Joseph W Daugherty v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedMay 8, 2026
Docket2025-CA-0134
StatusPublished

This text of Joseph W Daugherty v. Commonwealth of Kentucky (Joseph W Daugherty 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
Joseph W Daugherty v. Commonwealth of Kentucky, (Ky. Ct. App. 2026).

Opinion

RENDERED: MAY 8, 2026; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2025-CA-0134-MR

JOSEPH W. DAUGHERTY APPELLANT

APPEAL FROM LYON CIRCUIT COURT v. HONORABLE JAMES R. REDD, III, JUDGE ACTION NO. 24-CR-00020

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: CETRULO, A. JONES, AND TAYLOR, JUDGES.

TAYLOR, JUDGE: Joseph W. Daugherty brings this appeal from a January 7,

2025, Judgment and Sentence on Plea of Not Guilty of the Lyon Circuit Court

upon a jury verdict finding him guilty upon two counts of third-degree assault and

with being a second-degree persistent felony offender, sentencing him to a total of

eighteen-years’ imprisonment. We affirm.

Daugherty was an inmate at the Kentucky State Penitentiary and was

placed in the restrictive housing unit. On May 22, 2023, Cassidy Parks, a licensed practical nurse, and Devin Canup, a corrections officer, went to Daugherty’s cell in

order for Parks to give Daugherty medication. Officer Canup opened the cell’s

tray slot, whereupon Daugherty threw liquid feces from a cup toward Parks and

Canup. The feces landed upon Parks’ clothing, hair, eyes, and mouth and upon

Canup’s pants and shoes.

Daugherty was indicted upon two counts of third-degree assault and

with being a persistent felony offender (PFO) in the second degree.1 A jury trial

ensued. The jury found Daugherty guilty of third-degree assault upon nurse Parks

and of third-degree assault upon officer Canup and with being a PFO in the second

degree. The jury recommended eight-years’ imprisonment for the assault of

officer Canup (enhanced by PFO) and ten-years’ imprisonment for the assault of

nurse Parks (enhanced by PFO), to be served consecutively for a total of eighteen-

years’ imprisonment. By Judgment and Sentence on Plea of Not Guilty entered on

January 7, 2025, the circuit court sentenced Daugherty to a total of eighteen-years’

imprisonment. This appeal follows.

Standard of Review

Our standard of review when ruling on a directed verdict is well-

established:

1 Joseph W. Daugherty was originally indicted for being a persistent felony offender in the first degree; however, the Commonwealth amended the charge to being a persistent felony offender in the second degree.

-2- [T]he trial court must draw all fair and reasonable inferences from the evidence in favor of the Commonwealth. If the evidence is sufficient to induce a reasonable juror to believe beyond a reasonable doubt that the defendant is guilty, a directed verdict should not be given. For the purpose of ruling on the motion, the trial court must assume that the evidence for the Commonwealth is true, but reserving to the jury questions as to the credibility and weight to be given to such testimony.

Commonwealth v. Benham, 816 S.W.2d 186, 187 (Ky. 1991); see also Evans v.

Commonwealth, 544 S.W.3d 166, 168 (Ky. App. 2018). Our review proceeds

accordingly.

Analysis

Daugherty’s primary argument on appeal is that the trial court erred in

failing to grant his motion for directed verdict for the alleged crimes against nurse

Parks and officer Canup. We will address those arguments separately.

1. Nurse Parks

Daugherty contends the circuit court erred by denying his motion for

directed verdict upon the offense of third-degree assault against Parks. Daugherty

claims that Parks was not employed by the facility as required under Kentucky

Revised Statutes (KRS) 508.025(1)(b);2 thus, Daugherty maintains that he was not

2 Kentucky Revised Statutes (KRS) 508.025 was amended effective June 29, 2023, and July 15, 2024. Throughout this Opinion, we shall utilize the version of KRS 508.025(1) effective July 14, 2022, as Daugherty’s criminal conduct took place on May 22, 2023.

-3- guilty of third-degree assault thereunder. Daugherty points out that Parks was

employed by Wellpath, which is a private entity that provides medical staff to

correctional facilities. Daugherty asserts that Wellpath hired and employed Parks

as a nurse to provide medical services at the penitentiary. For these reasons,

Daugherty claims that he was entitled to a direct verdict of acquittal upon the

offense of third-degree assault.

Assault in the third degree is set out in KRS 508.025 and reads in

pertinent part:

(1) A person is guilty of assault in the third degree when the actor:

....

(b) Being a person confined in a detention facility, or a juvenile in a state residential treatment facility or state staff secure facility for residential treatment which provides for the care, treatment, or detention of a juvenile charged with or adjudicated delinquent because of a public offense or as a youthful offender, inflicts physical injury upon or throws or causes feces, or urine, or other bodily fluid to be thrown upon an employee of the facility[.]

Relevant herein, under KRS 508.025(1)(b), a person is guilty of third-degree

assault if he is incarcerated in a “detention facility” and throws feces on “an

employee of the facility.” There are no statutory definitions for the terms

-4- “employee” and “detention facility.” Consequently, these definitions must be

ascertained by common law.

When interpreting a statute, legislative intent is paramount.

Commonwealth v. Plowman, 86 S.W.3d 47, 49 (Ky. 2002). To determine

legislative intent, we simply look to the language utilized in the statute, and unless

ambiguous, words in a statute are given their plain and ordinary meaning. Adams

v. Commonwealth, 599 S.W.3d 752, 754 (Ky. 2019) (citing Stephenson v.

Woodward, 182 S.W.3d 162, 169-70 (Ky. 2005)). The interpretation of a statute

presents an issue of law, and our review is de novo. Commonwealth v. Love, 334

S.W.3d 92, 93 (Ky. 2011).

Under KRS 508.025(1)(b), it is clear that the Kentucky State

Penitentiary is a detention facility thereunder. And, when considering the term

“employee” in KRS 508.025(1)(b), the ordinary meaning is “one employed by

another [usually] for wages or salary.” MERRIAM-WEBSTER’S COLLEGIATE

DICTIONARY at 378 (10th ed. 2002). Employed ordinarily means “to use or engage

the services of” or “to provide with a job that pays wages or a salary.” MERRIAM-

WEBSTER’S COLLEGIATE DICTIONARY at 378 (10th ed. 2002). The preposition

“of,” as found in KRS 508.025(1)(b), ordinarily denotes a relationship of

belonging or association with something. MERRIAM-WEBSTER’S COLLEGIATE

DICTIONARY at 804 (10th ed. 2002).

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Related

Commonwealth v. Benham
816 S.W.2d 186 (Kentucky Supreme Court, 1991)
Covington v. Commonwealth
849 S.W.2d 560 (Court of Appeals of Kentucky, 1992)
Stephenson v. Woodward
182 S.W.3d 162 (Kentucky Supreme Court, 2006)
Commonwealth v. Love
334 S.W.3d 92 (Kentucky Supreme Court, 2011)
Commonwealth v. Plowman
86 S.W.3d 47 (Kentucky Supreme Court, 2002)
Evans v. Com. of Ky.
544 S.W.3d 166 (Court of Appeals of Kentucky, 2018)

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Joseph W Daugherty v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-w-daugherty-v-commonwealth-of-kentucky-kyctapp-2026.