Shawn Ogden v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedMarch 17, 2022
Docket2021 CA 000261
StatusUnknown

This text of Shawn Ogden v. Commonwealth of Kentucky (Shawn Ogden 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
Shawn Ogden v. Commonwealth of Kentucky, (Ky. Ct. App. 2022).

Opinion

RENDERED: MARCH 18, 2022; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2021-CA-0261-MR

SHAWN OGDEN APPELLANT

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE A. C. MCKAY CHAUVIN, JUDGE ACTION NO. 15-CR-002205

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, DIXON, AND K. THOMPSON, JUDGES.

DIXON, JUDGE: Shawn Ogden, pro se, appeals from an order of the Jefferson

Circuit Court, entered on February 4, 2021, denying his motion to amend his

prison sentence pursuant to CR1 60.02(f), CR 60.03, and the Fifth, Eighth, and

Fourteenth Amendments to the United States Constitution. Following review of

the record, briefs, and law, we affirm.

1 Kentucky Rules of Civil Procedure. FACTS AND PROCEDURAL BACKGROUND

On October 27, 2015, having pled guilty to three counts of burglary,

Ogden was sentenced to three years for each count, to run consecutively for a total

sentence of nine years, which was probated for five years. On December 20, 2018,

following Ogden’s stipulation to violating the terms of his probation, the trial court

entered an order revoking his probation. In February 2021, Ogden moved the trial

court to amend the final judgment pursuant to CR 60.02, CR 60.03, and the Fifth,

Eighth, and Fourteenth Amendments to the United States Constitution, which the

trial court denied shortly thereafter. This appeal followed.

STANDARD OF REVIEW

This Court reviews orders on CR 60.02 motions for abuse of

discretion. White v. Commonwealth, 32 S.W.3d 83, 86 (Ky. App. 2000) (citation

omitted). A trial court’s denial of a CR 60.03 motion is also reviewed for abuse of

discretion. Rogers Grp., Inc. v. Masterson, 175 S.W.3d 630, 636 (Ky. App. 2005)

(citations omitted). “The test for abuse of discretion is whether the trial judge’s

decision was arbitrary, unreasonable, unfair, or unsupported by sound legal

principles.” Foley v. Commonwealth, 425 S.W.3d 880, 886 (Ky. 2014) (citation

omitted). Questions of constitutionality are reviewed de novo. Phon v.

Commonwealth, 545 S.W.3d 284, 290 (Ky. 2018) (citation omitted).

-2- ANALYSIS

Ogden is currently incarcerated at the Bell County Forestry Camp and

argues he is entitled to relief from the remainder of his sentence due to the risk of

contracting SARS-CoV-2 (“COVID-19”). More specifically, Ogden argues: (1)

the trial court abused its discretion in denying his motion under CR 60.02(f); (2)

the trial court abused its discretion in denying his motion under CR 60.03; and (3)

he is entitled to relief under the Fifth, Eighth, and Fourteenth Amendments to the

United States Constitution.

First, Ogden is not entitled to relief under CR 60.02(f). The Supreme

Court of Kentucky has held there is a “high standard for granting a CR 60.02

motion,” because relief under CR 60.02 is designed to be “special” and

“extraordinary.” Barnett v. Commonwealth, 979 S.W.2d 98, 101-02 (Ky. 1998).

“[B]ecause of the desirability of according finality to judgments, CR 60.02(f) must

be invoked only with extreme caution, and only under most unusual

circumstances.” Commonwealth v. Bustamonte, 140 S.W.3d 581, 584 (Ky. App.

2004) (citation omitted).

Although the COVID-19 pandemic may be considered unusual and

extraordinary, CR 60.02 “functions to address significant defects in the trial

proceedings.” Ramsey v. Commonwealth, 453 S.W.3d 738, 739 (Ky. App. 2014)

(citing Wine v. Commonwealth, 699 S.W.2d 752, 754 (Ky. App. 1985)). Here,

-3- Ogden does not allege error stemming from any trial proceedings; rather, he argues

for release based on nebulous concerns for his health as a result of the COVID-19

pandemic. However, health concerns are not trial defects and do not qualify as

“claims of an extraordinary nature” entitling Ogden to relief under CR 60.02(f).

Ramsey, 453 S.W.3d at 739 (internal quotation marks and citation omitted). In

fact, we have rejected similar COVID-19-based arguments of other prisoners.

