Rodney Bowling v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedAugust 16, 2018
Docket2016-SC-0548
StatusUnpublished

This text of Rodney Bowling v. Commonwealth of Kentucky (Rodney Bowling 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
Rodney Bowling v. Commonwealth of Kentucky, (Ky. 2018).

Opinion

RENDERED: AUGUST 16, 2018 TO BEPUBLISHED

2016-SC-000548-MR

RODNEY BOWLING APPELLANT

ON APPEAL FROM CLAY CIRCUIT COURT y. HONORABLE OSCAR G. HOUSE, JUDGE NO. 15-CR-00017

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION OF THE COURT BY JUSTICE WRIGHT AFFIRMING

A Clay Circuit Court juiy convicted Appellant, Rodney Bowling, of

murder, driving under the influence, and two counts of first-degree assault.

The jury recommended sentences of thirty years’ imprisonment for murder;

thirty days’ confinement and a $500 fine for driving under the influence; and

ten years’ imprisonment for each of the two counts of assault. The jury

recommended that the sentences run concurrently. Consistent with the jury’s

sentencing recommendations, the trial court fixed Bowling’s sentence at thirty

years’ imprisonment and a $500 fine. Bowling now appeals to this Court as a

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

Bowling asserts six claims of error in his appeal: (1) the trial court erred

in denying his motion for a directed verdict as to murder, as he alleges the

Commonwealth failed to prove aggravated wantonness; (2) the trial court erred

in allowing expert testimony exceeding the scope of the Commonwealth’s RCr 7.24(l)(c) disclosure; (3) the trial court erred in the admission of laboratory

reports in contravention of his right to confront witnesses against him; (4) the

Commonwealth committed prosecutorial misconduct through statements made

during its closing argument; (5) the trial court erred in convicting him of both

murder and driving under the influence in violation of his right to be free from

double jeopardy; and (6) the trial court erred in imposing a fine against him for

driving under the influence after determining that he was indigent. For the

following reasons, we affirm Bowling’s convictions and their corresponding

sentences.

I. BACKGROUND

Bowling was driving in Clay County when his Ford Explorer crossed the

center line and struck a Ford Ranger operated by Ronnie Mitchell. Mitchell’s

girlfriend, Melissa Smith, and their daughter were in the truck with Mitchell.

Mitchell died as a result of the injuries he sustained in the collision, and Smith

and the couple’s daughter were both seriously injured. Bowling was taken to

the hospital, where a blood test was collected, revealing that Bowling was

under the influence of Xanax at the time of the collision. A few hours after the

wreck. Bowling was released from the hospital and consented to a police

interview.

Based on the collision. Bowling was indicted by a Clay County Grand

Jury of murder, driving under the influence, and two counts of assault. He

was convicted of all charges by a Clay Circuit Court jury. Further facts will be

developed as necessary in analyzing Bowling’s allegations of error. II. ANALYSIS

A. Directed Verdict Bowling argues the trial court erred in failing to direct a verdict on his

murder charge. Specifically, Bowling argues the prosecution failed to prove

aggravated wantonness. This Court succinctly stated the rule trial courts must

follow when faced with motions for directed verdict in Commonwealth v.

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

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.

Furthermore, “[o]n appellate review, the test of a directed verdict is, if under

the evidence as a whole, it would be clearly unreasonable for a jury to find

guilt, only then the defendant is entitled to a directed verdict of acquittal.” Id.

KRS 507.020(l)(b) states “a person is guilty of murder when . . . [while

operating] a motor vehicle under circumstances manifesting extreme

indifference to human life, he wantonly engages in conduct which creates a

grave risk of death to another person and thereby causes the death of another

person.” With this statute in mind, the jury instructions in Bowling’s case

required the jury to find beyond a reasonable doubt that Bowling; (1) caused

the collision resulting in Mitchell’s death and (2) that in causing said collision. he wantonly engaged in conduct creating a grave risk of Mitchell’s death under

circumstances which manifested an extreme indifference to human life.

Melissa Smith testified at trial. She was riding in the truck with Mitchell

along with the couple’s daughter at the time of the accident which claimed

Mitchell’s life. She testified that Mitchell had been forced to swerve into the

center of the road moments before the accident, as Bowling’s vehicle had

entered their lane of travel, heading toward them in the wrong direction. She

stated Mitchell reduced the speed of his truck and re-entered his lane once

Bowling returned to his lane. She testified that Mitchell had slowed his truck

to a near stop and pulled onto the shoulder of the road on his side when

Bowling again crossed the center line and hit Mitchell’s vehicle head-on. Smith

stated that she and her daughter were both seriously injured as a result of the

accident and that Mitchell was killed.

A Kentucky State Police accident re-constructionist also testified

concerning the accident. He testified that, in his expert opinion. Bowling’s

vehicle struck Mitchell’s as Mitchell exited the highway onto the shoulder on

Mitchell’s side of the road. Bowling’s expert accident re-constructionist also

agreed that Bowling’s vehicle struck Mitchell on Mitchell’s side of the road

(although he opined the cause of the accident was Mitchell entering Bowling’s

lane).

Kentucky State Police trooper Baxter testified that Bowling was impaired

at the scene—having slurred speech, drooping eyes, excessive slobbering, and a

white crust around his mouth. Baxter stated he did not perform any field sobriety tests because medical personnel were examining Bowling and were

transporting him to the hospital. Baxter did, however, arrange for hospital

staff to take a blood sample from Bowling at the hospital. When Bowling was

being discharged from the hospital, Baxter arrested him, as he believed

Bowling was impaired. After his arrest. Bowling voluntarily gave an interview,

which Baxter recorded. The recording was played for the jury during Baxter’s

testimony at trial.

The Commonwealth asserts that Bowling admitted during his interview

with Baxter to taking several prescription medications on the morning of the

collision “including Oxycodone, Neurontin, Xanax, high blood pressure pills,

etc.” Bowling’s counsel argues in his reply brief that he “believes [Bowling] only

says that he normally takes those prescriptions in a day and not that he had

actually taken all of them that day.” However, after listening to the interview,

this Court notes that Bowling admitted to having taken at least Xanax and

Oxycodone on the day of the incident.

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