Michael v. Hayes v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedAugust 23, 2021
Docket2019 SC 0455
StatusUnknown

This text of Michael v. Hayes v. Commonwealth of Kentucky (Michael v. Hayes 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
Michael v. Hayes v. Commonwealth of Kentucky, (Ky. 2021).

Opinion

RENDERED: AUGUST 26, 2021 TO BE PUBLISHED

Supreme Court of Kentucky 2019-SC-0455-MR

MICHAEL V. HAYES APPELLANT

ON APPEAL FROM JEFFERSON CIRCUIT COURT V. HONORABLE MITCHELL PERRY, JUDGE NO. 13-CR-002996

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION OF THE COURT BY JUSTICE HUGHES

AFFIRMING

Although a defendant who enters an unconditional guilty plea typically

waives his right to appeal, this Court has recognized some exceptions to the

general rule, one of which is the appealability of so-called sentencing issues.

Windsor v. Commonwealth, 250 S.W.3d 306 (Ky. 2008). This case requires us

to consider again the scope of such sentencing issues, and more specifically

whether a defendant who has entered an open plea can subsequently appeal

on the grounds that his statutorily-authorized sentence should be reversed

because the trial court did not give adequate consideration to mitigation

evidence. Finding first that this type of appeal exceeds our current post-guilty-

plea precedent, we further decline to extend the sentencing exception to

encompass a dispute about the weight to be accorded mitigation evidence.

Accordingly, we hold Appellant Michael V. Hayes has waived his right to appeal his sentence but recognizing perhaps some uncertainty regarding appealability

in these circumstances, we also address the merits of his appeal. For the

reasons stated herein, we affirm the judgment of the Jefferson Circuit Court.

FACTUAL AND PROCEDURAL BACKGROUND

The police were called to Javon Dawson’s apartment in early November

2013. They found Dawson dead on the floor, her throat cut. The investigation

led to an interview with Hayes, a neighbor who usually bought drugs from

Dawson’s cohabitating boyfriend. At the time of the murder, Dawson’s

boyfriend was in jail and Dawson was selling drugs to raise money for his bail.

The day before Dawson’s murder, a neighbor heard Hayes banging on

Dawson’s door, asking to buy $100 worth of crack on credit. Although Hayes

initially implicated another neighbor in the murder, he soon admitted killing

Dawson.

A Jefferson County grand jury indicted Hayes for murder, robbery in the

first degree, and tampering with physical evidence. The Commonwealth gave

notice that it would seek the death penalty based upon the aggravated

circumstance that Hayes murdered Dawson during the commission of robbery

in the first degree. The Commonwealth’s Offer on a Plea Agreement, which

Hayes accepted, described the facts of the case as follows:

On November 3, 2013, the defendant entered . . . the residence of . . . Dawson and her three children, and murdered Ms. Dawson with a 12-inch long kitchen knife. Ms. Dawson’s three children were asleep in the apartment when this happened. The defendant was thereby able to steal items from the victim including her purse, which was recovered in his apartment. When officers arrived at his apartment during a neighborhood canvas, he hid in

2 his hall closet a bag containing the purse and its contents, the knife, and some bloody clothing.

The Plea Agreement also stated that the plea

is being entered as an open plea, without agreement between the parties as to penalty. The defendant stipulates that, given that he committed the offense of murder while he engaged in the commission of a robbery in the first degree, this is an aggravating circumstance under KRS 532.025(2)(a)(2) and gives rise to the entire penalty range for capital murder as set out in KRS 532.030(1)[1] and outlined above [(20 to 50 years, or life, or life without parole, or life without parole for 25 years, or death)]. Therefore, the parties may argue for any penalty in that range and the Court will have sentencing discretion for the entire range of penalties.

The circuit court accepted Hayes’ open guilty plea to the three charges.

Its written order noted Hayes’ stipulations and that the Commonwealth made

no sentencing recommendation on the charges.

To assist the circuit court in the sentencing decision, in addition to the

presentence investigation report prepared by the probation officer,2 the

1 Kentucky Revised Statute (KRS) 532.030(1) states: When a person is convicted

of a capital offense, he shall have his punishment fixed at death, or at a term of imprisonment for life without benefit of probation or parole, or at a term of imprisonment for life without benefit of probation or parole until he has served a minimum of twenty-five (25) years of his sentence, or to a sentence of life, or to a term of not less than twenty (20) years nor more than fifty (50) years.

2 KRS 532.050 provides the presentence procedure for felony conviction. It states in part:

(1) No court shall impose sentence for conviction of a felony, other than a capital offense, without first ordering a presentence investigation after conviction and giving due consideration to a written report of the investigation. The presentence investigation report shall not be waived; however, the completion of the presentence investigation report may be delayed until after sentencing upon the written request of the defendant if the defendant is in custody.

3 Commonwealth filed a Statement of Facts and Hayes filed a Sentencing

Memorandum and a mitigation consultant’s report. The Commonwealth also

presented testimony from two of Dawson’s sisters and entered a victim impact

statement into the record during the sentencing hearing. Hayes did not call

any witnesses and did not testify on his own behalf. In response to Hayes’

request, the circuit court noted that it had already reviewed Hayes’

memorandum and the mitigation report but would do so again prior to making

its sentencing decision.

The Sentencing Memorandum and the mitigation report both conveyed to

the trial court that Hayes had relatively little criminal history—and specifically

no violent crimes. Moreover, Hayes’ current crimes for which he was to be

sentenced were related to 1) his never-treated cocaine and crack cocaine drug

(2) The report shall be prepared and presented by a probation officer and shall include:

(a) The results of the defendant’s risk and needs assessment;

(b) An analysis of the defendant’s history of delinquency or criminality, physical and mental condition, family situation and background, economic status, education, occupation, and personal habits;

(c) A preliminary calculation of the credit allowed the defendant for time spent in custody prior to the commencement of a sentence under KRS 532.120; and

(d) Any other matters that the court directs to be included.

....

(5) The presentence investigation report shall identify the counseling treatment, educational, and rehabilitation needs of the defendant and identify community-based and correctional-institutional-based programs and resources available to meet those needs or shall identify the lack of programs and resources to meet those needs. 4 addiction which was triggered by the 2006 deaths of his first fiancée and an

infant daughter, and 2) his being under the influence of drugs at the time of

the offenses.

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395 U.S. 238 (Supreme Court, 1969)
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Grigsby v. Commonwealth
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Windsor v. Commonwealth
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Hughes v. Commonwealth
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Smith v. Commonwealth
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McQueen v. Commonwealth
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Jones v. Commonwealth
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St. Clair v. Commonwealth
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Michael v. Hayes v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/michael-v-hayes-v-commonwealth-of-kentucky-ky-2021.