Kenneth Earl Douglas, Jr. v. Commonwealth of Kentucky

Court of Appeals of Kentucky·Decided August 28, 2026·No. 2024-CA-0626·Unpublished

Opinion

RENDERED: AUGUST 28, 2026; 10:00 A.M.

NOT TO BE PUBLISHED

Commonwealth of Kentucky

Court of Appeals

NO. 2024-CA-0626-MR

KENNETH EARL DOUGLAS, JR. APPELLANT

APPEAL FROM NELSON CIRCUIT COURT v. HONORABLE JOSEPH GUINAN BALLARD, JUDGE ACTION NO. 23-CR-00230

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION

AFFIRMING IN PART,

VACATING IN PART, AND REMANDING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; ACREE AND MOYNAHAN, JUDGES.

ACREE, JUDGE: Appellant Kenneth Douglas, Jr. (Kenneth) appeals the Nelson Circuit Court’s order denying his motion to suppress and his various convictions. We affirm in part but vacate Kenneth’s conviction for being a felon in possession of a firearm as a violation of double jeopardy and remand for resentencing.

BACKGROUND

In late June 2023, Kenneth and his cousin, William Joshua Douglas (Josh), were together at Kenneth’s house using methamphetamine. Josh’s girlfriend picked him up later in the evening. Josh left his truck parked at Kenneth’s house. When he returned the next day, chainsaws that were in the truck were missing. He confronted Kenneth who denied any knowledge of the chainsaws.

Josh went to Kenneth’s house on July 4 to inquire once again. That sparked an altercation. Kenneth, holding a 9mm handgun, stated, “I’ll shoot you cuz!” Josh retreated to his truck parked in the driveway. Kenneth fired multiple shots in Josh’s direction, hitting the truck several times but not hitting Josh.

Josh then drove to his mother’s house. Upon arrival, his mother called 911 and officers were dispatched to speak with Josh. While there, officers noted his truck had multiple bullet holes. Josh told officers he had purchased marijuana from Kenneth the previous week, that Kenneth was growing marijuana on the property, and that Kenneth had firearms inside his home.

Deputy Keegan Kirkpatrick and four other officers decided to go to Kenneth’s house to conduct a knock and talk. It was after 11:00 PM. They arrived without sirens or lights. Officers surrounded the house before knocking on several

doors to make contact. Lights inside the home were visible and vehicles were in the driveway. Officers observed two marijuana plants at the rear of the property.

Kenneth opened the side door that led to the basement. An officer directed him to come out with his hands up. Disregarding the officer’s instruction, Kenneth closed the door and went back inside. A call went out for backup. Three minutes later, Kenneth opened the front door and came out with his hands up. He was apprehended and placed in a cruiser. The call for backup was canceled because Kenneth was in custody. Deputy Kirkpatrick testified there was no evidence or information regarding any other person who may be a danger or a risk to the officers’ safety inside the residence.

Deputy Kirkpatrick testified that while Kenneth was in the cruiser, officers performed a “sweep of the home to secure it for a search warrant” because “at that point [he] was planning on applying for a search warrant.” His motivation for seeking a warrant was Josh’s statement he bought drugs from Kenneth a week earlier, Kenneth shot at Josh, there were marijuana plants growing at Kenneth’s house, there were shell casings in the driveway, and he knew Kenneth was a felon. During the sweep, officers found a shotgun, rifle, ammunition, and drug residue in plain view. The affidavit for the search warrant was submitted hours later, the search warrant issued, and the referenced items found during the search.

Kenneth moved to suppress the evidence, arguing the arrest had been achieved outside the home, there was no indicia of a dangerous individual posing a threat inside the home, and the officers lacked requisite probable cause or exigent circumstances to justify the warrantless entry. The court ultimately denied this motion on grounds that the officers had a reasonable suspicion that the home may have harbored an individual who posed a threat, and that the evidence located in the house was subject to inevitable discovery.

Kenneth proceeded to trial and was convicted of possession of a handgun by a convicted felon, possession of a firearm by a convicted felon, possession of a controlled substance (methamphetamine), first-degree wanton endangerment, possession of marijuana, and being a second-degree persistent felony offender. The trial court followed the jury’s recommendation for a total sentence of 13 years’ imprisonment.

STANDARD OF REVIEW

“A trial court’s denial of a motion to suppress is reviewed under a two-prong test.” Rhoton v. Commonwealth, 610 S.W.3d 273, 275 (Ky. 2020). Findings of fact are reviewed “under the clearly erroneous standard” and affirmed if those findings are supported by substantial evidence. Id. at 275–76. Review of the trial court’s application of law to the facts is de novo. Id.

ANALYSIS

I. Trial court did not err in denying Appellant’s suppression motion Kenneth argues the officers exceeded the scope of their purported knock and talk by immediately going to the backyard prior to knocking on any doors. The trial court did not analyze this argument in the body of its order denying the suppression motion. Consideration of the argument is found in a footnote, stating summarily:

Defendant has argued officers had no right to go into the backyard while conducting their knock and talk, but clearly an “immediate risk of danger” exigency existed in this case at the time the officers entered the backyard and they were lawfully in the backyard at the time they viewed the marijuana plants.

(R. at 169–70). No authority is cited for this conclusion. The Commonwealth provides no analysis of Kenneth’s assertion and argument that the officers exceeded the constitutionally permissible scope of the knock and talk.

A succinct statement of the basic rule for knock-and-talk procedures is that “police with legitimate business may enter the areas of the curtilage which are impliedly open to use by the public[,]” and they are free to use their other senses while so doing. Pace v. Commonwealth, 529 S.W.3d 747, 757 (Ky. 2017) (quoting 1 WAYNE R. LAFAVE, SEARCH AND SEIZURE: A TREATISE ON THE FOURTH AMENDMENT § 2.3(c) (4th ed. 2007)).

We believe Kenneth’s argument does not wholly lack merit.

However, we decline analyzing the issue or ruling either way. Rather, we will presume the officers did violate the Fourth Amendment by the way they conducted the knock and talk. To be clear, we presume so exclusively for the purpose of addressing the trial court’s alternative basis for denying the suppression motion, the “inevitable discovery rule.”

We agree with the trial court that “[e]ven assuming the protective sweep of the house was a violation of [Kenneth’s] constitutional rights, law enforcement officers would have still located the evidence in the house as they were going to obtain a search warrant to search the house.” (R. at 169).

The inevitable discovery rule was adopted by the United States Supreme Court to “permit admission of evidence unlawfully obtained upon proof by a preponderance of the evidence that the same evidence would have been inevitably discovered by lawful means.” Hughes v. Commonwealth, 87 S.W.3d 850, 853 (Ky. 2002) (citing Nix v. Williams, 567 U.S. 431, 444, 104 S. Ct. 2501, 2509, 81 L. Ed. 2d 377 (1984)). “The rationale behind the rule is that it does not put the police in a better position than they would have been absent the error, but only puts them in the same position as if there had been no unlawful search.” Commonwealth v. Elliott, 714 S.W.2d 494, 496 (Ky. App. 1986) (citing Nix, 467 U.S. at 443, 104 S. Ct. at 2508–09).

Officers were privy to ample information to support a search warrant.

The trial court summarized the information as follows:

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Kenneth Earl Douglas, Jr. v. Commonwealth of Kentucky, (Ky. Ct. App. 2026).

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