Jason Barrett v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedAugust 23, 2023
Docket2022 SC 0068
StatusUnknown

This text of Jason Barrett v. Commonwealth of Kentucky (Jason Barrett 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.

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Jason Barrett v. Commonwealth of Kentucky, (Ky. 2023).

Opinion

RENDERED: AUGUST 24, 2023 TO BE PUBLISHED

Supreme Court of Kentucky 2022-SC-0068-MR

JASON BARRETT APPELLANT

ON APPEAL FROM OHIO CIRCUIT COURT V. HONORABLE TIMOTHY R. COLEMAN, JUDGE NO. 19-CR-00001

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION OF THE COURT BY JUSTICE KELLER

AFFIRMING

An Ohio County grand jury indicted Jason Barrett on ten counts of first-

degree sexual abuse for actions perpetrated against his stepdaughter, K.V., a

minor at the time of the sexual abuse.1 K.V.’s mother, Katherine Barrett, was

also indicted on multiple counts of complicity to the sexual abuse.2 Barrett and

Katherine were tried jointly. Before the trial commenced, one count of sexual

abuse against Barrett was dismissed. A jury found both Barrett and Katherine

guilty of all other counts. Barrett was sentenced to 20 years in prison. He

1 We use abbreviations to identify the victim and her siblings to protect their

privacy. 2 There are multiple Barretts in this case. To avoid confusion, Jason will be

referred to as Barrett and Katherine will be referred to by her first name. appealed his conviction to this Court as a matter of right. See KY. CONST. §

110(2)(b). After careful review of the record, we affirm the Ohio Circuit Court.

I. BACKGROUND

This case involves nine incidents of sexual abuse that occurred between

February 10, 2016, and December 5, 2018. When Barrett committed these

acts, the victim, K.V., was between the ages of 15 and 17. During this period,

K.V. lived in the same household as Barrett, Katherine, her older sister E.M.,

and her three younger siblings. When K.V. was living with Barrett and

Katherine she also had an older boyfriend who lived in Georgetown, Kentucky.

K.V. told her boyfriend about the sexual abuse and showed him some of her

diary entries recalling events surrounding the abuse.

In December 2018, K.V. wanted to stay with her boyfriend for two weeks

around the holidays. At first Barrett and Katherine said yes but objected when

she wanted to stay longer. Their objection was because she was only 17 years

old. Around the same time, K.V.’s boyfriend reported the sexual abuse to his

teacher on December 6, 2018.

When K.V.’s boyfriend reported the sexual abuse to his teacher, the

teacher contacted the Cabinet for Health and Family Services. The

aforementioned report led to a welfare check at the Barrett home by deputies

with the Ohio County Sheriff’s Department on December 6, 2018. K.V., fearing

a truthful disclosure would lead to her and her siblings being placed in foster

care, denied that any abuse occurred. The police conducted another interview

2 with K.V. outside of the home on December 7, 2018, where she then told

Detective Katie Pate that she was sexually abused by Barrett.

Detective Pate also interviewed Barrett and Katherine. Barrett admitted to

touching K.V. on the buttocks but claimed it was not sexual. Katherine initially

denied seeing Barrett touch K.V. inappropriately but later admitted seeing him

touch her buttocks. Katherine insisted that the touching was not sexual.

At trial, K.V. testified to the nine incidents of sexual abuse and read

aloud from her diary entries. Barrett testified in his own defense and denied he

sexually abused his stepdaughter. Katherine testified she never knew or saw

Barrett touch K.V. inappropriately. E.M. testified she shared a room with K.V.

who never told her anything about Barrett sexually abusing her.

After two days of trial, the jury found Barrett guilty of all nine counts of

first-degree sexual abuse, and Katherine guilty of two counts of complicity to

sexual abuse. The trial court sentenced Barrett to a total of twenty years in

prison. Barrett now appeals to this Court as a matter of right alleging multiple

errors.

II. ANALYSIS

On appeal, Barrett alleges multiple errors by the trial court warranting

reversal of his conviction. First, he argues the Commonwealth engaged in

flagrant prosecutorial misconduct when the prosecutor told the jury in closing

argument, “[t]hat presumption of innocence, I would submit to you is gone

because you’ve heard the proof beyond a reasonable doubt.” Second, he argues

the trial court erroneously allowed K.V. to read from printed screenshots of her

3 iPad diary. Third, Barrett argues the trial court erred by allowing the

Commonwealth to ask a witness to comment on the credibility of another

witness. Fourth, he argues the jury instructions violated his right to a

unanimous verdict. Finally, Barrett argues this Court should overturn his

conviction based on cumulative error. We discuss each argument in turn.

A. The prosecutor’s closing argument was improper but was not flagrant prosecutorial misconduct.

Barrett argues the Commonwealth engaged in flagrant prosecutorial

misconduct during its closing argument. Specifically, he argues that the

flagrant prosecutorial misconduct occurred when the prosecutor told the jury

that the “presumption of innocence, I would submit to you is gone because

you’ve heard the proof beyond a reasonable doubt.” Barrett argues that single

comment was flagrant prosecutorial misconduct and violated his right to a fair

trial.

“Prosecutorial misconduct is ‘a prosecutor’s improper or illegal act

involving an attempt to persuade the jury to wrongly convict a defendant or

assess an unjustified punishment.’” Commonwealth v. McGorman, 489 S.W.3d

731, 741–42 (Ky. 2016) (quoting Noakes v. Commonwealth, 354 S.W.3d 116,

121 (Ky. 2011)). “If the misconduct is objected to, we will reverse on that

ground if proof of the defendant’s guilt was not such as to render the

misconduct harmless, and if the trial court failed to cure the misconduct with a

sufficient admonition to the jury.” Duncan v. Commonwealth, 322 S.W.3d 81,

87 (Ky. 2010). However, if no objection is made, the Court “will reverse only

4 where the misconduct was flagrant and was such as to render the trial

fundamentally unfair.” Id. (citations omitted).

No contemporaneous objection was made, and Barrett concedes that this

issue is unpreserved. Because the issue is unpreserved, Barrett requests we

review it for palpable error. See RCr 10.26.

Barrett argues the Commonwealth committed flagrant prosecutorial

misconduct in its closing argument when the prosecutor told the jury,

By the way, the presumption of innocence at this point in time [sic]. You’ve heard the proof. You’ve heard the evidence. You’ve heard this child tell you, in details that I didn’t want to have to get into in mixed company, but we have to, to hold these people accountable. That presumption of innocence, I would submit to you is gone because you’ve heard the proof beyond a reasonable doubt. There is no reasonable doubt what happened in this case. Because this child told you the truth.

(emphasis added). In support of his argument, Barrett cites to a Washington

Court of Appeals decision that reversed the defendant’s conviction because the

prosecutor made repeated improper comments in closing, including that the

presumption of innocence “kind of stops once you start deliberating.” State v.

Evans, 260 P.3d 934, 938 (Wash. Ct. App. 2011). Barrett argues that in

Kentucky “every person accused of committing a crime is entitled to the

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