Tara K. Thomas v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedFebruary 8, 2024
Docket2022 CA 001387
StatusUnknown

This text of Tara K. Thomas v. Commonwealth of Kentucky (Tara K. Thomas 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
Tara K. Thomas v. Commonwealth of Kentucky, (Ky. Ct. App. 2024).

Opinion

RENDERED: FEBRUARY 9, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-1387-MR

TARA K. THOMAS APPELLANT

APPEAL FROM WARREN CIRCUIT COURT v. HONORABLE JOE W. HENDRICKS, JR., SPECIAL JUDGE ACTION NO. 21-CR-01268

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: EASTON, KAREM, AND TAYLOR, JUDGES.

EASTON, JUDGE: The Appellant, Tara K. Thomas (“Thomas”), seeks reversal of

the final judgment of the Warren Circuit Court after a jury convicted her of

Retaliating Against a Participant in the Legal Process. Thomas contends the circuit

court erred in admitting too much evidence for the Commonwealth, including

misuse of KRE1 404(b), as contrasted with too little evidence allowed for her,

1 Kentucky Rules of Evidence. depriving Thomas of the opportunity to present a complete defense. Thomas also

believes the circuit court erred by amending the Indictment after the close of the

evidence with a consistent instruction to the jury and failing to give an instruction

for Harassing Communications as a lesser-included offense. Evaluation of this

record reveals no error by the circuit court. We affirm.

FACTUAL AND PROCEDURAL BACKGROUND

Because of events alleged to have occurred on October 7, 2020,

Thomas was charged with two counts each of Third-Degree Assault (of police

officers) and Third-Degree Terroristic Threatening, with additional counts of

Alcohol Intoxication, Resisting Arrest, and Harassment.2 Because of Thomas’ lack

of any disqualifying criminal record, the Commonwealth offered a felony pretrial

diversion to Thomas on September 20, 2021. Assistant Commonwealth Attorney,

Kori Beck Bumgarner (“Bumgarner”), communicated this offer to Thomas’

attorney.

2 Warren District Court Case No. 20-F-01090. Because we seek to present a complete picture for both sides of this case, we will refer to court records of cases referred to by the parties during the case. Judicial notice may not be taken of Kentucky CourtNet records to present as evidence in a trial. See Marchese v. Aebersold, 530 S.W.3d 441 (Ky. 2017). But information about the existence of charges may be referenced by an appellate court to provide perspective for the trial court proceedings. See, e.g., Mulazim v. Commonwealth, 600 S.W.3d 183, 203 n.6 (Ky. 2020). After the trial in this case, Thomas pled guilty to amended misdemeanor charges in Case No. 20- F-01090, which had by then resulted in an Indictment filed as Warren Circuit Court Case No. 21- CR-01096.

-2- The diversion offer included a requirement to serve some time as an

alternate sentence. Thomas reacted badly to this offer. On the night of September

20-21, 2021, Thomas sent a series of messages to Bumgarner, her husband, and her

stepfather. In summary, these messages included vulgar language and declared

death to Bumgarner and her two small children. Thomas was indicted on

November 17, 2021.

There were delays in this case because of the identity of the victim. A

special judge and a special prosecutor from other counties were appointed.

Thomas’ retained attorney withdrew because of a “breakdown of trust” according

to Thomas. It then took more time to appoint public defenders from another office.

This was needed because local public defenders worked frequently with

Bumgarner.

The delays led to more time in pretrial custody for Thomas. Thomas

was out on a bond for this case, but this bond was eventually revoked due to a

confirmed positive drug test (methamphetamine). The special prosecutor also

reported that he and his wife had received attempts at communication from

Thomas, although this was not confirmed with evidence in the record. Thomas

denied this. Even with the delays, the circuit court acceded to Thomas’ demand

that the case be tried promptly, despite the concerns of her appointed counsel.

