Sophal Phon v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedNovember 18, 2020
Docket2019 CA 001564
StatusUnknown

This text of Sophal Phon v. Commonwealth of Kentucky (Sophal Phon 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
Sophal Phon v. Commonwealth of Kentucky, (Ky. Ct. App. 2020).

Opinion

RENDERED: NOVEMBER 20, 2020; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2019-CA-1564-MR

SOPHAL PHON APPELLANT

APPEAL FROM WARREN CIRCUIT COURT v. HONORABLE JOHN R. GRISE, JUDGE ACTION NO. 96-CR-00599-005

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, GOODWINE, AND LAMBERT, JUDGES.

LAMBERT, JUDGE: Sophal Phon appeals the Warren Circuit Court’s September

13, 2019, order denying his motion to vacate or set aside its judgment pursuant to

Kentucky Rule of Criminal Procedure (RCr) 11.42 and Kentucky Rule of Civil

Procedure (CR) 60.02. Finding no error, we affirm. In 1996, Phon and his fellow gang members entered the home of

Khamphao Phromratsamy and Manyavanh Boonprasert. At the direction of the

gang leader, Phon shot both individuals and their twelve-year-old daughter in the

head execution style. Khamphao and Manyavanh were killed while their daughter

miraculously survived. Phon was under the age of eighteen at the time.1

Given the brutality of the crime, the Commonwealth sought the death

penalty; however, Phon was ultimately sentenced to life without parole (LWOP).

Prior to his formal sentencing, Phon filed his first RCr 11.42 motion claiming

ineffective assistance of counsel. Finding no error, the circuit court denied the

requested relief and this Court affirmed. Phon v. Commonwealth, 51 S.W.3d 456,

458-61 (Ky. App. 2001).

In 2005, the Supreme Court of the United States (SCOTUS) rendered

a decision in Roper v. Simmons, 543 U.S. 551, 125 S.Ct. 1183, 161 L.Ed.2d 1

(2005), wherein it held that sentencing juveniles to death was unconstitutional.

Based on this, “Phon filed [a] motion for a new sentencing hearing . . . arguing

that, because he had been subject to the death penalty when he pled guilty, he

should be entitled to a new sentencing hearing.” Phon v. Commonwealth, No.

2006-CA-002456-MR, 2008 WL 612283, at *2 (Ky. App. Mar. 7, 2008). We

1 For a more detailed recitation of the facts giving rise to this case, see Phon v. Commonwealth, 545 S.W.3d 284 (Ky. 2018). -2- disagreed, holding that Phon was not entitled to change his guilty plea nor to a new

sentencing hearing because the maximum penalty was no longer applicable. Id. at

*4.

Subsequently, SCOTUS issued a series of Opinions concerning

LWOP sentences for juveniles: Graham v. Florida, 560 U.S. 48, 130 S.Ct. 2011,

176 L.Ed.2d 825 (2010) (holding that it is unconstitutional for juveniles to be

sentenced to LWOP for nonhomicide offenses); Miller v. Alabama, 567 U.S. 460,

132 S.Ct. 2455, 183 L.Ed.2d 407 (2012) (holding that sentencing schemes

mandating LWOP for juvenile offenders are unconstitutional); and Montgomery v.

Louisiana, 136 S.Ct. 718, 193 L.Ed.2d 599 (2016) (holding that the substantive

rule announced in Miller v. Alabama applied retroactively to finalized sentences).

Using these cases, Phon requested a new sentencing hearing pursuant

to RCr 11.42 and CR 60.02. Additionally, he argued that his sentence was

prohibited under Kentucky Revised Statute (KRS) 640.040(1), which provides that

the maximum sentence for a juvenile convicted of a capital offense is life without

parole for twenty-five years (LWOP-25). In a detailed analysis of SCOTUS’s

decisions, the Kentucky Supreme Court refused to rule that Phon’s sentence was

unconstitutional; however, it did agree that Phon’s sentence was statutorily

prohibited. Phon, 545 S.W.3d at 308-09. As a result, the matter was remanded to

the circuit court with instruction to impose a sentence of LWOP-25. Id. at 310.

