Trevor Brown Jr v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedAugust 16, 2018
Docket2017-SC-0289
StatusUnpublished

This text of Trevor Brown Jr v. Commonwealth of Kentucky (Trevor Brown Jr v. Commonwealth of Kentucky) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Trevor Brown Jr v. Commonwealth of Kentucky, (Ky. 2018).

Opinion

RENDERED; AUGUST 16, 2018 TO BE PUBLISHED

2017-SC-000289-MR

TREVOR BROWN, JR. APPELLANT

ON APPEAL FROM HARDIN CIRCUIT COURT V. HONORABLE KEN HOWARD, JUDGE NO. 16-CR-00117

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION OF THE COURT BY CHIEF JUSTICE MINTON

AFFIRMING

A Hardin Circuit Court jury convicted Trevor Brown Jr. of complicity to

the kidnapping, complicity to the attempted murder, and complicity to the first-

degree robbery of Dealynn O’Connor. Following the jury’s recommendation, the

trial court entered judgment sentencing Brown to a total of 40 years’

imprisonment. Brown now appeals from the judgment as a matter of right, i

raising five issues for review. Finding no reversible error, we affirm the

judgment.

Ky. Const. § 110(2)(b). 1. BACKGROUND.

Several people, including Brown and O’Connor, came and went over the

span of two days from a trailer in Hardin County, Kentucky. The events that

come about during that get-together ended in criminal charges and separate

grand jury indictments against five people, including Brown, who was charged

with complicity to the kidnapping, complicity to the attempted murder, and

complicity to the first-degree robbery of O’Connor. Three of the five pleaded

guilty before trial and testified against Brown and a co-defendant, Marc Daniel

McCoy,2 in a joint jury trial after which both co-defendants were convicted.

A concise summary of the facts giving rise to the charges against Brown

is nearly impossible to relate because of the many actors involved and the

variations in stories. Testimony at trial revealed that an argument arose at the

Hardin County trailer between O’Connor and one or more of her assailants.

One or more of the assailants beat O’Connor badly, took a sizable amount of

money from her purse, and threw her into the bathroom.

One of the assailants then telephoned Brown, described what had

happened to O’Connor, and asked him for help. Brown responded by coming to

the trailer, where he and another assailant removed O’Connor—who was bound

and gagged, wrapped in a bedsheet, and hooded with a pillowcase over her

head—and put her into her automobile.

2 By separate opinion rendered today, we affirm the judgment of conviction and sentence of Brown’s co-defendant. McCoy v. Commonwealth, 2018-SC-000261-MR (Ky. 2018). Testimony also revealed that, at this point, Brown possessed a paper

towel containing jewelry taken from O’Connor. Brown, McCoy, and O’Connor

drove to a bridge spanning the Ohio River in neighboring Meade County,

Kentucky. Upon arriving at the bridge. Brown exited the vehicle with the

victim, stabbed her three times, and fled the scene.

II. ANALYSIS.

A. The trial court did not err in denying Brown’s motion for directed verdict on his kidnapping charge.

Brown first argues that the trial court erred when it denied his motion for

a directed verdict on the Complicity to Kidnapping. Specifically, Brown argues

that the prosecutor did not prove that O’Connor suffered a serious physical

injury, one of the elements necessary for a Class A felony conviction for

Kidnapping under Kentucky Revised Statutes (“KRS”) 509.040(2). That this

issue is preserved is undisputed.

KRS 509.040(2) enhances Complicity to Kidnapping to a Class A felony if

“the victim has suffered serious physical injury during the kidnapping.” KRS

500.080(15) defines serious physical injury as “physical injury which creates a

substantial risk of death, or which causes serious and prolonged

disfigurement, prolonged impairment of health, or prolonged loss or

impairment of the function of any bodily organ.”

The jury found Brown guilty of Complicity to Kidnapping in addition to

finding that O’Connor suffered a serious physical injury in the course of the

kidnapping. We note at the outset of our analysis that O’Connor died in an unrelated incident before this came to trial, so she could not provide testimony

describing her injuries. In fact, the only evidence at trial about O’Connor’s

injuries amounted to the knowledge that she was stabbed, pictures showing

the injury, and medical testimony provided by an expert witness testifying

solely based on medical records.

It is difficult to say that O’Connor’s injuries here qualify under the

serious and prolonged disfigurement, prolonged impairment of health, or

prolonged loss or impairment of the function of any bodily organ prongs. In

fact, the Commonwealth does not attempt to argue satisfaction of these prongs

of the serious physical injury test. This dispute then comes down to whether it

was clearly unreasonable for a jury to believe that, based on the evidence

adduced at trial, O’Connor suffered a “physical injury which creates a

substantial risk of death.”

The evidence at trial was that Brown stabbed O’Connor three times. As a

result of the stabbing, O’Connor suffered a punctured lung, creating a hole in

the lung and causing a pneumothorax, also known as a collapsed lung.

Because of this injury, O’Connor received treatment at a level one trauma

hospital. She was hospitalized for three days, had a tube inserted into her

torso, and remained hospitalized until she went a full day without her lung

collapsing upon removal of the chest tube. Medical testimony at trial revealed

that a pneumothorax, if untreated, can lead to respiratory arrest. The testifying

doctor also stated that any pneumothorax can become a “tension

pneumothorax,” which occurs when air becomes trapped in the chest wall and pushes the heart to the opposite side of the body. The doctor testified that this

situation is “an absolute surgical emergency. People will die.” The doctor

testified that in O’Connor’s case, the pneumothorax was caught quickly.

“On appellate review, the test of a directed verdict is, if under the

evidence as a whole, it would be clearly unreasonable for a jury to find guilty,

only then the defendant is entitled to a directed verdict of acquittal.”3

We cannot say that the trial court erred in denying Brown’s motion for a

directed verdict because it was not clearly unreasonable for a jury to find the

stab wound causing a pneumothorax to be a serious physical injury. As stated,

serious physical injury can mean a “physical injury which creates a substantial

risk of death.Medical testimony at trial revealed that O’Connor was

transferred to a level one trauma hospital and that her injury could have led to

respiratory arrest and a tension pneumothorax, both of which can cause death.

O’Connor was hospitalized for three days and monitored for one day without

the chest tube before she could be released.

Brown cites McDaniel v. Commonwealth^ and Anderson v.

Commonwealth^ for their assertions that a finding of serious physical injury “is

dependent on the seriousness of the resulting injury, not the potential of the

3 Commonwealth v. Benham, 816 S.W.2d 186, 187 (Ky. 1991) (citing Commonwealth v. Sawhill, 660 S.W.2d 3 (Ky. 1983)). 4 KRS 500.080(15). 5 415 S.W.3d 643 (Ky. 2013). 6 352 S.W.3d 577 (Ky. 2011).

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