Tammy Roberts v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedMarch 26, 2020
Docket2018-SC-0249
StatusUnpublished

This text of Tammy Roberts v. Commonwealth of Kentucky (Tammy Roberts 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
Tammy Roberts v. Commonwealth of Kentucky, (Ky. 2020).

Opinion

RENDERED: MARCH 26, 2020 TO BE PUBLISHED

2018-SC-000249-MR

TAMMY ROBERTS APPELLANT

ON APPEAL FROM GRAVES CIRCUIT COURT V. HONORABLE TIMOTHY C. STARK, JUDGE NO. 17-CR-00131

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION OF THE COURT BY JUSTICE WRIGHT

REVERSING, VACATING, AND REMANDING

A Graves Circuit Court jury convicted Appellant, Tammy Marie Roberts,

of murder and recommended a twenty-year sentence. Roberts was sentenced

in accordance with the jury’s recommendation, and now appeals to this Court

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

Roberts raises four claims of error in her appeal, alleging: (1) the trial

court erred in failing to grant a mistrial, (2) the trial court erred in refusing to

instruct on self-defense and imperfect self-defense, (3) the trial court erred in

ruling she did not qualify for the domestic violence exemption, and, (4) that she

should be granted a new trial because of cumulative errors. For the following

reasons, we reverse Roberts’s conviction, vacate her sentence, and remand to

the trial court for further proceedings consistent with this opinion. I. BACKGROUND

James Pinion died on February 10, 2017, from a single stab wound to

the chest. Roberts, Pinion’s girlfriend, was charged with his murder. Pinion

and Roberts lived together and shared a two-bedroom trailer with David and

Amy Hogg, a married couple. All four roommates frequently used drugs.

The night Pinion died, the Hoggs overheard an argument between Pinion

and Roberts. The argument resulted from a trip to the Dollar General Store by

Roberts and Amy. The toxic and turbulent relationship between Pinion and

Roberts was such that Pinion required Roberts to acquire his permission before

leaving the trailer—and to show him her underwear both before leaving the

trailer and after returning home. The day in question, Roberts failed to obtain

his permission, leading to an argument when she got home.

At some point, Amy heard blows being exchanged. Then, Roberts exited

the bedroom and talked to Amy in the kitchen for a few moments. Roberts told

Amy that Pinion had her medication and would not give it back to her. Then,

shortly before the stabbing, David heard Roberts and Pinion arguing and went

into their bedroom. Roberts told David that Pinion had her money and would

not give it back. David told Pinion to return the money and Pinion threw three

twenty-dollar bills on the bed. Police would later find three blood-soaked

twenty-dollar bills in the shoes Roberts wore. Shortly after David left the room

with the two still arguing, he heard Roberts scream “help” and saw Pinion

slumping in the hallway bleeding. Pinion was declared dead at the hospital.

2 In multiple statements to police, Roberts claimed Pinion accidentally fell

on the knife when he got his foot tangled in a sheet. Roberts maintained there

was no domestic violence the night Pinion was stabbed even after multiple

attempts by police to get Roberts to admit to stabbing Pinion in self-defense.

This denial was made despite both Amy and David hearing an argument prior

to the stabbing, Amy reporting the sound of someone being hit, and fresh

bruises and apparent red slap marks on Roberts observed by police that night.

Prior to trial, the Commonwealth gave Kentucky Rules of Evidence (KRE)

404(c) notice that it intended to introduce one of Roberts’s prior bad acts: a

2003 first-degree assault conviction from Fulton County. Roberts filed a

motion in limine seeking to prevent introduction of this prior assault. The trial

court issued a written order stating the Commonwealth could use information

regarding the prior crime in its case-in-chief if it first laid the proper

foundation.

The morning of trial, Roberts sought clarification of the court’s earlier

ruling. In response, the Commonwealth indicated it would redact those

portions of Roberts’s various recorded statements to police in which officers

confronted her with the prior assault. However, when the recordings were

played in the presence of the jury during trial, numerous statements were

played concerning the prior assault.

Roberts did not testify. She tendered and argued for self-defense

language in the murder instruction as well as for imperfect self-defense

instructions for second-degree manslaughter and reckless homicide. The trial

3 court overruled the tendered instructions, finding no evidence in the record to

support them. The jury convicted Roberts of wanton murder and

recommended a twenty-year sentence.

After the jury convicted Roberts, she moved the trial court to apply the

domestic violence victims’ exemption to change her parole eligibility from 85%

to 20%. The trial court overruled the motion finding there was no evidence

connecting the crime with an act of domestic violence.

II. ANALYSIS

A. Mistrial

During trial, the Commonwealth played recordings of police interviews

with Roberts. Multiple times in playing these recordings, the Commonwealth

failed to follow the trial court’s order to remove references to a prior assault

Roberts committed fourteen years prior to Pinion’s death. Roberts made three

mistrial motions during trial after the Commonwealth played the inadequately

redacted recordings.

1. KRE 404(b)

As a preliminary matter to determining whether the trial court abused its

discretion in failing to grant a mistrial, we examine whether the trial court

erred in ruling to allow the admission of KRE 404(b) evidence regarding the

fourteen-year-old Pulton County assault.

While KRE 404(a) states the general rule that “[ejvidence of a person’s

character or a trait of character is not admissible for the purpose of proving

action in conformity therewith on a particular occasion,” the rule goes on to

4 enumerate exceptions when evidence of one’s character may be used.

Specifically, KRE 404(b) reads, in pertinent part:

[e]vidence of other crimes, wrongs, or acts is not admissible to prove the character of a person in order to show action in conformity therewith. It may, however, be admissible:

(1) If offered for some other purpose, such as proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident ....

In examining whether the prior assault fit within the KRE 404(b)

exception, the trial court examined the similarities in the two crimes. The trial

court reviewed tendered documents from the 2003 assault in conducting its

review. In 2003, Roberts and her then-boyfriend, Louis Estrada, got into a

physical altercation. Roberts alleged Estrada had held her by her head and

punched her. According to Roberts, she stabbed him after he kept “getting in

her face.” Estrada countered that Roberts grabbed the knife while the two were

arguing. He said she lunged at him and stabbed him in the back as he was

walking away. Roberts ultimately pleaded guilty to first-degree assault in that

case after initially claiming it had been an accident.

The trial court emphasized the similarities in the cases, noting that in

both situations: Roberts’s victim was her then-boyfriend, Roberts and her

victim had been involved in an argument, Roberts said she had been hit,

Roberts stabbed the victim, and Roberts claimed an implausible story. After

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