John W. Ault v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedApril 10, 2026
Docket2025-CA-0004
StatusUnpublished

This text of John W. Ault v. Commonwealth of Kentucky (John W. Ault 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
John W. Ault v. Commonwealth of Kentucky, (Ky. Ct. App. 2026).

Opinion

RENDERED: APRIL 10, 2026; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2025-CA-0004-MR

JOHN AULT APPELLANT

APPEAL FROM FAYETTE CIRCUIT COURT v. HONORABLE THOMAS L. TRAVIS, JUDGE ACTION NO. 22-CR-00683

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

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

THOMPSON, CHIEF JUDGE: John W. Ault (Appellant) appeals from a

judgment of the Fayette Circuit Court arising from a conditional guilty plea to one

count each of sexual abuse in the first degree and incest.1 He argues that the circuit

court erred in denying his request to withdraw his guilty plea, and in its disposition

1 Kentucky Revised Statutes (KRS) 510.110 and KRS 530.020. of several rulings entered prior to and after the plea. After careful review, we find

no error and affirm the judgment on appeal.

FACTS AND PROCEDURAL HISTORY

On August 2, 2022, a Fayette County grand jury indicted Appellant on

four counts of sexual abuse in the first degree against victim “G.R.,” and one count

each of sexual abuse in the first degree, sodomy in the first degree, and incest

against victim “A.F.”2 G.R. is Appellant’s step-granddaughter, who was

approximately six years old in 2019 when the offenses began. She alleged that

they continued for three years. A.F. is Appellant’s biological daughter, who is now

approximately 39 years old. She alleged that the offenses committed against her

by Appellant occurred in the mid-1990s, when she was between seven and nine

years old. The explicit sexual nature of these offenses is detailed in the circuit

court record.

The matter proceeded in Fayette Circuit Court for approximately two

years, during which time Appellant moved to represent himself. The circuit court

granted the motion, and licensed counsel was retained to oversee Appellant’s self-

representation. Appellant filed several motions, including motions for a bill of

particulars, for discovery, for access to resources, to continue the trial, and to have

a victim evaluated.

2 We will use the victims’ initials as these charges involve sexual offenses against children.

-2- Shortly before trial, Appellant entered a conditional guilty plea to one

count of sexual abuse in the first degree and one count of incest, reserving the right

to appeal all pretrial motions. Per the plea offer, the Commonwealth

recommended a sentence of ten years in prison.

Shortly thereafter, Appellant moved to withdraw his guilty plea. In

support of the motion, Appellant argued that his hybrid counsel failed to advise

him regarding how long the appellate process would take and how the possible

death of witnesses could affect a trial. The circuit court denied the motion, and

sentenced Appellant to ten years in prison in accordance with the Commonwealth’s

recommendation. This appeal followed.3

ARGUMENTS AND ANALYSIS

Appellant first argues that the charges in the indictment involving

A.F. should have been severed from the charges involving G.R., and that the

Fayette Circuit Court erred in failing to so rule. Citing Peacher v. Commonwealth,

391 S.W.3d 821, 837 (Ky. 2013), Appellant argues that for separate offenses to be

tried together, there must be a sufficient nexus between them to justify a single

3 The Commonwealth questions Appellant’s preservation of the pretrial issues that he raises on appeal because he did not specify at the time of the guilty plea which issues he was reserving the right to appeal. The Commonwealth notes that Appellant entered a guilty plea conditioned on his “right to appeal all pretrial motions,” which number almost 100 filings. We have chosen to ignore the deficiency in preservation, if any, and proceed with the review. K.M.J. v. Cabinet for Health and Family Services, 503 S.W.3d 193, 196 (Ky. App. 2016).

-3- trial. He asserts that this nexus must be grounded on a logical relationship between

the offenses, a single transaction or occurrence, or a common scheme.

