Taylor McKinney v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedApril 27, 2023
Docket2022 CA 000261
StatusUnknown

This text of Taylor McKinney v. Commonwealth of Kentucky (Taylor McKinney 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
Taylor McKinney v. Commonwealth of Kentucky, (Ky. Ct. App. 2023).

Opinion

RENDERED: APRIL 28, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-0261-MR

TAYLOR MCKINNEY APPELLANT

APPEAL FROM FAYETTE CIRCUIT COURT v. HONORABLE LUCY ANNE VANMETER, JUDGE ACTION NO. 20-CR-00061

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: COMBS, EASTON, AND ECKERLE, JUDGES.

EASTON, JUDGE: The Appellant (“McKinney”) seeks reversal of his conviction

for possession of matter portraying a sexual performance by a minor. The basis for

his request is the circuit court’s ruling denying his motion to suppress evidence

from his cell phone. Finding no error, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

Narcotics detectives had been investigating drug trafficking by

McKinney and his brother. They had sufficient evidence to obtain a valid search warrant. They executed that search warrant on July 3, 2019. This search warrant

specifically authorized the seizure of cell phones, which often contain evidence of

drug trafficking. The detectives seized McKinney’s cell phone, the contents of

which is the subject of the later motion to suppress.

The detectives wanted to see if McKinney would cooperate to help

find “bigger fish,” such as suppliers in the drug trafficking. They asked McKinney

if he would cooperate. Upon an indication McKinney would cooperate, the

detectives asked McKinney to provide the passcode for the phone. McKinney

purposefully gave the detectives a wrong passcode.

When the detectives were unable to get into the phone, they went back

to McKinney at his residence that same night. The detectives explained they

wanted to save time to help in the investigation. They needed the correct passcode.

McKinney again purposefully put in more incorrect passcodes, almost to the point

of locking the phone to a factory reset, a security setting on such phones. After

discussion of the terms of his consent, McKinney finally provided the correct

passcode.

The discussion about the written consent serves as the basis of the

suppression motion. Detective Todd Hart (“Hart”) testified about this second

interaction. Unknown to Hart, McKinney secretly was recording the interaction.

Hart made clear he knew what was in the phone – evidence of drug trafficking.

-2- There was no discussion of anything other than drug transaction related

information.

McKinney later said he did not suspect there was any evidence of any

crime other than the drug activity on his phone. McKinney did not believe the

videos he took of sex with a fifteen-year-old girl was a crime. His concern about

the phone was general, not specific to the sex videos.

To try to protect himself, McKinney altered the consent form. Hart

expressed no objection to that part of McKinney’s action with respect to language

about using evidence against McKinney, but McKinney wrote through language

about using information against others, which would be contrary to entire purpose

of the discussion. At this, Hart bristled and told McKinney he was either going to

grant consent or not, and the evidence would be obtained in the long run anyway.

McKinney finally provided the correct passcode.

Detective Rob Sinnott (“Sinnott”) reviewed the cell phone and found

video files. Sinnott explained such files often contain evidence relevant to drug

trafficking, such as showing drug inventory, money, or guns. On one video,

Sinnott recognized a girl from the scene of the search. Sinnott assumed this girl

was a friend of another girl in the home. Sinnott recalled confirming the girl’s age

as fifteen during the initial search.

-3- When Sinnott saw a video of the fifteen-year-old girl performing oral

sex on McKinney, he was not sure if that was evidence of a crime. Sinnott works

in narcotics. He had to look up the age difference to determine if the video was

evidence of a crime.

Once Sinnott suspected crimes different from drug trafficking, he

stopped his review and then sought and obtained a search warrant. The search

pursuant to that warrant found multiple videos of sexual activity between

McKinney and the girl. This evidence led to the ten counts in the indictment

against McKinney to which he pled guilty to a single count.

McKinney argued the detectives violated an immunity agreement

made with him. He further contended his consent was obtained by deception and

thus not voluntary. Connected with this voluntariness argument, McKinney

contends he should have been read his Miranda1 rights again when the detectives

came back to his house. The circuit court denied the motion in a detailed and well-

reasoned order. This appeal follows McKinney’s conditional guilty plea to a single

charge with a one-year probated sentence.

STANDARD OF REVIEW

A trial court’s denial of a motion to suppress is reviewed under a two-prong test. First, we review the trial court’s findings of fact under the clearly erroneous standard. Under this standard, the trial court’s findings of fact will

1 Miranda v. Arizona, 384 U.S. 436, 86 S. Ct. 1602, 16 L. Ed. 2d 694 (1966).

-4- be conclusive if they are supported by substantial evidence. Second, we review de novo the trial court’s application of the law to the facts.

Rhoton v. Commonwealth, 610 S.W.3d 273, 275-76 (Ky. 2020) (footnotes

omitted). Here, the controlling facts are not in dispute. They are mostly verified by

undisputed audio and video evidence. We therefore focus our analysis on whether

the circuit court properly applied these facts to the law.

ANALYSIS

We begin with the contention McKinney should have had his Miranda

rights repeated when the police returned to the home to talk with McKinney about

his phone. Earlier that day, the detectives had read the Miranda rights to

McKinney and previously given McKinney a citation for the drug charges. When

Hart returned to talk with McKinney again, Hart was not in uniform. He displayed

no weapon. The conversation occurred in McKinney’s residence. McKinney was

not arrested after the interaction. McKinney was not in custody, and repeated

Miranda warnings were not required. This was a consensual discussion during an

investigation. See Quintana v. Commonwealth, 276 S.W.3d 753 (Ky. 2008).

We next address the claim of an agreement between the detectives and

McKinney. First, we emphasize Kentucky law does not authorize a unilateral

grant of immunity by a prosecutor in exchange for testimony a witness may give.

Commonwealth v. Blincoe, 34 S.W.3d 822 (Ky. App. 2000). It stands to reason

-5- then a police officer, as an actual or apparent agent for the prosecutor, also has no

such authority.

Despite this limitation, prosecutors may make agreements not to

prosecute in exchange for testimony. In this case, the proffered agreement was to

provide the passcode in exchange for no charges. When the Commonwealth

makes an agreement and a defendant fulfills his part of the agreement, the

Commonwealth will be required to complete its promised terms. This was

established in Workman v. Commonwealth, 580 S.W.2d 206 (Ky. 1979), overruled

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Related

Miranda v. Arizona
384 U.S. 436 (Supreme Court, 1966)
Quintana v. Commonwealth
276 S.W.3d 753 (Kentucky Supreme Court, 2008)
Hughes v. Commonwealth
87 S.W.3d 850 (Kentucky Supreme Court, 2002)
Workman v. Commonwealth
580 S.W.2d 206 (Kentucky Supreme Court, 1979)
Morton v. Commonwealth
817 S.W.2d 218 (Kentucky Supreme Court, 1991)
Utilities Electrical MacHine Corp. v. Joseph E. Seagram & Sons, Inc.
187 S.W.2d 1015 (Court of Appeals of Kentucky (pre-1976), 1945)
Putty v. Commonwealth
30 S.W.3d 156 (Kentucky Supreme Court, 2000)
Commonwealth v. Blincoe
34 S.W.3d 822 (Court of Appeals of Kentucky, 2000)
Commonwealth v. Morseman
379 S.W.3d 144 (Kentucky Supreme Court, 2012)
Leger v. Commonwealth
400 S.W.3d 745 (Kentucky Supreme Court, 2013)

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Bluebook (online)
Taylor McKinney v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/taylor-mckinney-v-commonwealth-of-kentucky-kyctapp-2023.