Jimmy Hall v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedJuly 2, 2026
Docket2025-CA-0470
StatusUnpublished

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. 2026).

Opinion

RENDERED: JULY 2, 2026; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2025-CA-0470-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: CETRULO, MCNEILL, AND TAYLOR, JUDGES.

CETRULO, JUDGE: Jimmy Hall (“Hall”) appeals from the Butler Circuit Court’s

denial of his motion for rulings on his unresolved pro se RCr1 11.42 claims. Upon

a careful review of the record below, we affirm, albeit on different grounds.

1 Kentucky Rule of Criminal Procedure. FACTS & PROCEDURAL BACKGROUND

The underlying facts of Hall’s conviction have been recited in three

Kentucky appellate court opinions,2 and we decline to engage in another detailed

recitation as it is unnecessary for purposes of our limited review. It is sufficient to

note that following his jury trial in 2015, Hall was convicted of two counts of first-

degree unlawful transaction with a minor, one count of use of electronic

communications systems to procure a minor, and being a first-degree persistent

felony offender. The trial court sentenced Hall to two terms of life imprisonment

for each count of unlawful transaction with a minor and 20 years of imprisonment

for use of electronic communications and ordered all sentences to run

consecutively. Hall appealed to the Kentucky Supreme Court as a matter of right.

In 2018, our Supreme Court affirmed Hall’s convictions but determined the trial

court erred by ordering the service of consecutive sentences and remanded the case

with the directive to correct the judgment such that the sentences would be served

concurrently. Hall, 2018 WL 898651, at *6.

After the conclusion of his direct appeal, Hall filed a pro se motion for

relief pursuant to RCr 11.42 in September 2020, raising a total of five ineffective

assistance of counsel (IAC) claims and one ineffective assistance of appellate

2 Hall v. Commonwealth, No. 2015-SC-000714-MR, 2018 WL 898651 (Ky. Feb. 15, 2018); Hall v. Commonwealth, No. 2022-CA-0536-MR, 2023 WL 4535216 (Ky. App. Jul. 14, 2023); Hall v. Commonwealth, No. 2023-CA-0639-MR, 2024 WL 4095871 (Ky. App. Sep. 6, 2024).

-2- counsel (IAAC) claim. The IAC claims targeted trial counsel’s (1) failure to

request a jury instruction on lesser included offense(s); (2) failure to preserve issue

regarding KRE3 106; (3) failure to object to a particular witness’s testimony; (4)

failure to investigate phone and computer data; and (5) failure to properly advise

Hall regarding his right to testify. The IAAC claim dealt with appellate counsel’s

failure to obtain the full recording to support Hall’s KRE 106 argument on direct

appeal. Hall requested an evidentiary hearing in a separate pleading. In February

2021, the trial court appointed postconviction counsel with the Department of

Public Advocacy (DPA) to assist Hall with his pursuit for RCr 11.42 relief.

Postconviction counsel eventually filed a supplemental motion and

memorandum in January 2022, which expounded upon one of Hall’s identified

IAC claims and included an additional IAC claim not raised in Hall’s pro se

motion. While the supplemental motion focused the analysis on these two IAC

claims, the opening paragraph expressly incorporated Hall’s pro se arguments and

disavowed any waiver of such. The supplemental motion also included Hall’s

entire pro se motion as an attachment.

The Commonwealth filed its response in April 2022, but only

addressed the two IAC claims briefed in the supplemental filing. A week or so

later, the trial court entered its order denying Hall’s motion for RCr 11.42 relief.

3 Kentucky Rule of Evidence.

-3- The order concluded that “an evidentiary hearing [was] not required on the issues

raised by [Hall’s] Motion,” and similarly addressed only the two IAC claims raised

and briefed by counsel. The order did not make specific reference to the remainder

of Hall’s pro se arguments, and neither Hall nor postconviction counsel moved the

court for additional findings.

In May 2022, Hall, by and through the same postconviction counsel,

filed a notice of appeal, and the case came before this Court for review with

briefing concentrated on the two IAC claims and the denial of an evidentiary

hearing. On July 14, 2023, this Court rendered its unpublished Opinion affirming

the trial court’s order denying RCr 11.42 relief. Hall, 2023 WL 4535216, at *3.

