Robert Oates v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedMarch 25, 2021
Docket2020 CA 000105
StatusUnknown

This text of Robert Oates v. Commonwealth of Kentucky (Robert Oates 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
Robert Oates v. Commonwealth of Kentucky, (Ky. Ct. App. 2021).

Opinion

RENDERED: MARCH 26, 2021; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2020-CA-0105-MR

ROBERT OATES APPELLANT

APPEAL FROM LIVINGSTON CIRCUIT COURT v. HONORABLE CLARENCE A. WOODALL, III, JUDGE ACTION NO. 17-CR-00046

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, TAYLOR, AND K. THOMPSON, JUDGES.

CALDWELL, JUDGE: Robert Oates (“Oates”) appeals from his conviction of

Theft by Unlawful Taking over $500 and his resultant sentence of one-year

imprisonment. He alleges that the trial court erred in not directing a verdict on the

charge. He also complains that the trial court allowed evidence to be presented

which was more prejudicial than probative because it was not properly

authenticated, but acknowledges that he did not object to the admission of the evidence at trial. Finally, he alleges that the complaining witness’s utterance to the

Appellant whilst leaving the witness box was prejudicial and the jury should have

been admonished to ignore the utterance; relief he did not request from the trial

court. We affirm.

FACTS

In 2016, Oates was working for Greer Excavating in Livingston

County. Oates had previously operated his own construction business, but upon

divorcing, he had dissolved his business. While wrapping up his business, he sold

some equipment. This included a bulldozer which he sold to Greer Excavating,

owned and operated by Keith Greer (“Greer”). He then began working for Greer

as an employee.

In September of 2016, Oates was approached by Jim Tinsley

(“Tinsley”), who wanted to have some work done on property he owned.

Understanding that Tinsley would pay more if Greer Excavating was engaged,

Oates agreed to do the work for Tinsley as a side job “as a favor.”

According to Oates, he told Greer about the Tinsley job and Greer

agreed to allow him to use the bulldozer to do the work for Tinsley as long as rent

was paid for its use. After several weeks, toiling after work hours, Oates finished

the job and was paid by Tinsley via check made payable to Oates Construction in

the amount of $1,600, plus title to a Jeep valued by the parties at $500.

-2- Oates insists he then reimbursed Greer Excavating for materials he

had ordered for the Tinsley job through Greer Excavating, and made this

reimbursement in cash. He also alleged that he had paid Greer for rental of the

bulldozer. The total amount that Oates alleged he paid Greer for the job was

$1,900. He did not ask for or receive a receipt. Evidence at trial suggested Tinsley

paid Oates a total of $2,100 in cash plus the value of the Jeep.

Greer had a different view of the situation. He testified at the trial that

he was wholly unaware of the Tinsley job and denied that Oates ever asked

permission to use the bulldozer or order materials for the job through Greer

Excavating. When Greer was billed for the materials, he asked Oates about the bill

and learned of the Tinsley job. Oates assured him that he would reimburse the

company for the materials. When Greer was never paid for the materials by his

employee, Oates, he approached Tinsley for payment. That was when he was

presented with evidence that Tinsley had paid “Oates Construction” for the work

which had been completed using Greer Excavating equipment and with materials

purchased through the company. Greer denied ever being reimbursed by Oates for

any of the materials or the use of the bulldozer, despite Oates’ testimony to the

contrary.

Oates was charged with Theft by Unlawful Taking over $500 but

under $10,000, a Class D felony. Following a trial at which the trial court entered

-3- a directed verdict as to the Jeep, Oates was found guilty for keeping the $1,600

which Tinsley had paid him. The jury recommended the minimum sentence of

one-year imprisonment, which was imposed by the Livingston Circuit Court. He

now appeals as a matter of right.

STANDARD OF REVIEW AND ANALYSIS

Directed Verdict

The standard of review for the denial of a motion for directed verdict

of acquittal involves the following:

On motion for directed verdict, the trial court must draw all fair and reasonable inferences from the evidence in favor of the Commonwealth. If the evidence is sufficient to induce a reasonable juror to believe beyond a reasonable doubt that the defendant is guilty, a directed verdict should not be given. For the purpose of ruling on the motion, the trial court must assume that the evidence for the Commonwealth is true, but reserving to the jury questions as to the credibility and weight to be given to such testimony.

Commonwealth v. Benham, 816 S.W.2d 186, 187 (Ky. 1991).

Oates argues that the trial court erred when it allowed the jury to

deliberate because there was insufficient evidence provided to support a finding of

guilt. He complains that the evidence—which consisted of the testimony of Keith

Greer and Jim Tinsley, as well as the check Tinsley gave him payable to Oates

Construction, and receipts for materials Oates purchased through Greer Excavating

-4- to complete the Tinsley gig—was not sufficient because Oates himself disputed

their testimony.

However, Oates forgets that it is the jury who is the arbiter of the

credibility of witnesses when testimony is in conflict. What Oates suggests is that

the trial court should have placed his judgment as to the credibility of the witnesses

as paramount to the judgment of the trier of fact, i.e., the jury. However, the law is

actually in opposition to his argument.

[Such an argument] improperly shifts the credibility determination from the jury to the judge. As cautioned by Professor Lawson, the power to disqualify witnesses “should be applied grudgingly, only against the ‘incapable’ witness and never against the ‘incredible’ witness, since the triers of fact are particularly adept at judging credibility.” Robert G. Lawson, The Kentucky Evidence Law Handbook § 3.00[2][b] at 239 (5th ed. 2013) (quoting the Evidence Rules Study Committee, Kentucky Rules of Evidence—Final Draft, p. 54 (Nov. 1989)).

Ross v. Commonwealth, 531 S.W.3d 471, 477 (Ky. 2017).

When the testimony of witnesses differs on a fact, it is the jury’s

responsibility to determine witness credibility and find facts. It is not the trial

court’s purview to remove that duty from the jury.

[W]hen looking at the trial court’s failure to grant a directed verdict, an appellate court should not reverse unless “it would be clearly unreasonable for a jury to find guilt.” Commonwealth v. Benham, 816 S.W.2d 186, 187 (Ky. 1991).

-5- Commonwealth v. Goss, 428 S.W.3d 619, 625-26 (Ky. 2014), as modified (Apr.

28, 2014). A simple divergence of testimony, such as that at issue here, is

insufficient for us to determine “it would be clearly unreasonable for a jury to find

guilt.” Id.

The trial court properly allowed the jury to determine which witnesses

to find credible, and, through the testimony, determine the facts it found supported

by substantial evidence. We cannot say that it was wholly unreasonable for the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Commonwealth v. Benham
816 S.W.2d 186 (Kentucky Supreme Court, 1991)
Miller v. Commonwealth
283 S.W.3d 690 (Kentucky Supreme Court, 2009)
Martin v. Commonwealth
207 S.W.3d 1 (Kentucky Supreme Court, 2006)
Shegog v. Commonwealth
142 S.W.3d 101 (Kentucky Supreme Court, 2004)
Cole D. Ross v. Commonwealth of Kentucky
531 S.W.3d 471 (Kentucky Supreme Court, 2017)
McCleery v. Commonwealth
410 S.W.3d 597 (Kentucky Supreme Court, 2013)
Commonwealth v. Goss
428 S.W.3d 619 (Kentucky Supreme Court, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Robert Oates v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-oates-v-commonwealth-of-kentucky-kyctapp-2021.