Kimberly Dawn Tucker v. Commonwealth of Kentucky

Court of Appeals of Kentucky·Decided June 26, 2026·No. 2025-CA-0761·Unpublished

Opinion

RENDERED: JUNE 26, 2026; 10:00 A.M.

NOT TO BE PUBLISHED

Commonwealth of Kentucky

Court of Appeals

NO. 2025-CA-0761-MR

KIMBERLY DAWN TUCKER APPELLANT

APPEAL FROM MUHLENBERG CIRCUIT COURT v. HONORABLE BRIAN WIGGINS, JUDGE ACTION NO. 24-CR-00406

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION

AFFIRMING

** ** ** ** **

BEFORE: CETRULO, MCNEILL, AND TAYLOR, JUDGES. CETRULO, JUDGE: Kimberly Dawn Tucker (“Tucker”) appeals her conviction and total sentence of three years of imprisonment for one count of possession of a controlled substance in the first degree (“PCS 1st”) and one count of possession of drug paraphernalia following a jury trial and final sentencing in the Muhlenberg Circuit Court.

BACKGROUND

On the evening of December 4, 2024, Officer Rolley, a deputy with the Muhlenberg County Sheriff’s Office, along with two Kentucky State Police (“KSP”) troopers went to a residence in Muhlenberg County to attempt execution of arrest warrants for Cody Webster (“Webster”). Tucker answered the door and informed the officers that Webster had stayed at the residence but had not been there for some time and was not present. Nevertheless, Tucker consented to the officers’ request to search the residence to confirm Webster’s absence.

The officers entered the first room, which appeared to be a bedroom, and observed an uncapped syringe on the floor. Two officers continued to conduct a protective sweep while another remained with Tucker. After the officers cleared the residence, they returned to speak with Tucker and requested permission to search for contraband. Again, Tucker consented.

In the bedroom, officers found a cut straw inside a purse. The officers believed that the straw was indicative of drug use and that the purse belonged to Tucker. Under the mattress, officers located another syringe and confronted Tucker, who denied ownership and admitted to only using marijuana. Officers continued their search of the bedroom and retrieved a green plastic container from a desk drawer. Upon opening the container, the officers discovered

a small amount of a crystal-like substance, which they suspected to be methamphetamine.

The officers arrested Tucker and asked if she had any contraband on her person. Tucker replied that she did not and was handcuffed and placed in a police cruiser. On the way to the jail, Trooper Broadbent, the transporting officer, noticed Tucker moving around in the backseat. Tucker said that something was in her boot, but she did not know what it was. Trooper Broadbent pulled over to investigate, and when he opened the rear door, he found a hard eyeglass case in the area where Tucker was sitting. A search of the eyeglass case revealed a metal spoon with suspected methamphetamine residue, capped syringes, cotton swabs, and a metal rod.

The green plastic container, its contents, and one of the seized syringes were submitted to the KSP Western Laboratory for analysis. Only the crystalline substance from the green container underwent forensic examination,1 which yielded a positive identification for methamphetamine and a net weight of 0.202 grams.

1 At Tucker’s jury trial, the KSP forensic chemist who performed the analysis testified to the laboratory’s policy of testing a syringe if it was the only item submitted. In the present case, the syringe was not tested.

The grand jury returned an indictment against Tucker, charging her with one count of PCS 1st under KRS2 218A.1415, a class D felony, and one count of possession of drug paraphernalia under KRS 218A.500, a class A misdemeanor. The case proceeded to arraignment in circuit court and eventually to a jury trial on May 1, 2025.

The jury trial took all of one day. The Commonwealth presented the testimonies of a KSP forensic chemist, Trooper Broadbent, and Officer Rolley. Tucker did not testify nor call any defense witnesses during the guilt phase, but she testified on her own behalf during the penalty phase. The jury convicted Tucker on all counts and recommended a sentence of three years’ imprisonment on the charge of PCS 1st.3 On May 19, 2025, the circuit court held a final sentencing hearing, at which it denied Tucker’s request for a probated or alternative sentence and rendered its judgment in accordance with the jury’s verdict and sentencing recommendation. Tucker appealed.

ANALYSIS

In her direct appeal to this Court, Tucker argues: (1) the circuit court should have granted a mistrial following the prosecutor’s reference during voir dire

2 Kentucky Revised Statute.

3 Following the conclusion of the guilt phase, the parties negotiated a sentence on the misdemeanor charge for possession of drug paraphernalia of six months of imprisonment to run concurrently with the to-be-determined sentence for the felony count.

that Tucker was represented by the Department of Public Advocacy (“DPA”); (2) the circuit court should have directed a verdict of acquittal for the charge of PCS 1st; and (3) the circuit court should have granted a mistrial after the prosecutor implored the jurors to “send a message” to the community during the penalty phase closing arguments. We address each argument in turn and discuss additional facts as needed.

A. The Circuit Court Did Not Abuse Its Discretion by Declining to Declare a Mistrial Following the Prosecutor’s Disclosure in Voir Dire That the DPA Represented Tucker.

During voir dire, the prosecutor made the following statement: “The Defendant in this action is represented by the [DPA]. The assigned attorneys are [defense counsel] and [co-counsel]. [Defense counsel] formerly had a private practice . . . .” Defense counsel objected, and at the ensuing bench conference, requested a mistrial. The circuit court agreed that the prosecutor’s statement “caused an issue” and took a ten minute recess.

Upon returning to the bench, the court requested the parties to approach and reiterated its agreement that the prosecutor’s statement was improper. However, the court believed that, after reviewing the case law, the error did not necessitate a mistrial and indicated its intent to admonish the jury, noting defense counsel’s objection for the record. The court then proceeded to give the following admonition:

Ladies and gentlemen of the jury, before the court took a break, the Commonwealth’s Attorney made a reference to [defense counsel] and his co-counsel as “assigned attorneys for the Defendant.” They referenced their employment at the public defender’s office. You are to disregard the relationship between the attorneys for the Defendant and the Defendant. You are to set that aside, give that no consideration as you consider the evidence and the status of this case. There’s an attorney-client relationship between the Defendant and her attorneys and that is all the consideration that you should give that particular issue, so I’m going to ask and admonish you all to set that aside – any reference to [defense counsel]’s status as a public defender and his co-counsel’s status as a public defender. And I am confident that you all will take that admonition seriously – not let it play any role whatsoever in your ultimate determination in this case.

Approximately 20 minutes elapsed between the time of the prosecutor’s statement and the court’s admonishment. On appeal, Tucker argues that the prejudice resulting from the prosecutor’s statement could not be cured by an admonition. Moreover, Tucker claims the circuit court compounded the error by taking a recess and then admonishing the potential jurors, thereby drawing more attention to the issue and cementing it in the jurors’ minds.

A mistrial is a drastic measure of last resort and should be granted “only when a fundamental defect in the proceedings has rendered a fair trial manifestly impossible.” Jacobsen v. Commonwealth, 376 S.W.3d 600, 609 (Ky. 2012) (citing Parker v. Commonwealth, 291 S.W.3d 647, 658 (Ky. 2009)). “The standard for reviewing the denial of a mistrial is abuse of discretion.” Graves v.

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