Paul Cook v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedApril 26, 2018
Docket2016-SC-0579
StatusUnpublished

This text of Paul Cook v. Commonwealth of Kentucky (Paul Cook 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
Paul Cook v. Commonwealth of Kentucky, (Ky. 2018).

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IMPORTANT NOTICE NOT TO BE PUBLISHED OPINION

THIS OPINION IS DESIGNATED "NOT TO BE PUBLISHED." PURSUANT TO THE RULES OF CIVIL PROCEDURE PROMULGATED BY THE SUPREME COURT, CR 76.28(4)(C), THIS OPINION IS NOT TO BE PUBLISHED AND SHALL NOT BE CITED OR USED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE; HOWEVER, _ UNPUBLISHED KENTUCKY APPELLATE DECISIONS, RENDERED AFTER JANUARY 1, 2003, MAY BE CITED FOR CONSIDERATION BY THE COURT IF THERE IS NO PUBLISHED OPINION THAT WOULD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 OPINIONS CITED FOR CONSIDERATION BY THE COURT SHALL BE SET OUT AS AN UNPUBLISHED DECISION IN THE FILED DOCUMENT AND A COPY OF THE ENTIRE DECISION SHALL BE TENDERED ALONG WITH THE DOCUMENT TO THE COURT AND ALL PARTIES TO THE ACTION.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: APRIL 26, 2018

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fQ) ~LI [§:51, 7/fis J<,;., fl.JMJJtt ,l>C- PAUL COOK APPELLANT

ON APPEAL FROM CHRISTIAN CIRCUIT COURT V. HONORABLE ANDREW C. SELF, JUDGE NO. 15-CR-00065

COMMONWEALTH OF KENTUCKY APPELLEE

MEMORANDUM OPINION OF THE COURT

AFFIRMING

Appellant, Paul Cook, was indicted for three counts of first-degree incest

(victim under twelve), three counts of first-degree sodomy (victim under twelve),

three counts of first-degree sexual abuse (victim under twelve), and three

counts of first-degree unlawful transaction with a minor (victim under sixteen).

Cook's case proceeded to trial in the Christian Circuit Court. In Cook's first

trial, his defense counsel referred to Cook's eagerness to take a polygraph test

during his opening statement. The trial judge ultimately granted the

Commonwealth's motion for a mistrial. When a second trial was scheduled

after the mistrial, Cook filed a motion to dismiss based upon double jeopardy.

The trial court denied the motion and the second trial began with a different

jury. Before the trial court instructed the jury in the second trial, two ?f the

counts of unlawful transaction with a minor were dismissed. A Christian

Circuit Court jury convicted Cook of the remaining counts. He was sentenced to twenty-five years' imprisonment. Cook now appeals this conviction a:s a

matter of right, Ky. Const. § 110(2)(b).

I. BACKGROUND The charges against Cook involved his alleged sexual abuse of his

stepdaughter, Sandy.1 Sandy made the allegations of abuse while visiting her

father and sister, leading to a police investigation. The details of those

allegations are largely imr.naterial to the current appeal. However, to the extent

necessary for our analysis, Sandy's testimony will be discussed below.

When police interrogated Cook regarding the abuse, a detective

apparently asked if he would take a polygraph examination. In his opening

statement in the first trial, defense counsel stated:

The pqlice aren't really ther:~ to help you when they've got you in a little room asking you questions. They're there to get evidence, and [Cook] never admitted to doing anything wrong. His story,, never changed. In fact, when the detective asked him if he'd take a lie detector test, he jumped on the opportunity. He wants to prove his innocence.

The Commonwealth immediately objected to this reference, and a bench

conference ensued. During the bench conference, the parties _discussed the

appropriate remedyto cure the inadmissible statement regarding the

polygraph. The Commonwealth first suggested defense counsel had opened the

door to the polygraph results (which were not in Coo~'s favor), and the trial

court should, therefore, allow the introduction of those results. After the trial

1Throughout this opinion, the minpr victim's name has been changed to protect her anonymity.

2 judge declined to do so, the Commonwealth agreed to an admonition, but

conditioned that agreement upon an opportunity to do more research on the

issue and revisit it after the first break.2 The trial'court admonished the jury !

that it:

[S]hould disregard any reference to a polygraph test for a number of reasons. The most important of which is that polygraph test results are not admissible in a court of law. You should not conclude that Mr. Cook either took or did not take a polygraph test based upon what has been mentioned at this point. And, certainly, you should disregard in general any reference to a polygraph test.

After the admonition, defense counsel gave the remainder of his opening

statement, and then the .Commonwealth began its case in chief. Although the . ' ' admonition instructs jurors that polygraphs are inadmissible and they should

ignore any mention of polygraph testing, it fails to address defense counsel's

statement that Cook "jumped at the chance" to take the polygraph or any ( . inferences the jury may draw therefrom. The admissibility of a polygraph is a

different issue than Cook's eagerness to take the test and the implication that

he had total confidence that it would establish his innocence.

The Commonwealth called Sandy as its first witness, and, at the

conclusion of her testimony, the trial recessed for lunch. During the recess, '

2 During the. bench ~onference, the Commonwe'alth stated: "Can we go ahead and get in an option if maybe on a break, if we can find anything, that would-." At this point, the trial judge cut the Commonwealth off.in mid-sentence. At the end of the lunch break, the Commonwealth asked to discuss the proper remedy. The trial dourt, Commonwealth, and defense counsel did so during a meeting in the judge's chambers. There, the Commonwealth stated: "I requested, even though you just admonished the jury, that· on our next break I'll do research to see if I have any other remedies." Defense counsel did not contradict or in any way indicate that this was an incorrect statement of the proceedings.

3 the Commonwealth indicated to the 'trial court that it wanted to address an

issue and a meeting between the judge, the-Commonwealth, and defense

counsel took place in the trial judge's chambers. At the meeting, the

Commonwealth stated it had researched the issue and now believed a mistrial

was the appropriate remedy for the polygraph reference. Specifically·, the

Commonwealth stated:

Yes, Judge. As I made the court aware when we were at the bench earlier after the objection was made regarding the polygraph test, the mention of it during [defense counsel's] opening, I requested, even though you just admonished the jury, that on our next break I'll do research to see if I have any other remedies. Because, I thought that would have opened the door or ·something like that for its introduction. That_'s not true. Pretty much all polygraphs are inadmissible in Kentucky. At this time, due to the research, our only recourse_. .. is to ask for a mistrial. I don't think an· admonition is enough. In the case law . . .. where there is a clear inference there was a result and-that the result was favorable to the party that mentions it, it's fatal to the case . . . . [A]ll of us in this room know that polygraphs are inadmissible. We feel like he knowingly misrepresented inadmissible evidence, and the way he framed it was that when KSP asked [Cook] to take a polygraph test, he jumped at the chance. Now, that" creates an inference that there was a test taken and that itwas favorable because why else would he mention it during his own opening statement.

Defense counsel countered that the admonition was good enough, and

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Paul Cook v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/paul-cook-v-commonwealth-of-kentucky-ky-2018.