Joseph Franklin v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedOctober 24, 2024
Docket2023-SC-0417
StatusUnpublished

This text of Joseph Franklin v. Commonwealth of Kentucky (Joseph Franklin 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.

Bluebook
Joseph Franklin v. Commonwealth of Kentucky, (Ky. 2024).

Opinion

IMPORTANT NOTICE NOT TO BE PUBLISHED OPINION

THIS OPINION IS DESIGNATED “NOT TO BE PUBLISHED.” PURSUANT TO THE RULES OF CIVIL PROCEDURE PROMULGATED BY THE SUPREME COURT, RAP 40(D), THIS OPINION IS NOT TO BE PUBLISHED AND SHALL NOT BE CITED OR USED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE; HOWEVER, UNPUBLISHED KENTUCKY APPELLATE DECISIONS, RENDERED AFTER JANUARY 1, 2003, MAY BE CITED FOR CONSIDERATION BY THE COURT IF THERE IS NO PUBLISHED OPINION THAT WOULD ADEQUATELY ADDRESS THE ISSUE BEFORE THE COURT. OPINIONS CITED FOR CONSIDERATION BY THE COURT SHALL BE SET OUT AS AN UNPUBLISHED DECISION IN THE FILED DOCUMENT AND A COPY OF THE ENTIRE DECISION SHALL BE TENDERED ALONG WITH THE DOCUMENT TO THE COURT AND ALL PARTIES TO THE ACTION. RENDERED: OCTOBER 24, 2024 NOT TO BE PUBLISHED

Supreme Court of Kentucky 2023-SC-0417-MR

JOSEPH FRANKLIN APPELLANT

ON APPEAL FROM HOPKINS CIRCUIT COURT V. HONORABLE CHRISTOPHER BRYAN OGLESBY, JUDGE NO. 21-CR-00413

COMMONWEALTH OF KENTUCKY APPELLEE

MEMORANDUM OPINION OF THE COURT

AFFIRMING

Joseph Franklin was found guilty by a Hopkins County jury of various

crimes including first- and second-degree wanton endangerment, tampering

with physical evidence, first-degree fleeing and evading (two counts), and of

being a persistent felony offender in the first degree (PFO I). As recommended

by the jury, Franklin was sentenced to twenty years in prison. On appeal, he

claims that (1) KRE 1 404(b) evidence was improperly admitted at trial, (2) the

trial court erred by denying a directed verdict on the tampering with physical

evidence charge, as well as the fleeing and evading on foot charge, and (3)

double jeopardy bars the conviction for one of the fleeing and evading counts.

Upon review, we affirm.

1 Kentucky Rule of Evidence. FACTUAL AND PROCEDURAL BACKGROUND

In August 2021, Franklin was staying at Jeremy Hammack’s home.

Hammack was a confidential informant and he called crime stoppers and told

them that Franklin had an active warrant for his arrest. A surveillance team

started watching Hammack’s home. On the day of his arrest, Franklin left the

residence in a maroon truck. The surveillance team followed Franklin to

Joshua Scott’s residence. Scott was a known methamphetamine trafficker.

When Franklin left Scott’s residence, officers in marked vehicles were

waiting to initiate a traffic stop of Franklin. Sergeant Bailey activated his

emergency equipment and tried to stop Franklin. Franklin fled and a pursuit

ensued. The pursuit lasted about fifteen minutes and ended when Franklin

crashed the truck.

During the pursuit, Franklin drove 70 m.p.h. in a 35 m.p.h. zone, passed

a school bus, and disregarded multiple stop signs. The officers observed

Franklin throwing something out of the passenger window. Franklin wrecked

the truck near the White City Wildlife Management Area and fled on foot.

Multiple officers searched the area for over two hours trying to find Franklin.

John Slaton’s family owned property that connected to the wildlife area.

Slaton, saw Franklin, sweaty and muddy, walking on the family property.

Slaton knew that law enforcement was looking for Franklin and offered him a

ride in the bed of his pickup truck. On the way, Slaton called law enforcement

and they arrived to take Franklin into custody. Franklin was arrested at 6:30

p.m., about four hours after the pursuit began.

2 During the pursuit, Sergeant Bailey radioed that Franklin had thrown a

bag out the passenger window. Major Young, who was following the pursuit,

stopped to look on the side of the road for the bag. Major Young found a bag

which contained nine grams of methamphetamine.

Detective Ross obtained a search warrant for the truck Franklin wrecked

and left behind. Eighteen grams of methamphetamine, scales, and money were

found on the passenger floorboard.

