Teresa Rene Tyler v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedDecember 12, 2025
Docket2024-CA-0362
StatusUnpublished

This text of Teresa Rene Tyler v. Commonwealth of Kentucky (Teresa Rene Tyler 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
Teresa Rene Tyler v. Commonwealth of Kentucky, (Ky. Ct. App. 2025).

Opinion

RENDERED: DECEMBER 12, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-0362-MR

TERESA RENE TYLER APPELLANT

APPEAL FROM MCCRACKEN CIRCUIT COURT v. HONORABLE JOSEPH ROARK, JUDGE ACTION NO. 18-CR-00389-002

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: ECKERLE, A. JONES, AND TAYLOR, JUDGES.

ECKERLE, JUDGE: Appellant, Teresa Rene Tyler (“Tyler”), pro se, appeals the

McCracken Circuit Court’s Order entered February 14, 2024, denying her motion

seeking post-conviction relief pursuant to Kentucky Rule of Civil Procedure

(“CR”) 60.02(f). Finding no basis for relief, we affirm. I. Factual and Procedural History

Between approximately March 9, 2018, and March 30, 2018, Jennifer

Lynn Smith (“Smith”) and her two minor children, J.B., six years old, and M.S.,

three years old, resided with Tyler at her residence in Paducah, Kentucky. On

March 30, 2018, Smith took J.B. to the office of Dr. Caitlyn Cecil seeking an

adjustment to his medication as the result of what she claimed were behavioral

changes. Witnessing a severe and infected injury to J.B.’s buttocks, significant

bruising from his left ear to his left eye and cheek, and other signs of child abuse

and neglect, Dr. Cecil contacted law enforcement and immediately admitted J.B. to

Baptist Hospital. At the hospital, Dr. Cecil and law enforcement officials

witnessed and documented evidence of an infected burn and other severe injuries

to J.B., as well as injuries to M.S.’s buttocks and legs and signs of malnourishment

and neglect of both children. After a subsequent investigation, law enforcement

arrested both Tyler and Smith.

On May 18, 2018, the McCracken County Grand Jury indicted Tyler

and Smith on the following criminal charges: Count 1, First-Degree Criminal

Abuse – Child 12 or Under, J.B.; Count 2, First-Degree Criminal Abuse – Child 12

or Under, M.S.; and Count 3, First-Degree Assault, J.B. Trial Record (“TR”) 1, at

-2- p. 1.1 The Grand Jury’s true bill alleged that between March 9, 2018, through

March 30, 2018, Tyler along with Smith, acting alone or in complicity with one

another, intentionally abused and caused the torture, confinement, and cruel

punishment of Smith’s two children. Id. The indictment also charged Tyler and

Smith with causing serious physical injury to J.B. by means of a deadly weapon or

dangerous instrument. Id.

On May 31, 2018, Tyler appeared before the McCracken Circuit

Court (“Trial Court”), represented by private counsel, and entered a plea of “Not

Guilty.” TR 1, at pp. 97-100. On August 3, 2018, Tyler again appeared before the

Trial Court seeking a continuance and substitution of counsel. The Trial Court

granted Tyler’s continuance and appointed counsel from the Department of Public

Advocacy (“DPA”) to represent her. On September 7, 2018, a new private

attorney filed an appearance on Tyler’s behalf. However, on December 11, 2018,

DPA counsel filed a notice of substitution of counsel. Upon motion of the

Commonwealth on November 8, 2018, the Trial Court entered an Order to Sever

Tyler’s and Smith’s cases for the purpose of trial. The Trial Court set Tyler’s trial

date for February 19, 2019.

1 The Trial Record is composed of three bound volumes. There are two binders labeled “Volume 1” and one more labeled “Volume 2.” The binder labeled “Volume 1” that is re-paginated beginning with Tyler’s February 5, 2024, Motion under CR 60.02 will be referenced as “TR 1 Supp.” We will reference the other volumes “TR 1” and “TR 2.”

-3- On February 1, 2019, represented by DPA counsel, Tyler accepted a

written offer from the Commonwealth to plead guilty to all three counts of the

indictment. She signed an admission that she, in complicity with Smith:

[C]aused severe injuries to J.B., a minor child under 12 years, by burning him with a hot pan. The injuries required medical intervention and a skin graft in order to heal. From March 9, 2018, through March 30, 2018, [she and Smith] caused torture, cruel confinement and cruel punishment to two children, under the age of [12]. They locked them in closets, withheld food and forced them to eat urine and feces.

TR 2, at p. 184. On the “Motion to Enter Guilty Plea,” signed by Tyler and her

DPA counsel, the Commonwealth recommended a sentence of 10 years’

incarceration on each count, to run concurrently, which is the minimum sentence

for a class B felony. TR 2, at p. 181-184. The Commonwealth also recommended

that Tyler should not be eligible for probation or parole until she will have served

at least 85% of her sentence. Id., at p. 184.

On April 12, 2019, Tyler appeared before the Trial Court for

sentencing. The Trial Court gave Tyler and her DPA counsel the opportunity to

present any reasons for mitigation of punishment or for Tyler to make any

statements on her own behalf. The Trial Court noted the agreement between Tyler

and the Commonwealth upon her guilty plea and found that Tyler understood the

nature of the charges, that her plea was voluntary, and that she knowingly and

-4- voluntarily waived a jury trial and many other rights. The Trial Court considered

the nature and circumstances of Tyler’s crime and her criminal history.

On April 16, 2019, the Trial Court issued its Final Judgment/Sentence

of Imprisonment. The Trial Court followed the recommendations in the plea

agreement and sentenced Tyler to serve 10 years’ incarceration on each count of

the indictment, to be served concurrently, without eligibility for parole until she

has served 85% of her sentence. The Trial Court credited her with time served per

Kentucky Revised Statute (“KRS”) 532.120, and waived all Court costs and fines,

adjudging her to be a poor person as defined by KRS 453.190(2).

On June 19, 2019, with assistance of counsel, and again on August

19, 2019, acting pro se, Tyler moved the Trial Court to suspend further execution

of her sentence (“shock probation”), which the Trial Court denied on June 28,

2019, and August 27, 2019, respectively.

Just over three years after her sentencing, on April 29, 2022, Tyler

filed a motion to amend her final judgment pursuant to CR 60.02(f), CR 60.03, and

the Eighth and Fourteenth Amendments to the United States (“U.S.”) Constitution.

TR 2, at pp. 216-225. Tyler argued that she risked contracting SARS-CoV2

(“COVID-19”) during her confinement and that her “continued incarceration under

[those] circumstances [was] cruel and unusual punishment prohibited by the Eighth

and Fourteenth Amendments.” TR 2, at p. 221. Tyler also moved for the

-5- appointment of DPA counsel. Significantly, Tyler did not move to vacate, set

aside, or correct any part of her sentence under Kentucky Rule of Criminal

Procedure (“RCr”) 11.42; she did not plead ineffective assistance of counsel; and

she did not plead any trial errors.

On May 10, 2022, the Trial Court entered an Order Denying Relief,

finding that her risk of contracting COVID-19 was not a trial defect and, therefore,

did not “amount to claims of an extraordinary nature justifying relief from

judgment” under CR 60.02 and this Court’s decision in Ramsey v. Commonwealth,

453 S.W.3d 738 (Ky. App. 2014). TR 2, p. 237-238.

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