Randall Price v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedMay 22, 2026
Docket2025-CA-1426
StatusUnpublished

This text of Randall Price v. Commonwealth of Kentucky (Randall Price v. Commonwealth of Kentucky) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Randall Price v. Commonwealth of Kentucky, (Ky. Ct. App. 2026).

Opinion

RENDERED: MAY 22, 2026; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2025-CA-1426-MR

RANDALL PRICE APPELLANT

APPEAL FROM KENTON CIRCUIT COURT v. HONORABLE PATRICIA M. SUMME, JUDGE ACTION NO. 14-CR-00997

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, CETRULO, AND EASTON, JUDGES.

EASTON, JUDGE: Randall Price (Price), pro se, appeals from an Order of the

Kenton Circuit Court denying his latest post-conviction motion. Over a decade

ago, a jury convicted Price of First-Degree Assault1 and First-Degree Robbery.2

Price now argues that his assault conviction should be vacated because he has

1 Kentucky Revised Statutes (KRS) 508.010. 2 KRS 515.020. “newly discovered evidence” that serious physical injury, standing alone, does not

sustain a conviction for First-Degree Assault. He also repeats claims that his

assault conviction was improper because it was based on inconsistent findings of

intentional and wanton conduct and was precluded by double jeopardy. Finally,

Price believes he was denied effective assistance of counsel because appellate

counsel failed to raise issues in his prior appeals. We affirm.

FACTUAL AND PROCEDURAL HISTORY

This case has a long history. Price has filed multiple motions with

appeals and a federal court action relating to this case. Several preceding opinions

in both state and federal courts thoroughly describe the factual and procedural

history. We will discuss only the details of the case particularly relevant to this

appeal.

Price was indicted in 2014 on charges of First-Degree Assault and

First-Degree Robbery. He was tried before a jury and convicted on both counts.

He was sentenced to 20 years for the assault and 10 years for the robbery to be

served consecutively for a total sentence of 30 years. Price appealed the judgment

to the Supreme Court of Kentucky. In that direct appeal, Price argued he was

entitled to a directed verdict on the First-Degree Robbery charge because there was

no evidence to establish that he had committed theft of the victim’s wallet. The

Supreme Court disagreed finding sufficient evidence that Price stole the victim’s

-2- wallet after beating him, and that the beating Price inflicted upon the victim

satisfied the “use of physical force” and injury elements sufficient to support a

conviction for First-Degree Robbery.

Price also argued in his direct appeal that he should have been granted

a directed verdict on the First-Degree Assault charge, in part, because the

Commonwealth failed to prove the victim suffered a serious physical injury. Our

Supreme Court disagreed, noting that the victim suffered devastating injuries to his

facial bones, eye, and mouth. His cheekbone was free-floating as no longer

attached to the related facial muscles. His face was deformed. Medical testimony

established that the victim suffered a permanent loss to his mouth’s range of

motion.3 Price v. Commonwealth, No. 2015-SC-000469-MR, 2016 WL 7665874

(Ky. Dec. 15, 2016).

In 2017, Price filed a Motion to Vacate, Set Aside, or Correct

Judgment pursuant to RCr4 11.42. Price alleged multiple claims of ineffective

assistance of counsel. The circuit court denied the motion. Price appealed to this

3 As noted by our Supreme Court, one of the first responders to the scene testified that the victim was bleeding from his head, barely breathing, and not moving. The victim’s recovery from the assault was exacerbated by alcohol withdrawal symptoms and preexisting conditions of Hepatitis C and Cirrhosis of the liver. A few months after the assault, and before the trial, the victim succumbed to his liver disease and died at the age of fifty-nine. 4 Kentucky Rules of Criminal Procedure.

-3- Court, and this Court affirmed in Price v. Commonwealth, No. 2020-CA-0166-

MR, 2021 WL 1932722 (Ky. App. May 14, 2021).

Price next filed a 28 U.S.C.5 § 2254 habeas corpus petition in the

United States District Court, Eastern District of Kentucky, where he claimed his

convictions for First-Degree Robbery and First-Degree Assault violated the Double

Jeopardy Clause. Price argued to the federal court, as he again argues here, that his

assault charge did not contain an additional element that is not already contained in

the robbery charge.

The federal district court concluded that Price had failed to exhaust

state court remedies with respect to his double jeopardy claim. Price did not assert

a double jeopardy claim on direct appeal to the Supreme Court of Kentucky or in

his motion for collateral relief filed in 2017 under RCr 11.42. Instead, Price first

raised the issue in his brief appealing the trial court’s denial of his RCr 11.42

motion. This failure to properly present this claim led to this Court rejecting the

claim without addressing it. The federal district court held that “[b]y failing to

raise his double jeopardy claim, either on direct appeal or before the trial court in

his Rule 11.42 motion, Price did not ‘fairly present[ ] his claim[ ] to the state

courts.’” Price v. Green, No. CV 2:21-142-DCR, 2023 WL 4703327 at *3 (E.D.

5 United States Code.

-4- Ky. Jul. 24, 2023) (citing Geneva v. Lazaroff, 77 F. App’x. 845, 849 (6th Cir.

2003)).

Despite this procedural flaw, the federal district court analyzed the

claim and determined that Price’s convictions under KRS 508.010 and KRS

515.020 did not violate the prohibition against double jeopardy. Id. at *4. The

Sixth Circuit denied Price’s request for a certificate of appealability. Price v.

Green, No. 23-5749, 2024 WL 752750, at *3 (6th Cir. Jan. 23, 2024).

In 2024, Price filed a prior motion pursuant to CR6 60.02 and RCr

10.26 in which he claimed his convictions violated constitutional and statutory

double-jeopardy prohibitions. Specifically, Price argued that the “conviction of

Assault First and Robbery First based on the same assault and the same facts with

no intent to injure only to rob violates the defendants double jeopardy rights and a

merger and vacation of the assault charge is required in the interest of justice and

due process.”7 Price claimed the assault only facilitated the robbery and thus he

could not be convicted of more than one offense because one offense is included in

the other. Price summarized that, due to counsel’s failure to raise this issue, he had

to raise it pro se in his prior appeals to this Court and in his habeas corpus petition

(overlooking that the argument was found to be without merit once raised).

6 Kentucky Rules of Civil Procedure. 7 Trial Record (TR) at 457.

-5- The circuit court found no double jeopardy violation or ineffective

assistance of appellate counsel (IAAC). In rejecting Price’s double jeopardy

argument, the circuit court found that the conviction of either the assault or the

robbery in this case required proof of an element not required to prove the other.

The conviction of robbery required proof of a theft, which was not required to

convict for assault. The conviction for assault required proof of serious physical

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Randall Price v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/randall-price-v-commonwealth-of-kentucky-kyctapp-2026.