Jason A. Watts v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedOctober 31, 2019
Docket2018-SC-0409
StatusUnpublished

This text of Jason A. Watts v. Commonwealth of Kentucky (Jason A. Watts 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
Jason A. Watts v. Commonwealth of Kentucky, (Ky. 2019).

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IMPORTANT NOTICE NOT TO BE PUBLISHED OPINION

THIS OPINION IS DESIGNATED "NOT TO BE PUBLISHED." PURSUANT TO THE RULES OF CIVIL PROCEDURE PROMULGATED BY THE SUPREME COURT, CR 76.28(4){C), THIS OPINION IS NOT TO BE PUBLISHED AND SHALL NOT BE CITED OR USED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE; HOWEVER, UNPUBLISHED KENTUCKY APPELLATE DECISIONS, RENDERED AFTER JANUARY 1, 2003, MAY BE CITED FOR CONSIDERATION BY THE COURT IF THERE IS NO PUBLISHED OPINION THAT WOULD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 OPINIONS CITED FOR CONSIDERATION BY THE COURT SHALL BE SET OUT AS AN UNPUBLISHED DECISION IN THE FILED DOCUMENT AND A COPY OF THE ENTIRE DECISION SHALL BE TENDERED ALONG WITH THE DOCUMENT TO THE COURT AND ALL PARTIES TO THE ACTION. RENDERED: OCTOBER 31, 2019 NOT TO BE PUBLISHED

2018-SC-000409-MR

JASON A. WATTS APPELLANT

ON APPEAL FROM LYON CIRCUIT COURT V. HONORABLE CLARENCE A. WOODALL III, JUDGE NOS. 16-CR-00097, 16-CR-00098, 16-CR-00099, 16-CR-00100, 16-CR-00101

COMMONWEALTH OF KENTUCKY APPELLEE

MEMORANDUM OPINION OF THE COURT

AFFIRMING

A Lyon County jury convicted Jason A. Watts of one count each of

second-degree unlawful transaction with a minor, third-degree sodomy;

second-degree sodomy, and first-degree rape (victim under twelve), and two

counts of third-degree rape. Watts received a sentence of life imprisonment on

the first-degree rape conviction, ten (10) years on the second-degree rape

conviction, and five (5) years each on the remaining charges. This appeal

followed as a matter of right. See Ky. Const. Section 110(2)(b). Having reviewed

the record and the arguments of the parties, we affirm the Lyon Circuit Court. I. BACKGROUND

In 2013 or 2014, Watts divorced his wife and took his daughter, K.W.,1

and his two sons to live in Lyon County. During that time, Watts and his

children resided in a house on Watts’s parents’ property. The home was

referred to as the “rec house” because there was a pool table in one of the

rooms. While living at the rec house in April of 2014, K.W., approximately

eleven years old,2 had her first period. A few weeks later, her father had sex

with her for the first time.

While residing in the rec house, K.W. befriended an older girl, M.W.

M.W. was approximately two years older than K.W. and would sometimes

babysit the Watts children. She would also spend the night at the rec house.

The first time that M.W. spent the night at the rec house, M.W. asked K.W. to

“hook [her] up” with Watts. That night, Watts gave the girls marijuana to

smoke. Later that same night, after the girls had gone to bed, K.W. woke up

and realized that M.W. and Watts were in the bathroom. K.W. could hear

heavy breathing and voices coming from the bathroom. The next morning,

M.W. revealed to K.W. that she and Watts had had sex the night before.

In or around August 2014, when K.W. was approximately twelve years

old, Watts moved the children to Paducah, Kentucky, where he had a girlfriend.

1 The juvenile victims will be identified by their initials. 2 K.W.’s testimony as to the exact dates of these events is unclear. She testified that she had her first period just before she turned eleven years old but later acknowledges that the first instance of rape occurred in April 2014, when she would have already turned eleven years old.

2 During that time, Watts did not sexually abuse K.W. K.W. testified at trial that

he “would not touch [her] when he had a girlfriend.” However, M.W. visited the

Watts family in Paducah on at least two occasions and had sex with Watts on

at least one of those visits. After a few months,3 Watts and his girlfriend ended

their relationship, and Watts moved the family back to Lyon County. This

time, they moved to a trailer on Jenkins Road.

Upon returning to Lyon County, M.W. and K.W. rekindled their

friendship. M.W., approximately fourteen years old, visited the trailer almost

every day. At trial, M.W. testified that she had sex with Watts at the Jenkins

Road trailer “quite a few times.” K.W. also testified that she witnessed M.W. in

Watts’s bed having sex with Watts on at least one occasion. On another day,

Watts, K.W., and M.W. were in Watts’s room when Watts had K.W. “masturbate

him” and give him oral sex. K.W. believed that M.W., who was seated nearby,

saw K.W. masturbating Watts. In fact, M.W. testified at trial that she

witnessed K.W. sitting with Watts with a blanket over them. M.W. testified that

she saw K.W.’s hand under the blanket moving up and down. On another

occasion, K.W. recalled lying on her back in Watts’s bedroom while Watts had

sex with her when her grandmother, Fonda Watts, walked in. K.W. did not

speak with her grandmother about the incident.

About two weeks after this incident, in December 2015, the sexual abuse

was reported to law enforcement. The matter was reported after a student

3 The exact date that the family moved back to Lyon County is unclear. However, K.W. testified that it was sometime during her seventh-grade year.

3 heard that M.W. and K.W. were in sexual relationships with Watts and reported

this to a teacher. The matter was initially investigated by Kentucky State

Police Trooper Christopher Smith, but that investigation was eventually closed

because Trooper Smith thought that it might be possible Watts was telling the

truth when he denied the allegations. Meanwhile, in December 2015,

Kentucky State Police Officer (now Detective) Eric Fields began investigating

the allegations concerning M.W. Upon learning about the allegations

concerning K.W., he reopened that case and took over both investigations. As

a result of these investigations, K.W. and her brothers were removed from

Watts’s home. Several months later, on May 22, 2016, Detective Fields

interviewed Watts. Unfortunately, according to Detective Fields’s testimony at

trial, he did not seek a search warrant allegedly because several months had

passed since the children’s removal and Watts claimed he had already removed

all of the children’s belongings from his home, including a mattress.

Throughout the period of abuse, K.W. kept several journals, including

one for her dreams, one for her feelings, and one for her poetry. She also had a

cell phone, which allegedly contained recordings of Watts “saying sexual

things” as well as recordings of Watts physically abusing his son. K.W. was

unable to retrieve these items before she was removed from her father’s home.

At trial, Watts admitted into evidence some but not all of the journal entries

during his cross-examination of K.W. Watts himself testified that he had

looked for but could not find the cell phone.

4 A Lyon County jury found Watts guilty of second-degree unlawful

transaction with a minor, third-degree sodomy, second-degree sodomy, first-

degree rape (victim under twelve), and two counts of third-degree rape. This

appeal followed as a matter of right.

II. ANALYSIS

In his appeal, Watts asserts various errors. First, he argues that it was

error to allow evidence of his prior drug and alcohol use, evidence related to

payment of his bond and legal fees, and testimony suggesting that he hid or

destroyed evidence. Next, he argues that he was denied the right to present a

complete defense because (1) he was unable to introduce evidence of the

victims’ alleged use of a sex toy and M.W.’s sexually transmitted disease

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