James Taylor v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedMay 20, 2021
Docket2020 CA 000776
StatusUnknown

This text of James Taylor v. Commonwealth of Kentucky (James Taylor 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 Taylor v. Commonwealth of Kentucky, (Ky. Ct. App. 2021).

Opinion

RENDERED: MAY 21, 2021; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2020-CA-0776-MR

JAMES TAYLOR APPELLANT

APPEAL FROM FAYETTE CIRCUIT COURT v. HONORABLE THOMAS L. TRAVIS, JUDGE ACTION NO. 19-CR-00184

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: JONES, MAZE, AND L. THOMPSON, JUDGES.

THOMPSON, L., JUDGE: James Taylor (“Appellant”) appeals from a final

judgment and sentence of imprisonment of the Fayette Circuit Court reflecting a

conditional plea of guilty to cocaine possession, tampering with physical evidence,

and persistent felony offender charges. He argues that the circuit court erred in denying his motion to suppress evidence wrongfully obtained by the police. For

the reasons addressed below, we find no error and affirm the judgment on appeal.

FACTS AND PROCEDURAL HISTORY

At approximately 1:20 a.m. on November 23, 2018, Lexington police

officers Andrew Schickler and Cole Phillips were patrolling what they described as

a known narcotics area near a Thornton’s gas station in Lexington, Kentucky. The

officers observed Appellant, who was wearing a backpack, walk out of the

Thornton’s and get into a Ford Explorer. The vehicle was driven by Madeline

Montgomery. Nathan Russell was sitting in the front passenger seat. Appellant

got into the back seat, and the vehicle drove away from the Thornton’s property.

Officers Schickler and Phillips were suspicious of Appellant, in part

because of his backpack, and followed Montgomery’s vehicle. After observing the

vehicle commit three traffic violations, Schickler turned on his blue lights and

stopped the vehicle. Schickler and Phillips both approached the car on the

passenger side. The windows on the vehicle were heavily tinted and would not roll

down. Russell opened the door on the front seat passenger side of the vehicle, and

he began talking to Schickler. Phillips would later testify that Taylor opened the

back seat door, though Taylor would say that Phillips opened it. Phillips remained

at the vehicle and made small talk with its occupants, while Schickler returned to

his police vehicle to run the occupants’ information through his computer.

-2- Phillips then shined his flashlight inside the vehicle and observed a

red baggie at Taylor’s feet that he immediately recognized as containing narcotics.

The baggie appeared to have drug residue on it. Phillips removed all three persons

from the vehicle and asked them who owned the baggie. None of the occupants

would admit to owning the baggie. The officers then searched the inside of the

vehicle, including Taylor’s backpack. Inside the backpack they found scales and

baggies. On Taylor’s person they located methamphetamine, cash, and two cell

phones. What is described in the record as a criminal planning manifesto with

robbery plans and a black mask were found next to where Taylor was sitting in the

vehicle.

The officers arrested Taylor. He was taken to the police station where

he indicated that he needed to use the restroom. Accompanied by police, Taylor

went into the bathroom and began to manipulate something in his buttocks area.

An officer searched the back of Taylor’s pants and found pills and 5.68 grams of

crack cocaine.

Taylor was charged with trafficking in a controlled substance,

tampering with physical evidence, two counts of possession of a controlled

substance, possession of drug paraphernalia, and being a persistent felony offender

-3- in the second degree.1 Taylor subsequently moved to suppress the admission of the

baggie found in the vehicle near Taylor’s feet and other evidence found in the

backpack and on Taylor’s person. In support of the motion, Taylor, through

counsel, argued that Officer Phillips had no lawful authority to open the back door

of Montgomery’s vehicle, and but for that unlawful act, the baggie would not have

been in plain sight. Further, Taylor argued that because Phillips’ observation of

the baggie was the basis for the search of Taylor’s backpack and person, the baggie

and other evidence were inadmissible.

A hearing on the motion was conducted on May 23, 2019, after which

the Fayette Circuit Court entered an order denying the relief sought. The court

determined in relevant part that: 1) the traffic violations formed a sufficient basis

for an investigatory stop; 2) irrespective of whether Taylor or Officer Phillips

opened the door it was reasonable for Phillips to be standing on the passenger side

of the vehicle away from the traffic flow; and 3) because the windows were

heavily tinted and would not roll down, it was reasonable for the doors to be open

for the officers’ safety. Further, the court found that the incriminating nature of the

baggie with drug residue rendered the subsequent search of the vehicle, including

Taylor’s backpack, constitutionally permissible.

1 Kentucky Revised Statutes (“KRS”) 218A.1412; KRS 524.100; KRS 218A.1415; KRS 532.080(2).

-4- Thereafter, Taylor accepted a plea offer on one count of possession of

a controlled substance, first degree, tampering with physical evidence, and

persistent felony offender, second degree. As part of the plea, Taylor retained the

right to appeal the denial of his motion to suppress. In exchange for the plea to the

reduced charges, the Commonwealth recommended a total sentence of five years

in prison. The recommended sentence was accepted by the circuit court, and this

appeal followed.

ARGUMENT AND ANALYSIS

Taylor argues that the Fayette Circuit Court committed reversible

error in failing to suppress the evidence of his guilt including the red baggie, scales

and other baggies found in the backpack, and the items found on his person. While

acknowledging that Officer Phillips may have been justified in shining his

flashlight into the vehicle, Taylor argues that Phillips was not justified in opening

the rear passenger door. Taylor argues that without opening the door, Officer

Phillips would not have been able to see the red baggie and, without that

observation, the search of the backpack and Taylor’s person would not have

occurred. Taylor contends that the true purpose of the vehicle stop was to search

his backpack and person, and Phillips found a way to effectuate that purpose by

unlawfully opening the back door. Taylor asserts that the evidence of criminality

is fruit of the poisonous tree and thus not admissible in court. As the Fayette

-5- Circuit Court erred in failing to so rule, Taylor argues that the order denying his

motion to suppress must be reversed.

The plain view doctrine is an exception to the Fourth Amendment’s

warrant requirement. Coolidge v. New Hampshire, 403 U.S. 443, 465, 91 S. Ct.

2022, 29 L. Ed. 2d 564 (1971). The plain view doctrine applies when a law

enforcement officer is lawfully at the place where the evidence can be plainly

viewed; he has a lawful right to access the object itself; and, the object’s

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Related

Coolidge v. New Hampshire
403 U.S. 443 (Supreme Court, 1971)
Hazel v. Commonwealth
833 S.W.2d 831 (Kentucky Supreme Court, 1992)
Iris Jennings v. Commonwealth of Kentucky
490 S.W.3d 339 (Kentucky Supreme Court, 2016)

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James Taylor v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-taylor-v-commonwealth-of-kentucky-kyctapp-2021.