Randall Bays v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedDecember 18, 2025
Docket2024-SC-0340
StatusUnpublished

This text of Randall Bays v. Commonwealth of Kentucky (Randall Bays 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.

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Randall Bays v. Commonwealth of Kentucky, (Ky. 2025).

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IMPORTANT NOTICE NOT TO BE PUBLISHED OPINION

THIS OPINION IS DESIGNATED “NOT TO BE PUBLISHED.” PURSUANT TO THE RULES OF CIVIL PROCEDURE PROMULGATED BY THE SUPREME COURT, RAP 40(D), THIS OPINION IS NOT TO BE PUBLISHED AND SHALL NOT BE CITED OR USED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE; HOWEVER, UNPUBLISHED KENTUCKY APPELLATE DECISIONS, RENDERED AFTER JANUARY 1, 2003, MAY BE CITED FOR CONSIDERATION BY THE COURT IF THERE IS NO PUBLISHED OPINION THAT WOULD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 OPINIONS CITED FOR CONSIDERATION BY THE COURT SHALL BE SET OUT AS AN UNPUBLISHED DECISION IN THE FILED DOCUMENT AND A COPY OF THE ENTIRE DECISION SHALL BE TENDERED ALONG WITH THE DOCUMENT TO THE COURT AND ALL PARTIES TO THE ACTION. RENDERED: DECEMBER 18, 2025 NOT TO BE PUBLISHED

Supreme Court of Kentucky 2024-SC-0340-MR

RANDALL BAYS APPELLANT

ON APPEAL FROM KNOX CIRCUIT COURT V. HONORABLE MICHAEL O. CAPERTON, JUDGE NO. 23-CR-00108-001

COMMONWEALTH OF KENTUCKY APPELLEE

MEMORANDUM OPINION OF THE COURT

AFFIRMING

A Knox County jury convicted Randall Bays of first-degree trafficking in a

controlled substance (first offense, methamphetamine, over two grams) and

being a first-degree persistent felony offender (“PFO”). He received a total

sentence of twenty years’ imprisonment and appeals to this Court as a matter

of right. 1 Having carefully reviewed the record, law, and briefs, we affirm.

On September 30, 2022, Barbourville Police Detective Adam Townsley

received a tip from a known confidential informant (“CI”) that Bays would be

traveling that day from Louisville to Knox County with a quantity of

methamphetamine. The CI stated Bays would be driving a gold Buick LeSabre

1 KY. CONST. § 110(2)(b). with the license plate number, BTX-241, and also advised that Bays would

have two passengers with him, one female and one “non-female.”

Detective Townsley relayed this information to Officer Karl Middleton, a

patrolman with the Barbourville Police Department. Later that day, Officer

Middleton spotted Bays driving a gold LeSabre with the license plate number,

BTX-231, 2 instead of BTX-241, and began to follow him. There was a single

female passenger in the car who was later identified by police as Stacie Goley.

After Bays crossed the center line of the roadway multiple times, Officer

Middleton initiated a traffic stop.

When Officer Middleton approached the vehicle, Bays explained that he

crossed the center line because he was trying to turn the cruise control off.

Bays was unable to provide Officer Middleton with valid proof of insurance.

Officer Middleton asked Bays if there were any illegal substances in the car to

which Bays replied in the negative. At this point, Officer Middleton asked Bays

to exit the vehicle to perform field sobriety tests (“FSTs”). As Bays was exiting

the vehicle, Officer Middleton requested consent to search the vehicle. Bays

consented to a search of the interior of the vehicle.

Around the time the FSTs were completed, a K9 unit arrived on the

scene. Officer Middleton estimated that no more than ten minutes had elapsed

from the initial stop of the vehicle and the arrival of the K9 unit. At this point,

Goley was asked to exit the vehicle. When Goley exited the vehicle, officers

2 At some point, it was determined this vehicle was not registered to either Bays

or his passenger.

2 observed her throw a small bag of suspected methamphetamine onto the

ground. The K9 unit then conducted a free air sniff around the outside of the

vehicle. The dog alerted to the presence of controlled substances on the

driver’s side door. Based on the positive indication from the dog sniff and the

observation of Goley’s attempt to dispose of suspected methamphetamine, the

officers searched the entirety of the vehicle. In the trunk, officers discovered

over two pounds of suspected methamphetamine concealed inside two coffee

cans. Bays and Goley were then placed under arrest. At the time of arrest,

approximately forty-five minutes had elapsed from the commencement of the

initial stop.

Bays was indicted on charges of first-degree trafficking in a controlled

substance (first offense, methamphetamine, two or more grams), failure to

produce an insurance card, careless driving, and PFO 1. 3 He filed a motion to

suppress the evidence obtained as result of the warrantless search. Following

a hearing at which Officer Middleton was the sole witness, 4 the trial court

denied the motion in an order entered on March 27, 2024.

Bays proceeded to a jury trial after the denial of his suppression motion

and was found guilty of first-degree trafficking and PFO 1. The Commonwealth

had previously dismissed the charges of failure to produce an insurance card

and careless driving. The trial court sentenced Bays to a total of twenty years’

3 Goley was also charged with first-degree trafficking in a controlled substance.

The present appeal concerns only the charges against Bays. 4 There was no bodycam recording of the traffic stop and arrest.

3 imprisonment in accordance with the recommendation of the jury. This appeal

followed.

Bays’ sole argument on appeal is that the police impermissibly extended

the duration of the initial traffic stop in violation of the Fourth Amendment of

the United States Constitution. In support of this contention, he presents two

related claims. First, he argues the mission of the stop was not diligently

pursued because Officer Middleton had no basis to require the performance of

FSTs. Second, he argues Officer Middleton lacked reasonable and articulable

suspicion to investigate for drugs at the outset of the traffic stop. Bays

concedes both these claims are unpreserved and requests palpable error

review. 5

RCr 6 10.26 authorizes an appellate court to review an unpreserved error

as follows:

A palpable error which affects the substantial rights of a party may be considered by the court on motion for a new trial or by an appellate court on appeal, even though insufficiently raised or preserved for review, and appropriate relief may be granted upon a determination that manifest injustice has resulted from the error.

A palpable error is “easily perceptible, plain, obvious, and readily

noticeable.” Brewer v. Commonwealth, 206 S.W.3d 343, 349 (Ky. 2006). To

demonstrate manifest injustice, a party must show the “probability of a

5 We note Bays argued below that the stop was improperly prolonged based on

a theory that the mission of the initial stop was completed after the performance of the FSTs. He has not pursued this argument in his briefing to this Court. Therefore, this claim of error has been abandoned. Halvorsen v. Commonwealth, 671 S.W.3d 68, 74 (Ky. 2023). 6 Kentucky Rules of Criminal Procedure.

4 different result or error so fundamental as to threaten a defendant's

entitlement to due process of law.” Martin v. Commonwealth, 207 S.W.3d 1, 3

(Ky. 2006). In other words, a palpable error occurs where “the defect in the

proceeding was shocking or jurisprudentially intolerable.” Id. at 4.

The Fourth Amendment protects “[t]he right of the people to be secure in

their persons, houses, papers, and effects, against unreasonable searches and

seizures.” U.S. CONST. AMEND IV.

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