Lawrence Richardson v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedApril 27, 2022
Docket2020 SC 0300
StatusUnknown

This text of Lawrence Richardson v. Commonwealth of Kentucky (Lawrence Richardson v. Commonwealth of Kentucky) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lawrence Richardson v. Commonwealth of Kentucky, (Ky. 2022).

Opinion

RENDERED: APRIL 28, 2022 TO BE PUBLISHED

Supreme Court of Kentucky 2020-SC-0300-DG

LAWRENCE RICHARDSON APPELLANT

ON REVIEW FROM COURT OF APPEALS V. NOS. 2018-CA-1418 AND 2018-CA-1455 NICHOLAS CIRCUIT COURT NO. 16-CR-00070

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION OF THE COURT BY JUSTICE HUGHES

AFFIRMING IN PART, REVERSING IN PART, AND REMANDING

Lawrence Richardson entered an Alford1 plea to two counts of criminal

attempt to commit first-degree unlawful transaction with a minor and one

count of third-degree terroristic threatening after his grandson reported various

instances of Richardson’s sexual misconduct. Pursuant to the plea agreement,

the Commonwealth recommended a ten-year prison sentence, which the trial

court imposed. The trial court also ordered Richardson to complete the Sex

Offender Treatment Program (SOTP) but determined that Richardson was not

subject to post-incarceration supervision pursuant to Kentucky Revised

Statute (KRS) 532.043.

On appeal, the Court of Appeals upheld the SOTP requirement but

concluded that the trial court wrongly determined that Richardson was not

1 Alford v. North Carolina, 400 U.S. 25 (1970). subject to post-incarceration supervision. Richardson petitioned this Court for

discretionary review. After careful review of the record, we affirm in part,

reverse in part, and remand this case to the trial court.

FACTS AND PROCEDURAL HISTORY

In August 2016, twelve-year-old G.R. disclosed to his mother that his

maternal grandfather, Larry Richardson, had sexually abused him while he

was between the ages of seven and eleven. G.R. stated that on at least six

occasions when he was in the bathroom at his grandparents’ house,

Richardson entered the bathroom and fondled his genitals. His mother called

the police and G.R. reported these allegations. During his interview with the

Child Advocacy Center, G.R. also disclosed that Richardson had inserted his

penis into G.R.’s anus. When the police informed Richardson of G.R.’s

allegations, Richardson threatened to kill himself. He also made threats

against G.R.’s mother.

Richardson was charged with first-degree sodomy (victim under 12);

incest (victim under 12); six counts of first-degree sexual abuse (victim under

12); and third-degree terroristic threatening. After a January 2017 competency

evaluation at the Kentucky Correctional Psychiatric Center (KCPC), the trial

court determined that Richardson was competent to stand trial.2 Richardson

was evaluated by his own expert in January 2018 and again evaluated by

2 This competency hearing is not part of the record on appeal. When a portion of the record is not before the appellate court, a presumption arises that the missing record supports the decision of the trial court. Moody v. Commonwealth, 170 S.W.3d 393, 398 (Ky. 2005).

2 KCPC in March 2018 and the trial court reaffirmed its finding that Richardson

was competent.

Thereafter, Richardson and the Commonwealth reached a plea

agreement. Under the terms of the agreement, Richardson would enter an

Alford plea to two counts of attempted first-degree unlawful transaction with a

minor and one count of third-degree terroristic threatening. In exchange for

his plea, the Commonwealth would dismiss the remaining charges and

recommend a ten-year prison sentence. Richardson and the Commonwealth

agreed that the trial court would determine: (1) whether Richardson was

subject to post-incarceration supervision upon his release; and (2) whether

Richardson was required to complete the SOTP while incarcerated. Richardson

and the Commonwealth further agreed that the trial court’s rulings on SOTP

and post-incarceration supervision could be appealed by either party.

