005)
Gall v. Commonwealth
702 S.W.2d 37 (Kentucky Supreme Court, 1985)
Hodge v. Commonwealth
116 S.W.3d 463 (Kentucky Supreme Court, 2003)
Vinson v. Sorrell
136 S.W.3d 465 (Kentucky Supreme Court, 2004)
Brown v. Commonwealth
313 S.W.3d 577 (Kentucky Supreme Court, 2010)
Commonwealth v. Bussell
226 S.W.3d 96 (Kentucky Supreme Court, 2007)
Martin v. Commonwealth
207 S.W.3d 1 (Kentucky Supreme Court, 2006)
Leonard v. Commonwealth
279 S.W.3d 151 (Kentucky Supreme Court, 2009)
Haight v. Commonwealth
41 S.W.3d 436 (Kentucky Supreme Court, 2001)
Teague v. Commonwealth
428 S.W.3d 630 (Court of Appeals of Kentucky, 2014)
Commonwealth v. Lawson
454 S.W.3d 843 (Kentucky Supreme Court, 2014)
Commonwealth v. McGorman
489 S.W.3d 731 (Kentucky Supreme Court, 2016)

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James Harris v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-harris-v-commonwealth-of-kentucky-kyctapp-2023.