Meanwhile, Hall continued to file other postconviction motions with

the trial court, none of which led to any relief. At some point, another DPA

postconviction attorney assumed representation of Hall. Pertinent to this appeal,

Hall’s new counsel filed a “Motion for Ruling on Unresolved Claims” on July 8,

2024 – almost a year after this Court affirmed the trial court’s denial of Hall’s RCr

11.42 motion. In this new filing, Hall argued that the trial court failed to address

the remaining RCr 11.42 claims raised in his pro se motion originally filed in

September 2020. Following additional briefing and argument by the

Commonwealth and Hall, the trial court denied Hall’s second request for RCr

11.42 relief and an evidentiary hearing by order entered March 3, 2025. In this

-4- order, the trial court addressed all of Hall’s pro se RCr 11.42 claims. The appeal

from that order now follows.

ANALYSIS

On appeal, Hall continues to argue that he is entitled to RCr 11.42

relief and an evidentiary hearing. Generally, “[w]e review a trial court’s denial of

RCr 11.42 relief for an abuse of discretion.” Phon v. Commonwealth, 545 S.W.3d

284, 290 (Ky. 2018) (citing Teague v. Commonwealth, 428 S.W.3d 630, 633 (Ky.

App. 2014)). “‘The test for abuse of discretion is whether the trial judge’s decision

was arbitrary, unreasonable, unfair, or unsupported by sound legal principles.’” Id.

(quoting Foley v. Commonwealth, 425 S.W.3d 880, 886 (Ky. 2014)). In this case,

however, we decline to address the merits of Hall’s current appeal as the time to

raise them has passed.

“The structure provided in Kentucky for attacking the final judgment

of a trial court in a criminal case is not haphazard and overlapping, but is organized

and complete.” Gross v. Commonwealth, 648 S.W.2d 853, 856 (Ky. 1983). “At

each stage the defendant must raise ‘all issues then amenable to review, and

generally issues that either were or could have been raised at one stage will not be

entertained at any later stage.’” Owens v. Commonwealth, 512 S.W.3d 1, 14 (Ky.

App. 2017) (quoting Hollon v. Commonwealth, 334 S.W.3d 431, 437 (Ky. 2010)).

Importantly, subsection (3) of RCr 11.42 provides that when moving to vacate, set

-5- aside, or correct a sentence, “[t]he motion shall state all grounds for holding the

sentence invalid of which the movant has knowledge. Final disposition of the

motion shall conclude all issues that could reasonably have been presented in the

same proceeding.” (Emphasis added.) Under the plain language of RCr 11.42(3),

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Stoker v. Commonwealth
289 S.W.3d 592 (Court of Appeals of Kentucky, 2009)
Fischer v. Fischer
197 S.W.3d 98 (Kentucky Supreme Court, 2006)
McQueen v. Commonwealth
948 S.W.2d 415 (Kentucky Supreme Court, 1997)
Hollon v. Commonwealth
334 S.W.3d 431 (Kentucky Supreme Court, 2011)
Gross v. Commonwealth
648 S.W.2d 853 (Kentucky Supreme Court, 1983)
Foley v. Commonwealth
425 S.W.3d 880 (Kentucky Supreme Court, 2014)
Teague v. Commonwealth
428 S.W.3d 630 (Court of Appeals of Kentucky, 2014)
Mark D. Dean, P.S.C. v. Commonwealth Bank & Trust Co.
434 S.W.3d 489 (Kentucky Supreme Court, 2014)
Commonwealth v. Pollini
437 S.W.3d 144 (Kentucky Supreme Court, 2014)
Owens v. Commonwealth
512 S.W.3d 1 (Court of Appeals of Kentucky, 2017)
Phon v. Com. of Ky.
545 S.W.3d 284 (Missouri Court of Appeals, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Jimmy Hall v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jimmy-hall-v-commonwealth-of-kentucky-kyctapp-2026.