Williams v. Commonwealth, Nos. 2019-CA-0964-MR and 2020-CA-0638-MR,

2021 WL 943753 (Ky. App. Mar. 12, 2021); Gribbins v. Commonwealth, No.

2020-CA-0635-MR, 2021 WL 1164461 (Ky. App. Mar. 26, 2021); Morris v.

Commonwealth, No. 2020-CA-1195-MR, 2021 WL 1933656 (Ky. App. May 14,

2021); Thomas v. Commonwealth, No. 2020-CA-1081-MR, 2021 WL 3117200

(Ky. App. Jul. 23, 2021); Eaves v. Commonwealth, No. 2020-CA-1276-MR, 2021

WL 3818113 (Ky. App. Aug. 27, 2021); and Jackson v. Commonwealth,

___ S.W.3d ___, 2022 WL 332725 (Ky. App. Feb. 4, 2022).

Ultimately, because Ogden does not raise claims of error from a

defect in trial proceedings, he is not entitled to CR 60.02 relief. See Wine, 699

S.W.2d at 754. Thus, the trial court did not abuse its discretion in denying his CR

60.02 motion.

Second, Ogden’s claim under CR 60.03 must also fail. CR 60.03

states:

-4- Rule 60.02 shall not limit the power of any court to entertain an independent action to relieve a person from a judgment, order or proceeding on appropriate equitable grounds. Relief shall not be granted in an independent action if the ground of relief sought has been denied in a proceeding by motion under Rule 60.02, or would be barred because not brought in time under the provisions of that rule.

The plain language of CR 60.03 requires a separate, independent action. There is

no evidence that occurred herein.

Even so, Ogden’s argument is the same as that which fails under CR

60.02(f); consequently, he is not entitled to relief under CR 60.03. Foley, 425

S.W.3d at 888 (quoting CR 60.03) (“Appellant is not entitled to relief under CR

60.02. As such, in effect, the ‘relief sought [in his CR 60.03 action] has been

denied in a proceeding by motion under Rule 60.02.’ It follows that Appellant is

not entitled to relief under CR 60.03.”). Likewise, similar CR 60.03 arguments

made by other inmates during the COVID-19 pandemic have been consistently

rejected. Williams, 2021 WL 943753, at *2-3; Gribbins, 2021 WL 1164461, at *2;

Morris, 2021 WL 1933656, at *2; Thomas, 2021 WL 3117200, at *2; Eaves, 2021

WL 3818113, at *2; and Jackson, ___ S.W.3d ___, 2022 WL 332725, at *3.

Additionally, CR 60.03 “is intended as an equitable form of relief

when no other avenue exists.” Meece v. Commonwealth, 529 S.W.3d 281, 295

(Ky. 2017). To be entitled to such relief, Ogden must establish three necessary

elements. The Supreme Court of Kentucky has held:

-5- Generally, claimants seeking equitable relief through independent actions must meet three requirements.

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Related

Rogers Group, Inc. v. Masterson
175 S.W.3d 630 (Court of Appeals of Kentucky, 2005)
Bowling v. Commonwealth
163 S.W.3d 361 (Kentucky Supreme Court, 2005)
White v. Commonwealth
32 S.W.3d 83 (Court of Appeals of Kentucky, 2000)
Commonwealth v. Bustamonte
140 S.W.3d 581 (Court of Appeals of Kentucky, 2004)
Barnett v. Commonwealth
979 S.W.2d 98 (Kentucky Supreme Court, 1998)
Milby v. Mears
580 S.W.2d 724 (Court of Appeals of Kentucky, 1979)
William Harry Meece v. Commonwealth of Kentucky
529 S.W.3d 281 (Kentucky Supreme Court, 2017)
Wine v. Commonwealth
699 S.W.2d 752 (Court of Appeals of Kentucky, 1985)
Foley v. Commonwealth
425 S.W.3d 880 (Kentucky Supreme Court, 2014)
Ramsey v. Commonwealth
453 S.W.3d 738 (Court of Appeals of Kentucky, 2014)
Phon v. Com. of Ky.
545 S.W.3d 284 (Missouri Court of Appeals, 2018)
Woodall v. Commonwealth
563 S.W.3d 1 (Missouri Court of Appeals, 2018)

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