A Hopkins County grand jury indicted Franklin on sixteen counts related

to his arrest. At trial, in addition to finding Franklin guilty of being a PFO, the

jury found him guilty of the following offenses: first-degree trafficking in a

controlled substance (methamphetamine, more than 2 grams); first-degree

wanton endangerment; tampering with physical evidence; first-degree fleeing

and evading police (motor vehicle); first-degree fleeing and evading police (on

foot); first-degree criminal mischief; first-degree possession of a controlled

substance (methamphetamine); second-degree wanton endangerment;

possession with intent to use drug paraphernalia; speeding; reckless driving;

and disregard of at traffic control device (two counts). 2 As recommended by the

2 The jury recommended for each offense the following sentence or fine:

1) First-degree trafficking of methamphetamine: 10 years enhanced to 20 years. 2) First-degree wanton endangerment: 5 years enhanced to 20 years. 3) Tampering with physical evidence: 5 years enhanced to 15 years. 4) First-degree fleeing/evading police (motor vehicle): 5 years enhanced to 15 years. 5) First-degree fleeing/evading police (on foot): 5 years enhanced to 15 years. 6) First-degree criminal mischief: 5 years enhanced to 10 years. 7) First-degree possession of methamphetamine: 3 years in prison. 8) Second-degree wanton endangerment: 12 months in prison. 9) Possession with intent to use drug paraphernalia: 12 months in prison. 10) Speeding, recommended fine: $100.00. 11) Reckless driving, recommended fine: $100.00. 3 jury, the trial court sentenced Franklin to serve concurrent sentences, a total

of twenty years in prison. This appeal followed.

Additional facts pertinent to Franklin’s claims on appeal are set forth

below.

ANALYSIS

I. The trial court did not abuse its discretion by denying a mistrial.

Franklin claims that KRE 404(b) was violated when Detective Dozer, who

was part of the surveillance team, testified that he recognized Franklin from a

recent jail photo. Because KRE 404(b) was not mentioned by Franklin as a

basis for granting his motion for a mistrial, the Commonwealth views the claim

as unpreserved. However, we view the KRE 404(b) complaint to be apparent

from the context and defense counsel’s reference to the pretrial motion in limine

to exclude testimony relating to Franklin’s prior convictions as sufficiently

preserving the issue.

During trial, Detective Dozer testified that he did not know Franklin but

had seen social media pictures. As the detective was saying he had also seen “I

think recent jail, or previous, jail photos,” defense counsel objected. Defense

counsel argued that the jury heard the prejudicial “previous jail pictures”

testimony and moved for a mistrial. Although the trial court acknowledged

that it did not hear the testimony, the trial court offered to admonish the jury.

Defense counsel declined the admonition, stating she did not believe it would

cure the error and did not want to draw further attention to the testimony.

12) Disregard of a traffic control device, recommended fine for each count: $100.00.

4 Defense counsel reviewed the video testimony and again renewed her motion

for a mistrial, arguing that the jury heard Detective Dozer say “jail” twice and

“photos” once. The trial court again denied the motion.

“[A] mistrial is an extreme remedy and should be resorted to only when

there is a fundamental defect in the proceedings and there is a ‘manifest

necessity for such an action.’” Woodard v.

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

Related

Blockburger v. United States
284 U.S. 299 (Supreme Court, 1931)
Woodard v. Commonwealth
147 S.W.3d 63 (Kentucky Supreme Court, 2004)
Brewer v. Commonwealth
206 S.W.3d 343 (Kentucky Supreme Court, 2006)
Welch v. Commonwealth
235 S.W.3d 555 (Kentucky Supreme Court, 2007)
Welborn v. Commonwealth
157 S.W.3d 608 (Kentucky Supreme Court, 2005)
Gould v. Charlton Co., Inc.
929 S.W.2d 734 (Kentucky Supreme Court, 1996)
Commonwealth v. Benham
816 S.W.2d 186 (Kentucky Supreme Court, 1991)
Maxie v. Commonwealth
82 S.W.3d 860 (Kentucky Supreme Court, 2002)
Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
Cardine v. Commonwealth
283 S.W.3d 641 (Kentucky Supreme Court, 2009)
Johnson v. Commonwealth
105 S.W.3d 430 (Kentucky Supreme Court, 2003)
Shepherd v. Commonwealth
251 S.W.3d 309 (Kentucky Supreme Court, 2008)
Martin v. Commonwealth
207 S.W.3d 1 (Kentucky Supreme Court, 2006)
Sherroan v. Commonwealth
142 S.W.3d 7 (Kentucky Supreme Court, 2004)
Bray v. Commonwealth
68 S.W.3d 375 (Kentucky Supreme Court, 2002)
Acosta v. Commonwealth
391 S.W.3d 809 (Kentucky Supreme Court, 2013)
Kiper v. Commonwealth
399 S.W.3d 736 (Kentucky Supreme Court, 2012)
Bartley v. Commonwealth
400 S.W.3d 714 (Kentucky Supreme Court, 2013)

Cite This Page — Counsel Stack

Bluebook (online)
Joseph Franklin v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-franklin-v-commonwealth-of-kentucky-ky-2024.