Jesse Ooten v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedNovember 29, 2023
Docket2022 CA 001436
StatusUnknown

This text of Jesse Ooten v. Commonwealth of Kentucky (Jesse Ooten 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
Jesse Ooten v. Commonwealth of Kentucky, (Ky. Ct. App. 2023).

Opinion

RENDERED: DECEMBER 1, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-1436-MR

JESSE OOTEN APPELLANT

APPEAL FROM KENTON CIRCUIT COURT v. HONORABLE PATRICIA M. SUMME, JUDGE ACTION NO. 21-CR-01576

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; ECKERLE AND KAREM, JUDGES.

THOMPSON, CHIEF JUDGE: Jesse Ooten (“Appellant”) appeals from an

amended nunc pro tunc final judgment and sentence of imprisonment entered by

the Kenton Circuit Court. Appellant argues that the Commonwealth’s prosecution

of similar charges violated the prohibition against double jeopardy, and that he was

denied the right to present a complete defense. He requests an opinion ruling that

his convictions for tampering with a prisoner monitoring device and escape in the

second degree, violated his right to be free from double jeopardy. He also seeks a new trial on the charge of tampering with a prisoner monitoring device. After

careful review, we find no error and affirm the judgment on appeal.

FACTS AND PROCEDURAL HISTORY

On October 12, 2021, Appellant was placed on a home incarceration

program (“HIP”) as part of pretrial release on a domestic violence charge. As

Appellant could not return to his own home to serve the pretrial release, he stayed

with his co-worker, Ed Young, whose residence was designated as the official HIP

location.

Per the terms of the HIP, Young was allowed to transport Appellant to

and from work, with no stops. Other restrictions were placed on Appellant’s

freedom while at Young’s residence. Appellant could walk onto the front and back

porches, but no farther. Additionally, Appellant could have no visitors and was

required to wear an ankle monitor at all times. The location of the ankle monitor

could be viewed electronically by HIP employees and the employees would be

notified if the monitor was removed.

On November 4, 2021, Young transported Appellant to their

workplace in Young’s vehicle as he did on any other work day. Young would later

testify that at the workplace, he became aware that Appellant had been sent home

for the day. Young then looked on his phone at his home security cameras and saw

Appellant in his home in apparent violation of the terms of Appellant’s HIP.

-2- Young called the police, who met him at his residence. The police had reason to

believe that Appellant was behaving erratically and that he may have had a

handgun. They determined that Appellant was not at the residence and they found

Appellant’s ankle monitor, which had been removed by a knife. Appellant was

later arrested at a local park.

On December 16, 2021, a Kenton County grand jury returned two

indictments against Appellant. The first indictment, Kenton County No. 21-CR-

01576, charged Appellant with one count of tampering with a prisoner monitoring

device, escape in the second degree, and with being a persistent felony offender in

the second degree (“PFO”). The second indictment, Kenton County No. 21-CR-

01577, charged Appellant with one count each of a convicted felon in possession

of a handgun, theft by unlawful taking (firearm), criminal mischief in the first

degree, and with being a PFO in the first degree.

The charges set out in the first indictment proceeded to a jury trial in

August, 2022, resulting in a verdict of guilty on the tampering, escape, and PFO

charges.1 The second indictment was held for trial in 2023, and the judgment in

that proceeding is not now before us. Based on the 2022 verdict arising from the

first indictment, the circuit court sentenced Appellant to two years in prison on the

tampering conviction, four years on the escape conviction, and an enhancement to

1 Kentucky Revised Statutes (“KRS”) 519.070; KRS 520.030; KRS 532.080.

-3- 10 and 13 years, respectively, based on the PFO conviction, to be run concurrently.

This appeal followed.

STANDARD OF REVIEW

Appellant raises questions that “primarily involve[ ] the interpretation

of sections of the Constitution and statutes. Therefore, this Court applies the de

novo standard of review in deciding this appeal.” Greene v. Commonwealth, 349

S.W.3d 892, 898 (Ky. 2011) (citation omitted).

ARGUMENTS AND ANALYSIS

Appellant first argues that his prosecution and conviction on the

tampering and escape charges violated the prohibition against double jeopardy as

established in the Fifth Amendment to the United States Constitution and Section

13 of the Kentucky Constitution. Specifically, and per Kiper v. Commonwealth,

399 S.W.3d 736, 741 (Ky. 2012), as modified on denial of reh’g (Apr. 25, 2013),

he asserts that the tampering and escape charges arose from the same conduct at

Young’s residence; therefore, this should have resulted in a single charge. He

acknowledges that this issue is not preserved for appellate review. He argues,

however, that a claim of double jeopardy may be considered by an appellate court

despite its lack of preservation. In the alternative, he seeks a review for palpable

-4- error. We will review his argument for palpable error. See Cardine v.

Commonwealth, 283 S.W.3d 641, 652 (Ky. 2009).2

The double jeopardy clause of the Fifth Amendment of the United

States Constitution provides that no person shall “be subject for the same offence

to be twice put in jeopardy of life or limb[.]” Section 13 of the Kentucky

Constitution contains similar language. The standard for addressing double

jeopardy claims was set out in Blockburger v. United States, 284 U.S. 299, 52 S.

Ct. 180, 76 L. Ed. 306 (1932). KRS 505.020 is a codification of the double

jeopardy law. Fagan v. Commonwealth, 374 S.W.2d 274, 277 (Ky. 2012).

KRS 505.020(1)(c) states,

[w]hen a single course of conduct of a defendant may establish the commission of more than one (1) offense, he may be prosecuted for each such offense. He may not, however, be convicted of more than one (1) offense when . . . [t]he offense is designed to prohibit a continuing course of conduct and the defendant’s course of conduct was uninterrupted by legal process, unless the law expressly provides that specific periods of such conduct constitute separate offenses.

2 “A palpable error which affects the substantial rights of a party may be considered . . . 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.” Kentucky Rules of Criminal Procedure (“RCr”) 10.26.

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Related

Blockburger v. United States
284 U.S. 299 (Supreme Court, 1931)
Fitts v. Calvert
374 S.W.2d 274 (Court of Appeals of Texas, 1963)
Cardine v. Commonwealth
283 S.W.3d 641 (Kentucky Supreme Court, 2009)
Weaver v. Commonwealth
156 S.W.3d 270 (Kentucky Supreme Court, 2005)
Martin v. Commonwealth
207 S.W.3d 1 (Kentucky Supreme Court, 2006)
Greene v. Commonwealth
349 S.W.3d 892 (Kentucky Supreme Court, 2011)
Fagan v. Commonwealth
374 S.W.3d 274 (Kentucky Supreme Court, 2012)
Kiper v. Commonwealth
399 S.W.3d 736 (Kentucky Supreme Court, 2012)
Biederman v. Commonwealth
434 S.W.3d 40 (Kentucky Supreme Court, 2014)

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Jesse Ooten v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jesse-ooten-v-commonwealth-of-kentucky-kyctapp-2023.