Krishaun Mays v. Commonwealth of Kentucky

Court of Appeals of Kentucky·Decided March 20, 2026·No. 2024-CA-0774·Unpublished

Opinion

RENDERED: MARCH 20, 2026; 10:00 A.M.

NOT TO BE PUBLISHED

Commonwealth of Kentucky

Court of Appeals

NO. 2024-CA-0360-MR

BROOKE L. KENNEDY APPELLANT

APPEAL FROM FRANKLIN CIRCUIT COURT v. HONORABLE THOMAS D. WINGATE, JUDGE ACTION NO. 17-CR-00062-004

COMMONWEALTH OF KENTUCKY APPELLEE AND

NO. 2024-CA-0774-MR

KRISHAUN MAYS APPELLANT

APPEAL FROM FRANKLIN CIRCUIT COURT v. HONORABLE THOMAS D. WINGATE, JUDGE ACTION NO. 17-CR-00062-001

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION

AFFIRMING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; CETRULO AND KAREM, JUDGES. THOMPSON, CHIEF JUDGE: In this consolidated appeal, Krishaun Mays and Brooke L. Kennedy appeal from the denial of post-judgment motions following their criminal convictions resulting from the December 26, 2016 robbery and murder of Jared Banta in Franklin County, Kentucky. Mays argues that the circuit court improperly denied his motion pursuant Kentucky Rules of Criminal Procedure (RCr) 11.42 to vacate his judgment and sentence. Kennedy argues that the circuit court erred in denying her Kentucky Rules of Civil Procedure (CR) 60.02 motion to amend her conviction from complicity to robbery in the first degree to complicity to robbery in the second degree, and to reduce her sentence. After careful review, we find no error and affirm the orders on appeal.

APPEAL OF KRISHAUN MAYS

FACTS AND PROCEDURAL HISTORY On February 14, 2017, Mays was indicted by a Franklin County grand jury on charges of murder and robbery in the first degree.1 Kennedy and three other co-defendants were indicted on charges of complicity to murder and complicity to robbery in the first degree. The indictments arose from the murder of

1 Kentucky Revised Statutes (KRS) 507.020 and KRS 515.020.

Banta on December 26, 2016, which resulted after a scheme by Mays and his co- defendants to rob Banta. Mays was 17 years old at the time of the murder.

Mays’ appointed counsel had Mays’ mental capacity evaluated by Dr.

Eric Drogin, who determined that Mays had an IQ of 72. Counsel sought this information as a possible basis for arguing that Mays’ lower than average IQ could be a mitigating factor. Counsel did not challenge Mays’ competency.

On January 9, 2020, Mays’ counsel filed a RCr 8.07(2) motion to introduce this evidence at trial. A hearing on the motion was conducted, at which time the Commonwealth sought to have Mays evaluated at the Kentucky Correctional Psychiatric Center (KCPC) for rebuttal purposes. Both requests were granted, and the matter was set for trial.

On March 6, 2020, and prior to trial, Mays entered a guilty plea in exchange for the Commonwealth’s recommendation of a 20-year sentence on the murder charge, a five-year sentence on an amended charge of robbery in the second degree,2 and both sentences to be served consecutively for a total of 25 years in prison. Mays participated in a plea colloquy where he stated that he was satisfied with counsel’s representation, understood the nature of his plea, and that he was waiving his right to a jury trial and an appeal. Based on the plea, the parties agreed that the KCPC order could be rescinded.

2 KRS 515.030.

The matter moved to sentencing on May 20, 2020. Mays’ counsel unsuccessfully sought probation based on counsel’s claim that Mays’ IQ demonstrated that he was only “borderline competent.” The court then sentenced Mays in accordance with the Commonwealth’s recommendation.

On July 21, 2023, Mays, pro se, filed a motion for RCr 11.42 relief from judgment. In support of the motion, Mays argued that his counsel was ineffective in failing to move to withdraw his guilty plea; in failing to ensure that the KCPC evaluation was completed; in failing to file a direct appeal from his guilty plea; and, failing to prosecute an interlocutory appeal from an order denying his request to change venue. According to the record, the Commonwealth agreed that the KCPC evaluation should have been conducted, and stated that a retrospective hearing on the matter could be conducted.

On January 25, 2024, and May 23, 2024, the circuit court entered orders denying Mays’ motion for RCr 11.42 relief.3 The court found that no further competency hearings were necessary, as Mays’ own expert, Dr. Drogin, found Mays to be competent and his evaluation had been for mitigation purposes only. The court also noted that it was the Commonwealth, not Mays, which

3 The first order denied in part Appellant’s motion for RCr 11.42 relief and reserved in part for later adjudication additional portions of Appellant’s motion pending a response from the Commonwealth. The court’s second order disposed of Appellant’s motion in toto; denied his request for counsel on the RCr 11.42 motion; and, stated that it would appoint appellate counsel if requested by Appellant.

requested the KCPC evaluation for possible rebuttal purposes, and that this request was rendered moot by virtue of Mays’ guilty plea. The court determined that Mays’ arguments were refuted by the record; therefore, no evidentiary hearing was required. It denied Mays’ motion for relief and this appeal followed.

STANDARD OF REVIEW

To prevail on a claim of ineffective assistance of counsel, Mays must show two things:

First, the defendant must show that counsel’s performance was deficient. This requires showing that counsel made errors so serious that counsel was not functioning as the “counsel” guaranteed the defendant by the Sixth Amendment. Second, the defendant must show that the deficient performance prejudiced the defense.

This requires showing that counsel’s errors were so serious as to deprive the defendant of a fair trial, a trial whose result is reliable.

Strickland v. Washington, 466 U.S. 668, 687 (1984). “[T]he proper standard for attorney performance is that of reasonably effective assistance.” Id.

An error by counsel, even if professionally unreasonable, does not warrant setting aside the judgment of a criminal proceeding if the error had no effect on the judgment. The purpose of the Sixth Amendment guarantee of counsel is to ensure that a defendant has the assistance necessary to justify reliance on the outcome of the proceeding. Accordingly, any deficiencies in counsel’s performance must be prejudicial to the defense in order to constitute ineffective assistance under the Constitution.

Id. at 691-92 (citation omitted). “It is not enough for the defendant to show that the errors had some conceivable effect on the outcome of the proceeding.” Id. at 693. “The defendant must show that there is a reasonable probability that, but for counsel’s unprofessional errors, the result of the proceeding would have been different. A reasonable probability is a probability sufficient to undermine confidence in the outcome.” Id. at 694. Additionally, “a hearing is required only if there is an issue of fact which cannot be determined on the face of the record.” Stanford v. Commonwealth, 854 S.W.2d 742, 743-44 (Ky. 1993).

ARGUMENTS AND ANALYSIS

Mays, pro se, argues that the Franklin Circuit Court abused its discretion in denying his motion for RCr 11.42 relief. He first contends that his counsel was ineffective for negotiating a plea agreement before ensuring the KCPC evaluation was completed. He maintains that there is no evidence in the record demonstrating that he was competent to enter into a guilty plea, and that the KCPC evaluation might have shown that he lacked the IQ to understand the guilty plea or to be held culpable if the matter proceeded to trial. On this basis, Mays asserts that he did not receive the effective assistance of counsel to which he was entitled, as effective assistance would have included staying the plea negotiation process until the KCPC hearing was completed.

KRS 532.135 states that,

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