Nathaniel Lucas v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedJune 12, 2024
Docket2023 SC 0072
StatusUnknown

This text of Nathaniel Lucas v. Commonwealth of Kentucky (Nathaniel Lucas 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
Nathaniel Lucas v. Commonwealth of Kentucky, (Ky. 2024).

Opinion

IMPORTANT NOTICE NOT TO BE PUBLISHED OPINION

THIS OPINION IS DESIGNATED “NOT TO BE PUBLISHED.” PURSUANT TO THE RULES OF CIVIL PROCEDURE PROMULGATED BY THE SUPREME COURT, RAP 40(D), THIS OPINION IS NOT TO BE PUBLISHED AND SHALL NOT BE CITED OR USED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE; HOWEVER, UNPUBLISHED KENTUCKY APPELLATE DECISIONS, RENDERED AFTER JANUARY 1, 2003, MAY BE CITED FOR CONSIDERATION BY THE COURT IF THERE IS NO PUBLISHED OPINION THAT WOULD ADEQUATELY ADDRESS THE ISSUE BEFORE THE COURT. OPINIONS CITED FOR CONSIDERATION BY THE COURT SHALL BE SET OUT AS AN UNPUBLISHED DECISION IN THE FILED DOCUMENT AND A COPY OF THE ENTIRE DECISION SHALL BE TENDERED ALONG WITH THE DOCUMENT TO THE COURT AND ALL PARTIES TO THE ACTION. RENDERED: JUNE 13, 2024 NOT TO BE PUBLISHED

Supreme Court of Kentucky 2023-SC-0072-MR

NATHANIEL LUCAS APPELLANT

ON APPEAL FROM HARDIN CIRCUIT COURT V. HONORABLE JOHN D. SIMCOE, JUDGE NO. 21-CR-00746

COMMONWEALTH OF KENTUCKY APPELLEE

MEMORANDUM OPINION OF THE COURT

AFFIRMING

Nathaniel Lucas was convicted in Hardin Circuit Court of robbery in the

first degree, being a convicted felon in possession of a handgun, tampering with

physical evidence, and being a persistent felony offender in the first degree.

The jury recommended a sentence of thirty-five years in the aggregate, with the

sentence of twenty years for robbery in the first degree and the sentence of

fifteen years for possession of a handgun by a convicted felon running

concurrently, and the additional fifteen-year sentence for tampering with

physical evidence running consecutively, for a total sentence of thirty-five

years. 1 Following the jury’s recommendation, the trial court sentenced Lucas

1 The Parties’ Briefs differ regarding the terms of Lucas’s sentences. Lucas’s Brief states that the first-degree robbery sentence (twenty years) runs concurrently with the possession of a handgun by a convicted felon sentence (fifteen years) and consecutively with the tampering with physical evidence sentence (fifteen years), for a total of thirty-five years. The Commonwealth’s Brief states that Lucas was sentenced to thirty-five years’ incarceration. Lucas now appeals to this Court as a matter

of right. Ky. Const. § 110(2)(b). Having carefully reviewed the record and the

briefing of the parties, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

On July 29, 2021, at about 4:13 a.m., a robbery occurred at the

Speedway gas station located on North Mulberry Street in Elizabethtown,

Kentucky. During the robbery, the perpetrator brandished a gun and

demanded that the store clerk place cash and a carton of cigarettes into an

orange bag. The perpetrator then left the store.

The events of the robbery were captured on surveillance video. After the

robbery, the Speedway clerk contacted 911 and offered a general description of

the robber as a black male, dressed in camouflage and an orange vest, and

wearing a mask. Law enforcement immediately arrived on the scene. Upon

searching the area, Deputy Kevin Johnson of the Hardin County Sheriff's Office

quickly detained a suspect who matched the clerk’s description. The suspect

was determined to be Lucas, who was sweating despite the cool weather that

evening. Law enforcement also recovered in Lucas’s vicinity an orange bag

containing a shirt, a camouflage hat, a carton of cigarettes, and approximately

$200 in cash. Found nearby was an additional bag containing a gun and

to concurrent sentences for possession of a handgun by a convicted felon (fifteen years) and tampering with physical evidence (fifteen years) that run consecutive to his sentence for robbery in the first degree (twenty years), also totaling thirty-five years. A review of the trial court’s judgment reveals that Lucas is correct. 2 bearing a tag with a Lake City, Florida address. The gun was owned by a

resident of Lake City, where Lucas is from.

While other detectives interviewed Lucas, along with his girlfriend and

niece, Sergeant Madison Kuklinski reviewed still photographs from surveillance

footage taken at the Speedway. Sergeant Kuklinski noticed that, in one of the

photographs, the suspect was wearing a large and distinctive watch. She

further observed that Lucas was not wearing a watch in the interview room.

Sergeant Kuklinski discussed the missing watch with the other officers.

Deputy Johnson recalled placing handcuffs on Lucas at the scene of the

robbery and putting the handcuffs over a watch on Lucas’s wrist. As a result,

Johnson checked the police cruiser in which he had placed and transported

Lucas upon his arrest and eventually recovered a watch from the backseat.

The watch was tucked in the backseat of the vehicle and matched the general

description of the one worn by the suspect in the surveillance video. When

Sergeant Kuklinski confronted Lucas regarding the watch, Lucas persisted in

denying his involvement in the robbery.

Lucas was charged with robbery in the first degree, tampering with

physical evidence, possession of a handgun by a convicted felon, and being a

persistent felony offender in the first degree. The jury found Lucas guilty on all

counts and recommended a sentence of thirty-five years, which the trial court

imposed. This appeal followed.

3 ANALYSIS

Lucas raises two issues for review by this Court: (1) whether the trial

court erred by failing to grant a directed verdict on the tampering with physical

evidence charge; and (2) whether the prosecutor engaged in flagrant

misconduct during closing argument. We review each issue in turn, providing

additional facts as necessary.

I. Lucas Was Not Entitled To A Directed Verdict On The Tampering With Physical Evidence Charge.

Lucas first argues that the trial court erred in refusing to grant his

motion for a directed verdict on the tampering charge. Lucas failed to preserve

this issue for appeal. Although he referenced the tampering charge in making

his motion, he never specified the particular elements that the Commonwealth

failed to prove. Lucas also neglected to raise the issue in his subsequent

motions for judgment notwithstanding the verdict and for new trial. Kentucky

Rules of Criminal Procedure (RCr) 10.24, 10.02, & 10.06.

To preserve an alleged directed verdict issue for appeal, a criminal

defendant must: (1) move for a directed verdict at the close of the

Commonwealth’s evidence; (2) renew the same directed verdict motion at the

close of all the evidence, unless the defendant does not present any evidence;

(3) identify the particular charge the Commonwealth failed to prove; and (4)

“identify the particular elements of that charge the Commonwealth failed to

prove.” Ray v. Commonwealth, 611 S.W.3d 250, 266 (Ky. 2020) (emphasis

added). Lucas neither identified which elements of the tampering count the

Commonwealth failed to prove, nor provided any specificity whatsoever 4 regarding the grounds for his motion. This deficiency amounts to a clear

failure to properly preserve Lucas’s directed verdict claim for appellate review. 2

When a defendant fails to preserve an error based upon the sufficiency of

the evidence, an appellate court may review the issue for palpable error.

Chavies v. Commonwealth, 354 S.W.3d 103, 113 (Ky. 2011), abrogated on other

grounds by Roe v. Commonwealth, 493 S.W.3d 814 (Ky. 2015). Because Lucas

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