-3- The circuit court conducted a pretrial conference on July 29, 2022. At

this pretrial conference, KRE 404(b) issues were addressed. The first day of the

trial was used to select a jury. The rest of the trial took place on August 3, 2022.

During the trial, the circuit court allowed Bumgarner’s husband and stepfather to

testify about the messages they had received, which were reported to Bumgarner.

Emotional testimony described Bumgarner’s reactions to the threats on the day

they were received.

Thomas’ defense focused on her intent. She sought to prove that she

was expressing frustration with the justice system, not actual threats of harm. With

each witness, her counsel pointed out that the messages contained no actual

specific threat of how harm would come to Bumgarner. No witness called 911.

Thomas lived an hour away. Additionally, Thomas wanted to call her mother as a

witness to present evidence of Thomas’ frustration. After a discussion among

counsel and the circuit court for over ten minutes, Thomas decided not to call any

witnesses.

At the conclusion of the evidence, the circuit court instructed the jury

with respect to threats not just about Bumgarner but also about her children,

although the Indictment referred only to Bumgarner by name. The jury convicted

Thomas and fixed her sentence at four years. The circuit court imposed this

-4- sentence, denying probation. The circuit court denied a new trial motion. We will

develop more details of the case as we address the appeal contentions.

STANDARD OF REVIEW

The circuit court’s evidentiary rulings are reviewed for abuse of

discretion. Woodard v. Commonwealth, 147 S.W.3d 63, 67 (Ky. 2004). “The test

for abuse of discretion is whether the trial judge’s decision was arbitrary,

unreasonable, unfair or unsupported by sound legal principles.” Id. We review

legal questions de novo. We must determine whether the circuit court committed

error in the amendment of the Indictment or in its jury instructions, including

whether to instruct on a lesser included offense. See Fields v. Commonwealth, 219

S.W.3d 742 (Ky. 2007) (a case involving both issues).

ANALYSIS

We will review the evidentiary issues first as they will provide context

for the other decisions made by the circuit court. Thomas argues the presentation

of messages sent to Bumgarner’s husband and stepfather violated KRE 404. She

also insists the evidence about Bumgarner’s reaction to the messages was improper

for the first phase of the trial and should have been limited to the sentencing phase

as victim impact evidence. We start with the KRE 404 issues.

KRE 404(b) is often imprecisely referred to as a rule governing “prior

bad acts.” The acts offered as evidence can be contemporaneous or even after the

-5- events at issue so long as they are offered and considered only for a proper purpose

other than the character of the actor. In this case, the evidence about the messages

served an important purpose other than an attack on Thomas’ character.

Retaliation Against a Participant in the Legal Process occurs when

someone “threatens to engage in conduct causing or intended to cause bodily

injury[3] . . . [to] a participant in the legal process.” KRS4 524.055(1). As it

pertains to this case, other elements are that the threat related to Bumgarner for

performing her duty as a prosecutor.

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Related

Stirone v. United States
361 U.S. 212 (Supreme Court, 1960)
Virginia v. Black
538 U.S. 343 (Supreme Court, 2003)
Woodard v. Commonwealth
147 S.W.3d 63 (Kentucky Supreme Court, 2004)
Fields v. Commonwealth
219 S.W.3d 742 (Kentucky Supreme Court, 2007)
Luttrell v. Commonwealth
554 S.W.2d 75 (Kentucky Supreme Court, 1977)
Capshaw v. Commonwealth
253 S.W.3d 557 (Court of Appeals of Kentucky, 2007)
Clark v. Commonwealth
267 S.W.3d 668 (Kentucky Supreme Court, 2008)
Johnson v. Commonwealth
864 S.W.2d 266 (Kentucky Supreme Court, 1993)
Stephen Marchese v. Allison Aebersold
530 S.W.3d 441 (Kentucky Supreme Court, 2017)
Hammonds v. State
80 A.3d 698 (Court of Appeals of Maryland, 2013)

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