Jimmy Hall v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedJuly 13, 2023
Docket2022 CA 000536
StatusUnknown

This text of Jimmy Hall v. Commonwealth of Kentucky (Jimmy Hall 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
Jimmy Hall v. Commonwealth of Kentucky, (Ky. Ct. App. 2023).

Opinion

RENDERED: JULY 14, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-0536-MR

JIMMY HALL APPELLANT

APPEAL FROM BUTLER CIRCUIT COURT v. HONORABLE PHILLIP PATTON, JUDGE ACTION NO. 14-CR-00059

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, COMBS, AND LAMBERT, JUDGES.

CALDWELL, JUDGE: Jimmy Hall (Hall) filed a motion pursuant to RCr1 11.42

seeking a new trial due to allegations of ineffective assistance of trial counsel. The

trial court denied relief, and he appeals. We affirm.

1 Kentucky Rules of Criminal Procedure. FACTS

In 2014, Hall engaged in sexual intercourse and sodomy with a young

girl who was only twelve (12) years old. The two had met on a telephone chat line

and Hall had told the young girl that he was just a few years older than she, but he

was actually fifty-six (56) years old. After the encounter, which took place in a

hotel room, the young girl told her mother what had occurred, and her mother

contacted the police.

While officers were at the young girl’s home responding to her

mother’s call, Hall began calling and texting her. Police were able to determine his

location via the cell signal and Hall was arrested. During an interrogation, Hall

admitted to having sex with the girl and acknowledged she had just turned thirteen

(13) years old.

He was tried on charges of use of electronic communications system

to procure a minor to sexual activity, two counts of unlawful transaction with a

minor, and being a persistent felony offender in the first degree. The jury found

him guilty of all charges and he was sentenced to life imprisonment.2

2 The trial court improperly ordered Hall’s two life sentences and a twenty-year sentence to all run consecutively. On direct appeal, the Kentucky Supreme Court reversed the sentence and remanded the matter for entry of a corrected judgment imposing a life sentence.

It is well established that life sentences may not be ordered to run consecutively. Bedell v. Commonwealth, 870 S.W.2d 779, 783 (Ky. 199[3), as modified on denial of reh’g (Jan. 31, 1994)]. Nor, when imposed as a result of the same trial, may a sentence for a term of years

-2- Following a direct appeal wherein his conviction was affirmed, Hall

filed a motion pursuant to RCr 11.42 seeking relief for ineffective assistance of

trial counsel. In the memorandum filed in support of the motion, counsel for Hall

argued trial counsel had been ineffective for failing to object to the testimony of a

hotel housekeeper. The housekeeper testified she threw away a blood-stained

bedsheet after cleaning the room in which the two had stayed. Further, it was

alleged that trial counsel had been ineffective by failing to present any mitigating

evidence concerning a history of abuse suffered by Hall and possible mental illness

during the penalty phase of his trial.

The trial court denied relief, without holding an evidentiary hearing,

finding that the record conclusively established Hall was not entitled to any relief.

The court referred to the opinion of the Kentucky Supreme Court, which pointed

out that the testimony of the housekeeper was brief, and the evidence of guilt was

overwhelming. As to the failure to present any evidence in mitigation, the court

run consecutively with a life sentence. See v. Commonwealth, 746 S.W.2d 401, 403-04 (Ky. 1988). While the trial court erred in ordering Hall’s sentences to run consecutively, the relief requested by Hall of a new sentencing hearing is inappropriate. Rather, the appropriate remedy is the remand of this case to the trial court for entry of a corrected judgment clarifying that Hall’s sentences are to run concurrently with each other.

Hall v. Commonwealth, No. 2015-SC-000714-MR, 2018 WL 898651, at *6 (Ky. Feb. 15, 2018).

-3- held that the vague allegations that the outcome may have been different if counsel

had called witnesses in mitigation were insufficient for a finding of ineffectiveness.

STANDARD OF REVIEW

We review the factual findings of the trial court for clear error. The

conclusions of law drawn therefrom are reviewed de novo. Ford v.

Commonwealth, 628 S.W.3d 147, 156 (Ky. 2021). On appeal, allegations of

ineffective assistance of counsel are reviewed in a two-part test. Strickland v.

Washington, 466 U.S. 668, 104 S. Ct. 2052, 80 L. Ed. 2d 674 (1984). This test was

adopted by the Kentucky Supreme Court in Gall v. Commonwealth, 702 S.W.2d 37

(Ky. 1985).

The first prong requires the appellant to show that the performance by

counsel was objectively deficient. The second prong requires a showing that that

deficient performance resulted in actual prejudice such that there exists a strong

probability that the outcome of the matter would have been more favorable to the

appellant without the instance of ineffectiveness. Strickland, 466 U.S. at 687, 104

S. Ct. at 2064.

ANALYSIS

Whether an RCr 11.42 movant is entitled to an evidentiary hearing

regarding his claim of ineffectiveness is determined under a two-part test. First,

the movant must show that the “alleged error is such that the movant is entitled to

-4- relief under the rule.” Hodge v. Commonwealth, 68 S.W.3d 338, 342 (Ky. 2001).

So, the trial court must assume that the factual allegations in the motion are true,

and only after such determination may turn to the question of whether there “has

been a violation of a constitutional right, a lack of jurisdiction, or such a violation

of a statute as to make the judgment void and therefore subject to collateral attack.”

Lay v. Commonwealth, 506 S.W.2d 507, 508 (Ky. 1974)). If that determination is

answered in the affirmative, then an evidentiary hearing is only required when the

motion raises “an issue of fact that cannot be determined on the face of the record.”

Stanford v. Commonwealth, 854 S.W.2d 742, 743-44 (Ky. 1993).

The trial court determined that the allegations made by Hall could be

refuted by the record. We do not disagree as the allegations were refuted by

review of the record alone.

Next, we address Hall’s allegation that trial counsel was ineffective

for failing to present evidence in mitigation during the sentencing phase. The trial

court found that the allegation of ineffectiveness was not made with sufficient

specificity in the motion. We agree with the trial court.

The motion filed in the trial court simply alleged that counsel failed to

make reasonable investigations into mitigation evidence that could be presented to

the sentencing jury. There is an acknowledgement that trial counsel’s investigator

-5- conducted investigations into the charges Hall faced but alleges that the

investigator was never tasked with searching for any evidence in mitigation.

However, even if we were to find that counsel’s performance fell

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Related

Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
Bedell v. Commonwealth
870 S.W.2d 779 (Kentucky Supreme Court, 1994)
Lay v. Commonwealth
506 S.W.2d 507 (Court of Appeals of Kentucky (pre-1976), 1974)
See v. Commonwealth
746 S.W.2d 401 (Kentucky Supreme Court, 1988)
Stanford v. Commonwealth
854 S.W.2d 742 (Kentucky Supreme Court, 1993)
Gall v. Commonwealth
702 S.W.2d 37 (Kentucky Supreme Court, 1985)
Hodge v. Commonwealth
68 S.W.3d 338 (Kentucky Supreme Court, 2002)

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