Michael Dumas v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedNovember 16, 2023
Docket2022 CA 001468
StatusUnknown

This text of Michael Dumas v. Commonwealth of Kentucky (Michael Dumas 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
Michael Dumas v. Commonwealth of Kentucky, (Ky. Ct. App. 2023).

Opinion

RENDERED: NOVEMBER 17, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-1468-MR

MICHAEL DUMAS APPELLANT

APPEAL FROM MARSHALL CIRCUIT COURT v. HONORABLE DAVID C. BUCKINGHAM, SPECIAL JUDGE ACTION NO. 09-CR-00118

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, DIXON, AND MCNEILL, JUDGES.

ACREE, JUDGE: Appellant, Michael Dumas, appeals the Marshall Circuit

Court’s September 29, 2022 Order denying his RCr1 10.10 motion to correct an

alleged clerical error in a final criminal judgment against him. Having reviewed

the record, we affirm.

1 Kentucky Rules of Criminal Procedure. On June 12, 2009, the Commonwealth charged Dumas with four

counts of distribution of matter portraying a sexual performance by a minor in

violation of KRS2 531.340 and three counts of possession of matter portraying a

sexual performance by a minor in violation of KRS 531.335. A jury convicted

Appellant of all charges, and the court entered a final judgment against Dumas on

May 18, 2010. The court sentenced Dumas to a total of twenty years of

incarceration. On direct appeal, the Kentucky Supreme Court affirmed the

conviction on all substantive grounds. Dumas v. Commonwealth, No. 2010-SC-

000378-MR, 2011 WL 2112560, at *1 (Ky. May 19, 2011).

Thereafter, Dumas, acting pro se, filed a RCr 11.42 motion claiming

ineffective assistance of counsel. The circuit court denied this motion, and this

Court dismissed his appeal of that order for untimeliness. Then, on September 14,

2021, Dumas filed a motion to amend his final judgment. The final judgment

indicated Dumas would be subject to a five-year conditional discharge period after

his release from incarceration. Neither KRS 531.340 nor KRS 531.335 permit

five-year conditional discharge time after release from prison. The circuit court

granted Appellant’s motion, believing the error to be a clerical mistake.

Subsequently, Dumas filed the RCr 10.10 motion that is the subject of

this appeal. In his motion, Dumas argued he was not required to provide a blood

2 Kentucky Revised Statutes.

-2- sample per KRS 17.170. Further, Dumas argued the judgment should reflect that

he must register as a “registrant” and not a “sexual offender” because he was not

convicted of a sex crime. The circuit court denied this motion and rejected his

arguments. This appeal follows.

Pursuant to RCr 10.10:

Clerical mistakes in judgments . . . may be corrected by the court at any time on its own initiative or on the motion of any party and after such notice, if any, as the court orders. During the pendency of an appeal, such mistakes may be so corrected before the appeal is perfected in the appellate court, and thereafter while the appeal is pending may be so corrected with leave of the appellate court.

RCr 10.10.

For RCr 10.10 to operate correctly, a key distinction must be made

between clerical errors and judicial errors. “Clerical mistakes or errors, as opposed

to judicial errors, are ‘all errors, mistakes, or omissions which are not the result of

the exercise of the judicial function.’” Machniak v. Commonwealth, 351 S.W.3d

648, 652 (Ky. 2011) (quoting Buchanan v. W. Ky. Coal Co., 291 S.W. 32, 35 (Ky.

1927)). Thus, the Kentucky Supreme Court emphasized: “[t]he distinction

between judicial and clerical errors ‘does not depend so much upon the person

making the error as upon whether it was the deliberate result of judicial reasoning

and determination, regardless of whether it was made by the clerk, by counsel, or

by the judge.’” Id. (quoting Buchanan, 291 S.W. at 35).

-3- An important consequence of determining whether an error is clerical

or judicial becomes apparent when considering that “[g]enerally speaking, a trial

court lacks power to amend a judgment ten days after the entry of that judgment.”

Winstead v. Commonwealth, 327 S.W.3d 479, 485-86 (Ky. 2010). Therefore,

unlike clerical errors, judicial errors are not subject to correction under RCr 10.10.

Id. at 486. Fatal to Dumas’ argument, both alleged errors would be judicial errors.

However, we are not convinced the circuit court made any errors at all. Despite

this, assuming arguendo Dumas did correctly identify errors on his final judgment,

the errors are not clerical errors.

He, again, alleges two errors. First, Dumas alleges he does not need

to register as a “sexual offender” but rather as a “registrant.” Reviewing the final

judgment, the judgment requires: “Pursuant to KRS 17.510(2) defendant has been

convicted of a sex crime and has been informed of duty to register with the

appropriate local Probation and Parole [O]ffice.” Nothing in this portion of the

judgment indicates whether he must be called a “registrant” or “sexual offender.”

It solely requires him to register with the proper local authority. Thus, on its face,

there is no clerical error of the nature that Dumas complains about.

Further, KRS 17.510(2) states: “A registrant shall, on or before the

date of his or her release by the court, the parole board, the cabinet, or any

detention facility, register with the appropriate local probation and parole office in

-4- the county in which he or she intends to reside. The person in charge of the release

shall facilitate the registration process.” KRS 17.510(2). It is without question

that, at the time of Dumas’ conviction, KRS 17.510(2) required those convicted of

violations of KRS 531.335 to register with the appropriate probation or parole

board. See Hamilton-Smith v. Commonwealth, 285 S.W.3d 307 (Ky. App. 2009)

(Appellant required to register as a sexual offender per KRS 17.510(2) after

conviction for violating KRS 531.335).

Consequently, no clerical error exists concerning the judgment’s

requirement that Dumas register as a sexual offender pursuant to KRS 17.510(2).

Second, Dumas argues there exists a clerical error concerning the

judgment’s requirement that he provide blood for purposes of a DNA sample. The

judgment indicates:

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Related

Hamilton-Smith v. Commonwealth
285 S.W.3d 307 (Court of Appeals of Kentucky, 2009)
Winstead v. Commonwealth
327 S.W.3d 479 (Kentucky Supreme Court, 2010)
MacHniak v. Commonwealth
351 S.W.3d 648 (Kentucky Supreme Court, 2011)
Buchanan Sheriff v. West Ky. Coal Co.
291 S.W. 32 (Court of Appeals of Kentucky (pre-1976), 1927)

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Michael Dumas v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-dumas-v-commonwealth-of-kentucky-kyctapp-2023.