Katherine Morrison v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedSeptember 26, 2025
Docket2024-CA-0613
StatusUnpublished

This text of Katherine Morrison v. Commonwealth of Kentucky (Katherine Morrison 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
Katherine Morrison v. Commonwealth of Kentucky, (Ky. Ct. App. 2025).

Opinion

RENDERED: SEPTEMBER 26, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-0613-MR

KATHERINE MORRISON APPELLANT

APPEAL FROM TAYLOR CIRCUIT COURT v. HONORABLE SAMUEL TODD SPALDING, JUDGE ACTION NO. 21-CR-00286

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: COMBS, EASTON, AND LAMBERT, JUDGES.

EASTON, JUDGE: Appellant, Katherine Morrison (“Morrison”), pro se,

challenges an Order of the Taylor Circuit Court, which denied her motion pursuant

to CR1 60.02(f). Although the judgment in her case ultimately resulted from a

guilty plea, Morrison complains that her attorney at her jury trial prior to her guilty

1 Kentucky Rules of Civil Procedure. plea was ineffective. Because her subsequent guilty plea was voluntarily made, we

affirm.

FACTUAL AND PROCEDURAL HISTORY

Morrison was indicted for the murder of John Berry. Morrison shot

Berry during the late-night hours of September 24, 2021. A jury trial was

conducted on August 15 and 16, 2022. The jury found Morrison guilty of First-

Degree Manslaughter and recommended a sentence of 15 years’ imprisonment.

During closing arguments, the Commonwealth made references to

statements Morrison made to police during her initial interview. Some of these

statements were not familiar to Morrison’s counsel. The day after the trial, the

parties discovered that a 22-minute portion of Morrison’s recorded interview was

never disclosed to defense counsel contrary to RCr2 7.24(1). Morrison then filed a

motion for a new trial. Given the circumstances, the circuit court granted

Morrison’s motion for new trial without hesitation.

On August 31, 2022, two weeks after the trial, Morrison and the

Commonwealth announced to the circuit court that they had reached an agreement:

Morrison would plead guilty to First-Degree Manslaughter, with the same sentence

of 15 years, but with an important stipulation from the Commonwealth that the

2 Kentucky Rules of Criminal Procedure.

-2- domestic violence exception provided by KRS3 439.34014 and KRS 439.34025

would apply. This changed Morrison’s parole eligibility from an 85% requirement

to a 20% requirement. After even more time to consider the offer, on September 6,

2022, Morrison entered her guilty plea pursuant to the Commonwealth’s offer.

The circuit court accepted the plea and sentenced Morrison on October 18, 2022.

In March 2024, Morrison filed a pro se “Motion for Sentence

Modification Pursuant to CR 60.02(f).” In this motion, Morrison again claimed

she suffered domestic violence at the hands of the decedent. She alleged her trial

counsel failed to obtain an expert witness for the trial about domestic violence and

failed to present mitigation evidence during the penalty phase of the trial. She

requested that “her Manslaughter conviction and sentence of fifteen (15) years to

be amended to a lesser charge and the minimum sentence permitted.” The circuit

court denied the motion, finding that Morrison “has asserted no grounds in her

motion to justify the relief sought.” This appeal follows.

3 Kentucky Revised Statutes. 4 KRS 439.3401(4): “A violent offender with a sentence of a term of years shall not be released on probation, shock probation, parole, conditional discharge, or other form of early release until he or she has served at least eighty-five percent (85%) of the sentence imposed . . . (6) This section shall not apply to a person who has been determined by a court to have been a victim of domestic violence or abuse pursuant to KRS 533.060 with regard to the offenses involving the death of the victim or serious physical injury to the victim.” 5 “Exemption from KRS 439.3401 for victims of domestic violence and abuse; procedures; effect . . . (8) The effect of granting a motion under this section is to remove the status as a violent offender for the offense for which the motion was filed and permit the offender to be eligible for parole in the manner specified in KRS 439.340.”

-3- STANDARD OF REVIEW

While Morrison argues ineffective assistance of counsel which is

properly addressed by an RCr 11.42 motion, she filed a CR 60.02(f) motion6 in the

circuit court. The standard of review for both RCr 11.42 and CR 60.02 motions is

abuse of discretion. Teague v. Commonwealth, 428 S.W.3d 630, 633 (Ky. App.

2014); Foley v. Commonwealth, 425 S.W.3d 880, 886 (Ky. 2014). “The test for

abuse of discretion is whether the trial judge’s decision was arbitrary,

unreasonable, unfair, or unsupported by sound legal principles.” Commonwealth v.

English, 993 S.W.2d 941, 945 (Ky. 1999).

ANALYSIS

Morrison waived any claim of ineffective assistance of counsel. The

rules for post-conviction review are clear. Review is first by direct appeal, then a

motion under RCr 11.42, and then a motion under CR 60.02. Gross v.

Commonwealth, 648 S.W.2d 853 (Ky. 1983). CR 60.02 may not be used to

address issues which properly could have been raised in an RCr 11.42 motion.

McQueen v. Commonwealth, 948 S.W.2d 415, 416 (Ky. 1997). Regardless,

whether Morrison’s argument about ineffective counsel during her trial may now

be considered under CR 60.02 does not affect the ultimate outcome of her appeal.

6 Morrison’s motion is self-verified rather than notarized and thus does not satisfy RCr 11.42(2). Fraser v. Commonwealth, 59 S.W.3d 448, 452 (Ky. 2001).

-4- Morrison focuses only on the performance of her counsel during trial.

She believes she would have received a shorter sentence had sufficient evidence of

domestic violence been presented to the jury. But Morrison also could have

received a longer sentence at an 85% parole eligibility at a new trial. In any event,

the possible result of a trial is not the issue.

The jury verdict was set aside by the circuit court. “[T]he granting of

a new trial places the parties in the same position as if no trial had been had.”

Foster v. Commonwealth, 348 S.W.2d 759, 759 (Ky. 1961). Any error which may

have occurred during Morrison’s trial was rendered moot by the circuit court’s

granting of her motion for a new trial. We must look only at the voluntariness of

her subsequent guilty plea.

Morrison entered a guilty plea to First-Degree Manslaughter, applying

the exemption of KRS 439.3402. This resolution included a recognition of the

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Related

McMann v. Richardson
397 U.S. 759 (Supreme Court, 1970)
Fraser v. Commonwealth
59 S.W.3d 448 (Kentucky Supreme Court, 2001)
Foster v. Commonwealth
348 S.W.2d 759 (Court of Appeals of Kentucky (pre-1976), 1961)
McQueen v. Commonwealth
948 S.W.2d 415 (Kentucky Supreme Court, 1997)
Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
Gross v. Commonwealth
648 S.W.2d 853 (Kentucky Supreme Court, 1983)
Jackson v. Commonwealth
363 S.W.3d 11 (Kentucky Supreme Court, 2012)
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)

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