Appellant maintains that there is no sufficient connection between the

charges involving A.F. and G.R. to form a nexus between them sufficient to justify

a single trial. He notes that the allegations made by A.F. included digital

penetration, ejaculation, and professions of love. In contrast, G.R. alleged no

penetration or ejaculation, and Appellant told her she was a terrible person and

deserved the things he was doing to her. Appellant also points out that the

allegations made by A.F. centered on acts occurring between 1992 and 1994,

whereas those made by G.R. involved acts occurring between 2016 and 2019.

Based on the lack of a proper nexus required to justify a single trial, Appellant

argues that the circuit court erred in denying his motion to sever the charges.

Kentucky Rules of Criminal Procedure (RCr) 6.18 states that,

[t]wo (2) or more offenses may be charged in the same complaint or two (2) or more offenses whether felonies or misdemeanors, or both, may be charged in the same indictment or information in a separate count for each offense, if the offenses are of the same or similar character or are based on the same acts or transactions connected together or constituting parts of a common scheme or plan.

This rule exists in the interest of judicial economy and for the efficiency of

avoiding multiple trials. Garrett v. Commonwealth, 534 S.W.3d 217, 223 (Ky.

2017). In contrast, RCr 8.31 provides that,

-4- [i]f it appears that a defendant or the Commonwealth is or will be prejudiced by a joinder of offenses or of defendants in an indictment, information, complaint or uniform citation or by joinder for trial, the court shall order separate trials of counts, grant separate trials of defendants or provide whatever other relief justice requires. A motion for such relief must be made before the jury is sworn or, if there is no jury, before any evidence is received. No reference to the motion shall be made during the trial. In ruling on a motion by a defendant for severance the court may order the attorney for the Commonwealth to deliver to the court for inspection in camera any statements or confessions made by the defendants that the Commonwealth intends to introduce in evidence at the trial.

A trial judge has broad discretion in ruling on a motion for separate

trials, and that determination will not be overturned on appeal unless an abuse of

discretion is shown. Elam v. Commonwealth, 500 S.W.3d 818, 822 (Ky. 2016). It

abuses its discretion if its decision was “arbitrary, unreasonable, unfair, or

unsupported by sound legal principles.” Commonwealth v. English, 993 S.W.2d

941, 945 (Ky. 1999). “A criminal defendant is not entitled to severance unless he

positively shows prior to trial that joinder would be unduly prejudicial.” Cohron v.

Commonwealth, 306 S.W.3d 489, 493 (Ky. 2010) (footnote and citation omitted).

Finally, “[t]rial judges are vested with great discretion in determining whether to

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Related

Anderson v. Commonwealth
231 S.W.3d 117 (Kentucky Supreme Court, 2007)
Rice v. Commonwealth
387 S.W.2d 4 (Court of Appeals of Kentucky (pre-1976), 1965)
Cohron v. Commonwealth
306 S.W.3d 489 (Kentucky Supreme Court, 2010)
Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
Rigdon v. Commonwealth
144 S.W.3d 283 (Court of Appeals of Kentucky, 2004)
Bell v. Commonwealth
875 S.W.2d 882 (Kentucky Supreme Court, 1994)
Wolbrecht v. Commonwealth
955 S.W.2d 533 (Kentucky Supreme Court, 1997)
Paul T. Elam Jr v. Commonwealth of Kentucky
500 S.W.3d 818 (Kentucky Supreme Court, 2016)
Jerard Garrett v. Commonwealth of Kentucky
534 S.W.3d 217 (Kentucky Supreme Court, 2017)
Commonwealth v. Grider
390 S.W.3d 803 (Court of Appeals of Kentucky, 2012)
Peacher v. Commonwealth
391 S.W.3d 821 (Kentucky Supreme Court, 2013)
Cherry v. Commonwealth
458 S.W.3d 787 (Kentucky Supreme Court, 2015)
K.M.J. v. Cabinet for Health & Family Services
503 S.W.3d 193 (Court of Appeals of Kentucky, 2016)
Whaley v. Commonwealth
567 S.W.3d 576 (Missouri Court of Appeals, 2019)

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John W. Ault v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-w-ault-v-commonwealth-of-kentucky-kyctapp-2026.