Keith Bradley v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedAugust 30, 2024
Docket2022-CA-0977
StatusUnpublished

This text of Keith Bradley v. Commonwealth of Kentucky (Keith Bradley 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
Keith Bradley v. Commonwealth of Kentucky, (Ky. Ct. App. 2024).

Opinion

RENDERED: AUGUST 30, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-0975-MR

KEITH BRADLEY APPELLANT

APPEAL FROM WARREN CIRCUIT COURT v. HONORABLE STEVE ALAN WILSON, JUDGE ACTION NO. 19-CR-00579

COMMONWEALTH OF KENTUCKY APPELLEE

AND

NO. 2022-CA-0977-MR

APPEAL FROM WARREN CIRCUIT COURT v. HONORABLE STEVE ALAN WILSON, JUDGE ACTION NO. 18-CR-00510

COMMONWEALTH OF KENTUCKY APPELLEE OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, KAREM, AND LAMBERT, JUDGES.

ACREE, JUDGE: Appellant, Keith Bradley, appeals the Warren Circuit Court’s

May 25, 2022 Judgment and Sentence on Plea of Guilty. Bradley alleges (1) he

was denied both his constitutional and statutory rights to a speedy trial; and (2) the

circuit court erred in concluding Bradley was not partially exempt from

prosecution based on Kentucky’s “Good Samaritan Law”, KRS1 218A.133. We

affirm.

BACKGROUND

On December 18, 2017, Bradley was stopped for speeding in Warren

County. Bradley had an active warrant and was arrested. During a search incident

to his arrest, the police discovered on his person suspected methamphetamine and a

gabapentin pill – a drug for which Bradley did not have a prescription. Suspected

cocaine and more suspected methamphetamine were discovered in Bradley’s truck.

Bradley was released on bond. Bradley was indicted for tampering with physical

evidence, two counts of first-degree possession of a controlled substance, and

driving under the influence.

1 Kentucky Revised Statutes.

-2- Two months later, on February 28, 2018, Bradley was with a friend,

Tessa Reece, when she began to overdose. Bradley asked a neighbor to call 911

while he stayed with Reece. Paramedics were unable to save Reece. Bradley

admitted to the police that methamphetamine was in his truck, and he was arrested.

Bradley was indicted on charges of second-degree manslaughter, first-degree

trafficking in a controlled substance, possession of drug paraphernalia, and first-

degree persistent felony offender.

Bradley’s two cases were consolidated. He pleaded not guilty to all

charges. Bradley and the Commonwealth began negotiating an Alford2 plea and

negotiations continued until May 13, 2019. A pretrial conference was set for June

17, 2019. For unknown reasons, the circuit court continued the trial until July 22,

2020 and scheduled a pretrial conference for June 22, 2020. On March 20, 2020,

the parties, by agreement, rescheduled the pretrial conference for July 6, 2020.

Bradley filed a pro se motion to dismiss in June 2020. Apparently,

Bradley’s appointed counsel declined to file the motion on Bradley’s behalf.

Bradley argued KRS 218A.133 – commonly called the “Good Samaritan Law” –

exempted him from prosecution for the charges stemming from Reece’s death.

Bradley wanted to be present at the hearing on the motion, which resulted in

2 Under North Carolina v. Alford, a defendant is permitted to acknowledge the strength of the evidence against him and enter a guilty plea while maintaining his innocence. 400 U.S. 25, 36-37, 91 S. Ct. 160, 167, 27 L. Ed. 2d 162 (1970).

-3- another continuance of the pretrial conference and trial. The pretrial conference

was rescheduled for September 9, 2020, and the trial was continued to December

15, 2020. The trial did not take place in December 2020, and the Commonwealth

acknowledges that it “is not clear” why the circuit court did not hold the trial.

Bradley filed a second motion to dismiss in March of 2021, again

relying on KRS 218A.133. In a letter accompanying the motion, Bradley refiled

the motion because circuit court staff told him that there was no record of his

original motion. The circuit court scheduled status conferences for April 26, June

22, and August 23, 2021.

