Tiffany Hodges v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedNovember 15, 2024
Docket2023-CA-0902
StatusUnpublished

This text of Tiffany Hodges v. Commonwealth of Kentucky (Tiffany Hodges 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
Tiffany Hodges v. Commonwealth of Kentucky, (Ky. Ct. App. 2024).

Opinion

RENDERED: NOVEMBER 15, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-0902-MR

TIFFANY HODGES APPELLANT

APPEAL FROM HARDIN CIRCUIT COURT v. HONORABLE JOHN D. SIMCOE, JUDGE ACTION NO. 14-CR-00566

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

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

JONES, A., JUDGE: Tiffany Hodges, pro se, appeals the order of the Hardin

Circuit Court denying relief in response to her fifth post-conviction motion. We

affirm.

I. BACKGROUND

On June 19, 2015, Hodges entered a guilty plea to complicity to

murder, complicity to kidnapping, and theft by unlawful taking (over $500, less than $10,000). The charges stemmed from Hodges’ role in the kidnapping and

murder of Saul Flores with her co-defendant, Octavio Correa. In exchange for her

truthful testimony at Correa’s trial, the Commonwealth agreed not to seek the

death penalty against Hodges and would instead ask the trial court to impose a total

sentence of 20 to 50 years’ incarceration or life. On November 24, 2015, Hodges

appeared before the trial court for sentencing. The Commonwealth acknowledged

her role in the conviction of Correa as well as her willingness to cooperate and

asked the court to impose the minimum sentence of 20 years’ incarceration.

Hodges was sentenced to 20 years for complicity to murder, 20 years for

complicity to kidnapping, and 5 years for theft by unlawful taking; all terms to run

concurrently for a total of 20 years’ imprisonment. She did not appeal her

conviction.

Hodges’ first post-conviction motion for relief was filed four and one-

half years after her conviction. On May 19, 2020, Hodges requested modification

of her sentence due to the COVID-19 pandemic, arguing an increased risk of

infection in the prison system. The trial court denied her motion.

Hodges’ second motion for “sentence modification pursuant to CR[1]

60.02” was filed on December 2, 2020. Therein, Hodges argued her sentence was

1 Kentucky Rule of Civil Procedure.

-2- excessive. An order denying her motion was entered by the trial court on

December 15, 2020. On February 1, 2021, Hodges filed a notice of intent to

appeal and motioned the trial court to allow her to proceed in forma pauperis. On

February 5, 2021, the trial court entered an order denying the motion because

Hodges failed to include an affidavit of indigency. On February 26, 2021, she filed

a notice of intent to appeal in this Court. However, because the order on appeal

was entered on December 15, 2020, this Court dismissed the appeal as untimely on

May 10, 2021.2

Hodges’ third motion for “sentence modification pursuant to CR

60.02” was filed on July 9, 2021. It was substantively the same as her prior

motion. The trial court entered an order denying relief on July 21, 2021. At that

time, Hodges attempted to file a belated appeal in the Kentucky Supreme Court.

An order was entered denying relief and dismissing the appeal on June 29, 2022.

On August 12, 2022, Hodges filed her fourth motion for relief

pursuant to CR 60.02. The trial court entered an order denying relief on August

29, 2022. On September 12, 2022, Hodges filed another motion that was

substantively the same as the one denied just two weeks prior by the trial court.

Another order denying relief was entered on December 27, 2022. The trial court

entered a separate order on the same date that appointed the Department of Public

2 See Kentucky Court of Appeals Case No. 2021-CA-0258-MR.

-3- Advocacy (“DPA”) to represent Hodges on appeal. On August 1, 2023, DPA filed

a motion for belated appeal in this Court, explaining that it did not receive the trial

court’s order regarding appointment of counsel for appeal, and only found out

about the appeal after Hodges contacted its office. Although the Commonwealth

objected, this Court entered an order granting the belated appeal on October 5,

2023. However, on December 18, 2023, DPA filed a motion to withdraw as

counsel, citing, in relevant part, that “this ‘post-conviction proceeding . . . is not a

proceeding that a reasonable person with adequate means would be willing to bring

at his own expense.’ KRS[3] 31.110(2)(c). Thus, it appears that the Appellant has

‘no further right to be represented by counsel under the provisions of the [Public

Advocacy Statutes].’ KRS 31.110(2)(c).” This Court granted DPA’s motion to

withdraw and Hodges now proceeds pro se on appeal.

II. STANDARD OF REVIEW

Generally, a trial court’s denial of a motion for post-conviction relief

is reviewed for an abuse of discretion. Chatman v. Commonwealth, 565 S.W.3d

161, 164 (Ky. App. 2018); Age v. Age, 340 S.W.3d 88, 94 (Ky. App. 2011). The

trial court’s exercise of discretion will not be disturbed absent a determination that

it was arbitrary, unreasonable, unfair, or unsupported by sound legal principles.

Commonwealth v. English, 993 S.W.2d 941, 945 (Ky. 1999).

3 Kentucky Revised Statute.

-4- III. ANALYSIS

We begin by noting the deficiencies in Hodges’ brief. In

contravention of RAP4 32(A)(3) - (4), the brief contains no citations to the record

whatsoever. In contravention of RAP 32(E)(1)(a), the order on appeal is not

contained in the appendix of the brief. Finally, in contravention of RAP

32(E)(1)(c), the appendix contains materials not found in the record on appeal.

“While pro se litigants are sometimes held to less stringent standards

than lawyers in drafting formal pleadings, see Haines v. Kerner, 404 U.S. 519, 92

S. Ct. 594, 30 L. Ed. 2d 652 (1972), Kentucky courts still require pro se litigants to

follow the Kentucky Rules of [Appellate] Procedure.” Watkins v. Fannin, 278

S.W.3d 637, 643 (Ky. App. 2009). The rules of appellate procedure are “critical”

to effective appellate review and substantial compliance is mandatory. Oakley v.

Oakley, 391 S.W.3d 377, 380-81 (Ky. App. 2012). This Court has three options

when a party fails to follow the mandates of the RAP: ignore the deficiency, strike

the brief in whole or in part, or review only for manifest injustice. Ford v.

Commonwealth, 628 S.W.3d 147, 155 (Ky. 2021);5 see also RAP 31(H) which

4 Kentucky Rule of Appellate Procedure. 5 The manifest-injustice standard of review is reserved only for errors in appellate briefing related to the statement of preservation; if a party fails to inform the appellate court of where in the record his issue is preserved, the appellate court can treat that issue as unpreserved. Ford, 628 S.W.3d at 155.

-5- states that this Court may strike a brief “for failure to substantially comply with the

requirements of these rules.” While we decline to strike Hodges’ brief at this time,

we caution that this Court may not afford such generosity in the future.

Hodges presents three arguments on appeal. However, in each of her

preservation statements, she cites the order denying relief entered by the trial court

on February 5, 2021.

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Related

Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
Watkins v. Fannin
278 S.W.3d 637 (Court of Appeals of Kentucky, 2009)
Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
Age v. Age
340 S.W.3d 88 (Court of Appeals of Kentucky, 2011)
Cardwell v. Commonwealth
354 S.W.3d 582 (Court of Appeals of Kentucky, 2011)
Oakley v. Oakley
391 S.W.3d 377 (Court of Appeals of Kentucky, 2012)
Chatman v. Commonwealth
565 S.W.3d 161 (Court of Appeals of Kentucky, 2018)

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