-3- Following the instruction of the Kentucky Supreme Court, the circuit

court entered an order amending Phon’s sentence to LWOP-25, and he became

eligible for parole in 2022. Soon after the circuit court’s order was entered, Phon

filed a motion to vacate his amended LWOP-25 sentence pursuant to RCr 11.42

and CR 60.02 and requested a new sentencing hearing. On September 13, 2019,

the circuit court denied Phon’s motion, finding that his claim was not ripe and that

it was without merit. This appeal followed.

Phon claims his LWOP-25 sentence violates the Eighth Amendment

because Kentucky’s parole system does not provide a method by which a youthful

offender can demonstrate maturity and rehabilitation in order to receive a

meaningful opportunity for release. Although Phon cleverly attempted to style this

as a single issue, we believe his challenge contains two separate and distinct issues:

(1) whether his LWOP-25 sentence is constitutional and (2) whether the Kentucky

parole system, as it applies to juvenile offenders, violates the Eighth Amendment.

For the following reasons, the first challenge is prohibited under Kentucky law

while the latter is not ripe for judicial review.

Granting relief pursuant to RCr 11.42 or CR 60.02 is a power within

the sound discretion of the circuit court. Phon, 545 S.W.3d at 290. Therefore, we

review for abuse of discretion. Id.

-4- Kentucky law is clear that successive post-judgment motions are

impermissible. McQueen v. Commonwealth, 948 S.W.2d 415, 416 (Ky. 1997).

This is Phon’s fourth collateral attack. In his prior appeal, the Kentucky Supreme

Court carefully reviewed Phon’s sentence and analyzed Roper, Graham, Miller,

Montgomery, and KRS 640.040(1). The Court refused to rule that Phon’s LWOP

sentence was unconstitutional, and we are unconvinced the Court would come to a

different conclusion concerning Phon’s LWOP-25 sentence. 545 S.W.3d at 290-

99. The only reason Phon’s sentence was revised from LWOP to LWOP-25 is

because the LWOP sentence violated KRS 640.040(1). Id. at 308-09. Moreover,

the Court thoroughly discussed why the equitable remedy for Phon was to amend

his sentence to LWOP-25. Id. Phon has not directed our attention to, nor are we

aware of, any new law requiring us to distinguish the Kentucky Supreme Court’s

prior decision. “The Court of Appeals is bound by and shall follow applicable

precedents established in the opinions of the Supreme Court and its predecessor

court.” Rule of the Supreme Court (SCR) 1.030(8)(a). Thus, the court did not

abuse its discretion.

Phon’s second issue, that the Kentucky parole system as applied to

juvenile offenders violates the Eighth Amendment, is not ripe for judicial review.

As the Kentucky Supreme Court stated in Bingham Greenebaum Doll, LLP v.

Lawrence:

-5- Ripeness under federal law is a jurisdictional requirement under Article III of the United States Constitution. This requirement similarly appears under the Kentucky Constitution in that circuit courts have original jurisdiction of all justiciable causes not vested in some other court. For a claim to be justiciable, it must be ripe.

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Related

Abbott Laboratories v. Gardner
387 U.S. 136 (Supreme Court, 1967)
Califano v. Sanders
430 U.S. 99 (Supreme Court, 1977)
Roper v. Simmons
543 U.S. 551 (Supreme Court, 2005)
Phon v. Commonwealth
51 S.W.3d 456 (Court of Appeals of Kentucky, 2001)
McQueen v. Commonwealth
948 S.W.2d 415 (Kentucky Supreme Court, 1997)
Miller v. Alabama
132 S. Ct. 2455 (Supreme Court, 2012)
Montgomery v. Louisiana
577 U.S. 190 (Supreme Court, 2016)
W.B. v. Commonwealth, Cabinet for Health & Family Services
388 S.W.3d 108 (Kentucky Supreme Court, 2012)
Graham v. Florida
176 L. Ed. 2d 825 (Supreme Court, 2010)
Phon v. Com. of Ky.
545 S.W.3d 284 (Missouri Court of Appeals, 2018)
Bingham Greenebaum Doll, LLP v. Lawrence
567 S.W.3d 127 (Missouri Court of Appeals, 2018)

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