On August 9, 2021, Bradley filed his speedy trial motion. The circuit

court considered the motion at the previously scheduled August 23, 2021 status

conference. The circuit court scheduled another pretrial conference for October

18, 2021, and set trial for November 3, 2021. The trial was continued to

November 12. Again, the trial did not take place on that date.

Instead of conducting the trial, the circuit court considered Bradley’s

motion to dismiss. The circuit court granted the motion as to Bradley’s possession

charge but denied the motion as to his trafficking charge. Yet again, the circuit

court scheduled a pretrial conference for March 8, 2022, and scheduled trial for

July 12, 2022.

-4- Bradley filed a third motion to dismiss on February 14, 2022, arguing

the Commonwealth failed to prosecute his case. He argued the case should be

dismissed because his speedy trial motion was still pending, and the

Commonwealth had taken no action in response to the motion in more than 180

days.

The circuit court considered Bradley’s arguments on his motion to

dismiss for failure to prosecute at the March 8, 2022 pretrial conference. Bradley

argued his original case had been pending for three years and nine months, that his

second case had been pending for two years and nine months, and that his speedy

trial motion had been pending for seven months. He acknowledged that in-person

court proceedings had been suspended for a year due to COVID. The circuit court

denied Bradley’s motion, noting that COVID-related delays and a prosecutor’s

injury provided just cause for the delay.

Bradley entered his Alford plea on May 23, 2022, pleading guilty to

first-degree possession of a controlled substance, driving under the influence, first-

degree wanton endangerment, and first-degree trafficking in a controlled

substance. Bradley received a total sentence of eighteen years of incarceration.

On his motion to enter guilty plea, Bradley handwrote: “does not waive right to

appeal pretrial motions.” This is the only reference to preservation of his right to

appeal on any documents relating to his plea, and the circuit court’s order on

-5- Bradley’s guilty plea explicitly states that Bradley understood he waived both his

right to appeal and his right to a speedy trial. Bradley now appeals.

ANALYSIS

I. Preservation of Right to Appeal

We must first address the Commonwealth’s contention that Bradley

waived his right to appeal by entering his guilty plea, despite his motion to enter

guilty plea reflecting Bradley’s intention to the contrary. The Commonwealth

argues that no order or other document of the circuit court reflects that Bradley

pleaded guilty on the condition he would be able to appeal the circuit court’s

rulings on his pretrial motions. Indeed, the circuit court’s order explicitly states

otherwise. The Commonwealth argues Bradley’s handwritten amendment to his

motion was insufficient to preserve Bradley’s right to appeal.

This issue arose in Dickerson v. Commonwealth, in which the

Commonwealth argued a defendant, Dickerson, failed to preserve his right to

appeal. 278 S.W.3d 145, 148 (Ky. 2009). There, too, “nothing in the final

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Related

North Carolina v. Alford
400 U.S. 25 (Supreme Court, 1970)
Barker v. Wingo
407 U.S. 514 (Supreme Court, 1972)
Doggett v. United States
505 U.S. 647 (Supreme Court, 1992)
MPM Financial Group, Inc. v. Morton
289 S.W.3d 193 (Kentucky Supreme Court, 2009)
Dickerson v. Commonwealth
278 S.W.3d 145 (Kentucky Supreme Court, 2009)
Dunaway v. Commonwealth
60 S.W.3d 563 (Kentucky Supreme Court, 2001)
Tamme v. Commonwealth
973 S.W.2d 13 (Kentucky Supreme Court, 1998)
Whittaker v. McClure
891 S.W.2d 80 (Kentucky Supreme Court, 1995)
Stacy v. Commonwealth
396 S.W.3d 787 (Kentucky Supreme Court, 2013)
Darcy v. Commonwealth
441 S.W.3d 77 (Kentucky Supreme Court, 2014)
Goben v. Commonwealth
503 S.W.3d 890 (Kentucky Supreme Court, 2016)
Commonwealth v. Kenley
516 S.W.3d 362 (Court of Appeals of Kentucky, 2017)
Henderson v. Commonwealth
563 S.W.3d 651 (Missouri Court of Appeals, 2018)

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Keith Bradley v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/keith-bradley-v-commonwealth-of-kentucky-kyctapp-2024.