Timothy Hood v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedSeptember 5, 2025
Docket2024-CA-0539
StatusUnpublished

This text of Timothy Hood v. Commonwealth of Kentucky (Timothy Hood 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
Timothy Hood v. Commonwealth of Kentucky, (Ky. Ct. App. 2025).

Opinion

RENDERED: SEPTEMBER 5, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-0539-MR

TIMOTHY HOOD APPELLANT

APPEAL FROM BRECKINRIDGE CIRCUIT COURT v. HONORABLE KENNETH H. GOFF, II, JUDGE ACTION NO. 06-CR-00090

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: EASTON, A. JONES, AND MOYNAHAN, JUDGES.

JONES, A., JUDGE: Acting without the assistance of counsel, the Appellant,

Timothy Hood, appeals the Breckinridge Circuit Court’s March 14, 2024 Order

denying his CR1 60.02 motion for relief from final judgment. Having reviewed the

record and being otherwise sufficiently advised, we affirm.

1 Kentucky Rules of Civil Procedure. I. BACKGROUND

On June 28, 2006, while being held on felony charges at the

Breckinridge County Detention Center, Hood walked away from the facility

without authorization. He was subsequently charged with second-degree escape

under KRS2 520.030, and a warrant was issued for his arrest.

Later that day, Hood assaulted a woman by grabbing her throat and

threatening her before stealing her vehicle. Police Officer Mike Harned spotted

Hood driving the stolen car and attempted to stop him, but Hood fled, leading

Officer Harned and several others on a high-speed chase. The pursuit ended with

Hood’s arrest.

As a result, Hood was also charged with first-degree robbery (KRS

515.020), first-degree fleeing or evading police (KRS 520.095), first-degree

wanton endangerment (KRS 508.060), two counts of first-degree criminal mischief

(KRS 512.020), and being a first-degree persistent felony offender (KRS

532.080(3)).

Hood initially pleaded not guilty to all charges. However, on

February 8, 2007, he moved to withdraw his plea and enter a guilty plea. In

exchange, the Commonwealth agreed to dismiss the first-degree persistent felony

offender charge. The trial court found that Hood’s plea was knowing, voluntary,

2 Kentucky Revised Statutes.

-2- and made with the assistance of counsel, and accordingly accepted Hood’s guilty

plea on the remaining charges. Hood was sentenced as follows: three years for

second-degree escape; twelve years for first-degree robbery; three years each for

first-degree fleeing or evading police, first-degree wanton endangerment, and each

of the two counts of first-degree criminal mischief. The court ordered the

sentences to run partially concurrently and partially consecutively, for a total of

fifteen years. The fifteen-year sentence was also to run consecutive to any

sentence imposed by the same or another court prior to February 8, 2007.

On December 20, 2023, Hood filed a pro se motion to amend the

judgment under CR 60.02. He first argued that the Commonwealth had breached

the plea agreement, claiming he was led to believe he would be eligible for parole

after serving seven months on the three-year sentences. In reality, however, he

was not eligible until he had served thirty-five months. He also challenged the

Department of Corrections’ calculation of his parole eligibility date, asserting it

violated various statutes and regulations and resulted in a manifest injustice. On

March 1, 2024, Hood filed a supplemental CR 60.02 motion adding a complaint

about how the Department of Corrections calculated his parole eligibility under the

violent-offender statute.

By its order entered on March 14, 2024, the trial court denied Hood’s

motion, stating as follows:

-3- On February 8, 2007, [Hood] was sentenced to 15 years. The sentence of fifteen years expired on February 8, 2022. This court does not have jurisdiction with respect to any other sentence [Hood] may be serving or whether these sentences are to be consecutively served. The Department of Corrections, in memorandum dated October 16, 2023, advised the defendant that his parole eligibility was correct. This court is without jurisdiction to modify a sentence which has been served and any appeal of the Department of Corrections sentencing calculation must be filed against the Department of Corrections. It appears that appeal was filed October 18, 2023.

(Record (R.) at 207.)

This appeal followed.

II. STANDARD OF REVIEW

We review the denial of CR 60.02 motions for abuse of discretion.

Young v. Richardson, 267 S.W.3d 690, 697-98 (Ky. App. 2008). “The test for

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

unreasonable, unfair, or unsupported by sound legal principles.” Commonwealth v.

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

III. ANALYSIS

To the extent Hood seeks to challenge his original plea based on

alleged misrepresentations regarding his parole eligibility, his claim is untimely.

Motions under CR 60.02(e) and (f) must be filed “within a reasonable time.” In

Reyna v. Commonwealth, 217 S.W.3d 274 (Ky. App. 2007), we acknowledged that

-4- relief under CR 60.02 may be available to a defendant who was misinformed about

collateral consequences of a guilty plea, such as deportation. However, we held

the defendant’s motion was untimely because it was filed four years after the plea

and only after the defendant had completed his sentence. The same result is

warranted here. Hood waited nearly seventeen years after entering his guilty plea

before seeking relief. Under these circumstances, his motion was not filed within a

reasonable time and must be denied as untimely.3

Additionally, we agree with the trial court that CR 60.02 is not the

proper vehicle for Hood to challenge his parole eligibility date. Once a sentence

“is imposed and a defendant is remanded to the custody of the Department of

Corrections, the Kentucky Parole Board [] has sole responsibility for determining

parole eligibility.” Conn v. Kentucky Parole Board, 701 S.W.3d 76, 79 (Ky.

2024).4 The “correct path for [Hood] to have taken was to proceed against the

3 The trial court concluded that Hood had already served out his fifteen-year sentence stemming from the February 8, 2007 convictions when it considered his CR 60.02 motion. However, we are not certain that is correct. As noted, the fifteen-year sentence was ordered to run consecutive to any sentence imposed prior to that date. Hood had previously been convicted and sentenced on several charges, including a ten-year first-degree robbery conviction entered on July 5, 2006, in Jefferson Circuit Court. As a result, it is unclear whether the fifteen-year sentence had actually been completed when the trial court ruled. Nevertheless, any error on this point is harmless. Regardless of whether the sentence was still technically running, Hood waited more than seventeen years after his plea to seek relief. That delay alone renders his CR 60.02 motion untimely. 4 The Kentucky Supreme Court explained:

Once a prisoner is turned over to the Department of Corrections for execution of the sentence, the power to determine the period of incarceration passes to the

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Related

Hoskins v. Commonwealth
158 S.W.3d 214 (Court of Appeals of Kentucky, 2005)
Reyna v. Commonwealth
217 S.W.3d 274 (Court of Appeals of Kentucky, 2007)
Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
Young v. Richardson
267 S.W.3d 690 (Court of Appeals of Kentucky, 2008)
Mason v. Commonwealth
331 S.W.3d 610 (Kentucky Supreme Court, 2011)
Jones v. Commonwealth
319 S.W.3d 295 (Kentucky Supreme Court, 2010)

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