The trial court accepted Richardson’s Alford plea and scheduled a

sentencing hearing that would also address the SOTP and post-incarceration

supervision. Under the SOTP statute, an offender is ineligible for SOTP if he

has demonstrated evidence of an intellectual disability. KRS 197.410(2). In

support of his claim that he is intellectually disabled, Richardson presented

testimony from Dr. Richard Granacher. Dr. Granacher testified that

Richardson suffers from dementia, has an IQ of 70, and would have difficulty

learning and remembering information in a classroom setting. However, Dr.

Granacher acknowledged that he was unsure whether the Department of

Corrections had accommodations available to account for Richardson’s

3 intellectual deficits. In response to Richardson’s claim of intellectual disability,

the Commonwealth pointed to the evaluations performed by KCPC, which

concluded that Richardson was competent and did not suffer from an

intellectual disability.

After considering both arguments, the trial court noted an incongruence

in Richardson’s SOTP argument—Richardson entered a plea, meaning that he

was competent to understand his legal options and the constitutional rights he

was waiving, yet he claimed to be incapable of understanding and retaining

information related to sexual offenses. Ultimately, the trial court declined to

decide whether Richardson was intellectually disabled, noting that KRS

197.410 did not define the term. Instead, the trial court concluded that it

would be appropriate to order Richardson to enroll in SOTP and, if Richardson

was ultimately deemed too low functioning to succeed in the program, that

problem could be addressed with a Kentucky Rule of Civil Procedure (CR) 60.02

motion or some other appropriate request for relief. The trial court also noted

that there was no information about the SOTP in evidence and no evidence that

Richardson would be unable to participate in the SOTP.

Richardson also argued that he was not subject to the five-year post-

incarceration supervision requirement set out in KRS 532.043 and KRS

532.060 because he entered an Alford plea to attempted unlawful transaction

with a minor. Richardson noted that the post-incarceration supervision

statutes make no mention of attempt offenses, while another statute applicable

to sex offenders, the Sex Offender Registration Act (SORA), explicitly includes

4 attempt offenses. KRS 17.500(8). Richardson insisted that the differences in

the statutes suggest that the General Assembly did not intend for post-

incarceration supervision to apply to attempt crimes. The trial court agreed

with Richardson and found that post-incarceration supervision statutes do not

apply to attempt crimes.

Following the hearing, the trial court sentenced Richardson to ten years

in prison. He denied Richardson’s request for probation and ordered him to

serve his time, noting that he was entitled to more than 700 days in

presentencing custody credit. Thereafter, Richardson appealed the SOTP

ruling and the Commonwealth cross-appealed the post-incarceration

supervision ruling.

The Court of Appeals held that the trial court acted within its discretion

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Related

North Carolina v. Alford
400 U.S. 25 (Supreme Court, 1970)
Commonwealth v. Harrelson
14 S.W.3d 541 (Kentucky Supreme Court, 2000)
Commonwealth v. Love
334 S.W.3d 92 (Kentucky Supreme Court, 2011)
Jones v. Commonwealth
319 S.W.3d 295 (Kentucky Supreme Court, 2010)
St. Clair v. Commonwealth
140 S.W.3d 510 (Kentucky Supreme Court, 2004)
Moody v. Commonwealth
170 S.W.3d 393 (Kentucky Supreme Court, 2005)
Beckham v. Bd. of Educ. of Jefferson Cty.
873 S.W.2d 575 (Kentucky Supreme Court, 1994)
Caudill v. Maloney's Discount Stores
560 S.W.2d 15 (Kentucky Supreme Court, 1977)
Donald Howard v. Commonwealth of Kentucky
496 S.W.3d 471 (Kentucky Supreme Court, 2016)
University of Louisville v. Rothstein, Mark
532 S.W.3d 644 (Kentucky Supreme Court, 2017)
Skaggs v. Commonwealth
488 S.W.3d 10 (Court of Appeals of Kentucky, 2016)

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