Sanford D. Rice v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedJune 26, 2026
Docket2025-CA-0707
StatusUnpublished

This text of Sanford D. Rice v. Commonwealth of Kentucky (Sanford D. Rice 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
Sanford D. Rice v. Commonwealth of Kentucky, (Ky. Ct. App. 2026).

Opinion

RENDERED: JUNE 26, 2026; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2025-CA-0707-MR

SANFORD D. RICE APPELLANT

APPEAL FROM CUMBERLAND CIRCUIT COURT v. HONORABLE DAVID WILLIAMS, JUDGE ACTION NO. 18-CR-00042

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, EASTON, AND KAREM, JUDGES.

EASTON, JUDGE: Appellant (Rice) asks us to reverse the revocation of his shock

probation by the Cumberland Circuit Court. The sole basis for this request is

Rice’s argument that the circuit court did not make sufficient findings required by

KRS1 439.3106(1)(a). Finding no error by the circuit court, we affirm.

1 Kentucky Revised Statutes. FACTUAL AND PROCEDURAL BACKGROUND

After a traffic stop in 2018, Rice was indicted for felony charges of

trafficking methamphetamine and tampering with evidence. The Commonwealth

agreed to reduce the trafficking charge to possession. The circuit court then

imposed an agreed-upon sentence of eight years with probation.

One month into his probation, a social media post showed Rice

holding a gun to his head. Rice admitted he did this on Thanksgiving Day 2018.

The parties addressed this violation with the circuit court in February 2019. One of

the attorneys described Rice’s behavior as a “lark,”2 and the circuit court took no

action on the violation. In June 2019, Rice committed disorderly conduct, and no

action was taken on this violation.

Then after another traffic stop in May 2020, Rice was arrested again

for trafficking in methamphetamine and tampering with evidence. An additional

charge of impersonating an officer resulted from the discovery of a badge of an

officer with the Tennessee Department of Corrections in Rice’s possession. The

circuit court revoked Rice’s probation in October 2020. Although Rice criticizes

this decision also, there was no timely appeal of that revocation decision.

2 In American English, a lark is defined as “a merry, carefree adventure; frolic; escapade” or as an “innocent or good-natured mischief; a prank.” Lark, COLLINS DICTIONARY https://www.collinsdictionary.com/dictionary/lark (last visited Jun. 3, 2026). A felon with a history of drug trafficking having a handgun and mimicking suicide is not a lark.

-2- The circuit court granted shock probation in May 2021. After yet

another traffic stop in December 2024, Rice was again arrested for trafficking in

methamphetamine and tampering with evidence. The circuit court conducted a

hearing to address revocation in February 2025. The primary evidence at this

hearing was the testimony of the arresting officer, Kentucky State Trooper, Joseph

Pineiroa.

Pineiroa stopped the car being driven by Rice in Elizabethtown

because the rear license plate was not illuminated. The female passenger was

acting very nervous with rapid speech and trouble standing still. She initially got

out of the car without permission and had to be told to get back in the car. Pineiroa

called for a canine unit when Rice refused consent to search.

Eventually, Pineiroa found two marijuana “blunts,” a “large quantity”

of plastic bags, a digital scale, pipes, and a large knife near the driver’s seat.

During the interaction, a bag of marijuana and two bags of methamphetamine were

discovered on Rice along with a cut straw. The bag of marijuana and one bag of

methamphetamine fell off Rice during the arrest process. Another bag of

methamphetamine was not discovered until Rice admitted to having it on him just

before jail processing. The total methamphetamine quantity was eighteen grams.

The prosecutor argued that Rice had been shown leniency enough and

that it was simply unacceptable for him to have 18 grams of methamphetamine

-3- while on shock probation. Seeing the obviousness and seriousness of the violation,

Rice’s attorney did not argue that a violation had not been established3 but rather

simply said: “I would just ask for leniency.” The Court revoked the shock

probation and entered a standard order for that purpose. This appeal follows. The

briefs filed by the parties are sufficiently compliant with the Kentucky Rules of

Appellate Procedure (RAP) not to require comment.

STANDARD OF REVIEW

A decision by the circuit court to revoke probation is reviewed for

abuse of discretion. See Southwood v. Commonwealth, 372 S.W.3d 882, 884 (Ky.

App. 2012). An abuse of discretion occurs only when the decision is “arbitrary,

unreasonable, unfair, or unsupported by sound legal principles.” Id. (citations

omitted). “Generally, a trial court’s decision revoking probation is not an abuse of

discretion if there is evidence to support at least one probation violation.” Lucas v.

Commonwealth, 258 S.W.3d 806, 807-08 (Ky. App. 2008). As for sufficient

compliance with KRS 439.3106(1)(a), this presents a legal question, and legal

3 Because probation revocation requires proof only by a preponderance of the evidence, the subsequent outcome of a pending criminal charge which has served as a probation violation is largely irrelevant. Even so, we have the benefit of the subsequent proceedings in the Hardin Circuit Court of which we may take judicial notice. T.C. v. M.E., 603 S.W.3d 663, 667 n.6 (Ky. App. 2020). Rice was again given yet another break after the December 2024 arrest when he entered an unconditional guilty plea to trafficking in less than two grams of methamphetamine and received a three-year sentence. Commonwealth v. Rice, Hardin Circuit Court, Case No. 25- CR-00130 (Judgment entered October 28, 2025).

-4- questions are reviewed de novo. Vincent v. Commonwealth, 706 S.W.3d 94, 99

(Ky. 2024).

ANALYSIS

KRS 439.3106 provides:

(1) Supervised individuals shall be subject to:

(a) Violation revocation proceedings and possible incarceration for failure to comply with the conditions of supervision when such failure constitutes a significant risk to prior victims of the supervised individual or the community at large, and cannot be appropriately managed in the community[.]

A circuit court must make the two findings required by this statute to revoke

probation. It may do so orally or in writing. Commonwealth v. Andrews, 448

S.W.3d 773 (Ky. 2014). The circuit court here entered a written order which

included a finding of a probation violation and the further findings that Rice’s

“failure to comply with the terms of probation constitutes a significant risk to his

or her prior victims or community at large and that the probationer cannot be

appropriately managed in the community[.]” The circuit court also noted no other

alternative to imposing the sentence.

We have observed that circuit judges sometimes offer further

explanation to support these findings, but this is not necessary. Since Andrews,

this Court has consistently held that “[n]either KRS 439.3106 nor Andrews require

-5- anything more than a finding to this effect supported by the evidence of record.”

McClure v.

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

Related

Lucas v. Commonwealth
258 S.W.3d 806 (Court of Appeals of Kentucky, 2008)
Southwood v. Commonwealth
372 S.W.3d 882 (Court of Appeals of Kentucky, 2012)
Commonwealth v. Andrews
448 S.W.3d 773 (Kentucky Supreme Court, 2014)
McClure v. Commonwealth
457 S.W.3d 728 (Court of Appeals of Kentucky, 2015)
Helms v. Commonwealth
475 S.W.3d 637 (Court of Appeals of Kentucky, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Sanford D. Rice v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanford-d-rice-v-commonwealth-of-kentucky-kyctapp-2026.