Quinton R. Huddleston v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedFebruary 15, 2018
Docket2016-SC-0673
StatusPublished

This text of Quinton R. Huddleston v. Commonwealth of Kentucky (Quinton R. Huddleston 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
Quinton R. Huddleston v. Commonwealth of Kentucky, (Ky. 2018).

Opinion

RENDERED: FEBRUARY 15, 2018 TO BE PUBLISHED

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QUINTON R. HUDDLESTON APPELLANT

ON APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE AUDRA JEAN ECKERLE, JUDGE NO. 14-CR-001620

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION OF THE COURT BY JUSTICE VENTERS

AFFIRMING

Appellant, Quinton Huddleston, appeals from a judgment of the Jefferson

Circuit Court convicting him of murder, for which he was sentenced to life in

prison without the possibility of parole, criminal attempt to commit murder,

and several other related crimes. As grounds fol'. relief, he contends that the

trial court erred by: (1) denying his request to introduce parole eligibility

information during the capital sentencing phase of the trial; (2) permitting the

Commonwealth to introduce during the guilt phase evidence of other crimes

committed by Appellant against the victims' family; and (3) allowing the

testimony of a witness who was three years old at the time of the crimes and

six years old at the time of the trial. For the reasons explained below, we

affirm. I. FACTUAL AND PROCEDURAL BACKGROUND Appellant and Tanisha Gordon broke up after a tumultuous relationship

that included instances of domestic violence. A short time later, Appellant

forced his way into Tanisha's apartment where he killed her brother, Joshua

Gordon, by shooting him in the chest. Appellant then beat Tanisha with his

gun and shot her in the face. Tanisha survived, but Appellant's attack left her

with devastating injuries. Her three-year-old son, La,Martez, witnessed the

shootings. Later, at the age of six, he briefly testified at Appellant's trial as a

witness for the Commonwealth.

The Commonwealth elected to seek the death penalty and the case was

tried accordingly. Appellantdid not deny that he killed Joshua and attacked

·Tanisha. He claimed that he did so because of an extreme emotional·

disturbance. He testified that he went to the apartment with no intent to

engage in violence, but when he realized that his relationship with Tanisha was

over and that he would not be able to raise LaMartez as his son, he was

overtaken by an extreme emotional disturbance impelling.him to violence. The

jury rejected Appellant's defense and found him guilty as charged.

Although the jury found the existence of a death-qualifying aggravating

circumstance, upon completion of the capital sentencing proceeding, it

recommended a sentence of life without the possibility of parole. Appellant and

the Commonwealth then agreed to concurrent sentences on the remaining

crimes. This appeal followed.

2 II. THE EXCLUSION OF PAROLE ELIGIBILITY INFORMATION DURING THE DEATH PENALTY PHASE IS NOT REQUIRED. The fact that Appellant was tried and convicted in the same trial for both

capital and non-capital crimes posed some penalty-phase complexities for the

trial court. KRS 532.055, entitled "Verdicts and sentencing by ajury in felony

cases," spells out the truth-in-sentencing process generally applicable in any

felony case, while KRS 532.025 details essential sentence-determining factors

that pertain only to the process for fixing the penalty for a capital crime when

the death penalty is a possible· sentence.

As an aside, we review the interplay between ~RS 532.055 and KRS

532.025 mindful that in Commonwealth v. Reneer, we recognized KRS 532.055

as "a legislative attempt to invade the rule making prerogative of the Supreme

Court by legislatively prescribing rules of practice and procedure [and

therefore] it violate[d] the separation of powers doctrine enunciated in Section

28 of the Kentucky Constitution." 734 S.W.2d 794, 796 (Ky. 1987).

Nevertheless, in the spirit of comity, we declined _to hold KRS 532.055

unconstitutional and we agreed to follow its process, at least "for the time

being." Id. at 798. We recently reiterated our recognition of that legislative

incursion, and our continuing acceptance of it as a matter of comity, in

Jackson v. Commonwealth, 481 S.W.3d 794, 799-800 (Ky. 2016). We continue

that'policy now.

Returning to the matter at hand, in Francis v. Commonwealth,

reconciling what we saw as an inconsistency in the two processes set forth in

KRS 532.025 and KRS 532.055, we held that "in any case in which the death

3 penalty is sought, the capital penalty sentencing phase pursuant to KRS

532.025 should be conducted before the truth-in-sentencing hearing under

KRS 532.055(2) and the PFO proceeding per KRS 532.080 are held." 752

S.W.2d 309, 311 (Ky. 1988). Our purpose was to prevent the capital

sentencing process from being tainted by truth-in-sentencing information

admissible under KRS 532.055. Significantly, at the time of the Francis

decision, KRS 532.055(3) expressly stated that the truth-in-sentencing

provisions of KRS 532.055 "shall n,ot apply to sentencing hearings provided for

in KRS 532.025 [for death penalty sentencing]." (Emphasis added.) I

As a natural corollary of the Francis rule, we held in.Perdue v.

Commonwealth that "when the death penalty is sought, evidence of minimum

parole eligibility guidelines may not be introduced at all." 916 S.W.2d 148, 163

(Ky. 1995). "[P]arole eligibility information which is fully admissible under KRS

532.055 has no place in a death penalty hearing pursuant to KRS 532.025.

I Justice Leibson's dissent in Francis (based upon his rejection of the Majority's view that the error was harmless) highlighted the statutory rationale for the Francis rule, stating: KRS 532.055, the Truth-In-Sentencing statute, by its expressed terms, applies to all felony sentencing hearings except for those 'provided for in KRS 532.025

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