James Lang v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedFebruary 21, 2022
Docket2020 SC 0045
StatusUnknown

This text of James Lang v. Commonwealth of Kentucky (James Lang 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 Lang v. Commonwealth of Kentucky, (Ky. 2022).

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IMPORTANT NOTICE NOT TO BE PUBLISHED OPINION

THIS OPINION IS DESIGNATED “NOT TO BE PUBLISHED.” PURSUANT TO THE RULES OF CIVIL PROCEDURE PROMULGATED BY THE SUPREME COURT, CR 76.28(4)(C), THIS OPINION IS NOT TO BE PUBLISHED AND SHALL NOT BE CITED OR USED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE; HOWEVER, UNPUBLISHED KENTUCKY APPELLATE DECISIONS, RENDERED AFTER JANUARY 1, 2003, MAY BE CITED FOR CONSIDERATION BY THE COURT IF THERE IS NO PUBLISHED OPINION THAT WOULD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 OPINIONS CITED FOR CONSIDERATION BY THE COURT SHALL BE SET OUT AS AN UNPUBLISHED DECISION IN THE FILED DOCUMENT AND A COPY OF THE ENTIRE DECISION SHALL BE TENDERED ALONG WITH THE DOCUMENT TO THE COURT AND ALL PARTIES TO THE ACTION. RENDERED: FEBRUARY 24, 2022 NOT TO BE PUBLISHED

Supreme Court of Kentucky 2020-SC-0045-MR

JAMES LANG APPELLANT

ON APPEAL FROM JEFFERSON CIRCUIT COURT V. HONORABLE BARRY WILLETT, JUDGE NOS. 12-CR-003313 AND 17-CR-001135

COMMONWEALTH OF KENTUCKY APPELLEE

MEMORANDUM OPINION OF THE COURT

AFFIRMING

Appellant James Lang, a parolee indicted for the offense of second-degree

escape, opted for a bench trial for both the guilt and penalty phases of his trial.

He was convicted as charged and sentenced to twenty years in prison, his five-

year escape sentence being enhanced due to his status as a persistent felony

offender in the first degree (PFO I). Lang brings three issues on appeal. He

argues that (1) because he acted as his own counsel during his trial without

having had a Faretta1 hearing, reversal is required; (2) the second-degree

escape charge should have been dismissed because it was based upon the

Department of Corrections’ (DOC) inaccurate sentence time-credit calculations;

and (3) the trial court sentenced him in abstentia in violation of the Due

1 Faretta v. California, 422 U.S. 806 (1975). Process provisions of the Kentucky and U.S. Constitutions. For the reasons

stated below, we affirm the Jefferson Circuit Court’s judgment.

FACTUAL AND PROCEDURAL BACKGROUND

Lang was staying at Dismas Charities House (Dismas), a DOC

community facility,2 in Louisville in 2012 as a state inmate. On August 8,

2012, he left for work but never reported to work or back to Dismas. Lang was

arrested September 25, 2012 and indicted by a Jefferson County grand jury on

October 25, 2012 for committing the offense of second-degree escape.3 He was

later indicted in 2017 for being a PFO I.

A bench trial was held in May 2017. The Commonwealth called five

witnesses. Lang, along with his attorney, cross-examined the DOC Offender

Information Administrator (OIA). Lang testified on his own behalf and did not

call any other witnesses. The trial judge found Lang guilty of second-degree

escape, and at a subsequent penalty phase bench trial, found Lang to be a PFO

I. He was sentenced December 3, 2018 to prison for twenty years, an

enhancement of his five-year sentence for committing escape in the second

degree.

The claims Lang raises on appeal are addressed in turn.

2 Dismas Charities was referred to as a “halfway house” during Lang’s trial. 3 “A person is guilty of escape in the second degree when he escapes from a

detention facility or, being charged with or convicted of a felony, he escapes from custody.” Kentucky Revised Statute (KRS) 520.030(1). “Escape in the second degree is a Class D felony.” KRS 520.030(2). 2 ANALYSIS

I. Faretta Hearing

Lang’s first claim is that the trial court committed error by failing to

conduct a Faretta hearing before allowing Lang to function as hybrid counsel.

Because this issue is unpreserved, Lang requests Kentucky Rule of Criminal

Procedure (RCr) 10.26 palpable error review.4

Lang filed his written pro se motion to be designated as co-counsel

pursuant to Section 11 of the Kentucky Constitution. Viewing Kentucky’s

Constitution as guaranteeing a criminal defendant the right to be heard by

both counsel and by himself, Lang disagreed with Kentucky precedent that

requires a Faretta hearing in hybrid counsel situations. Lang requested that

the trial court simply designate him as co-counsel. Otherwise, he requested

the trial court hold a Faretta hearing to determine exactly his and his counsel’s

obligations with respect to representation.

Lang’s motion was considered during a pretrial conference held three

months before his trial. Lang’s counsel began, describing Lang acting recently

as co-counsel in another division of Jefferson Circuit Court.5

4 RCr 10.26 states:

A palpable error which affects the substantial rights of a party may be considered by the court on motion for a new trial or by an appellate court on appeal, even though insufficiently raised or preserved for review, and appropriate relief may be granted upon a determination that manifest injustice has resulted from the error.

5 Fillers and repetitions are omitted from the transcription.

3 Counsel: Your Honor, Mr. Lang served as his own counsel in Division 11 . . . last week.6 He conducted cross examination of all the Commonwealth’s witnesses, filed some motions on his own, asked but was not allowed to do the opening and closing. So what I did was objections, some motions, and opening and closing statements, and tendered instructions. Mr. Lang, I don’t know how much you have seen of his legal filings, but it’s one where I think he wants to move forward and it’s a very important matter to him to exercise his individual rights to represent himself but with the assistance of counsel.

Lang: Yes, sir.

Court: Why would you want to do that?

Lang: Previously, I was, from my experience, I wasn’t, I had to get conflict counsel7 because the Public Defender’s Office just was hosing me basically. They weren’t talking to me, they weren’t doing nothing. And I wanted to protect myself. That has subsequently changed somewhat. And I believe, I just, like I said would prefer to be in a position where if I felt things were going south to be able to file a motion or address the court.

Court: Okay. My experience with criminal defendants representing themselves in Circuit Court has not been good.

Court: The last individual that represented himself, I have to stop and remember, he turned down 10 years . . .15 years and ended up getting 45. Particularly in light of the fact that the lawyer sitting next to you is very competent. He’s very good at what he does. You know you have a constitutional right to represent yourself if you want to, but my analogy is, it’s a lot like needing surgery, would you ever dream of performing surgery on yourself.

6 Lang’s agreement that it was “last week” is omitted. 7 The attorney representing Lang at this point is appointed conflict counsel.

4 Lang: No.

Court: No.

Lang: I understand Your Honor. And actually I’m in a position now where I think [counsel] and I have an understanding, if I could go ahead and waive the Faretta request.

Court: Well, I don’t want you to think I’m trying to push you into doing that. It’s your decision.

Lang: That sounds fine.

Court: Okay, is that what you want to do today, you want to waive?

Lang: Yes, sir. (Answering contemporaneously with the court’s question.)

Court: You want to waive? Okay. All right. And if you change your mind you can always re-motion.

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