Vincent Bernard Ficklin v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedAugust 15, 2022
Docket2020 SC 0573
StatusUnknown

This text of Vincent Bernard Ficklin v. Commonwealth of Kentucky (Vincent Bernard Ficklin 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.

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Vincent Bernard Ficklin v. Commonwealth of Kentucky, (Ky. 2022).

Opinion

IMPORTANT NOTICE NOT TO BE PUBLISHED OPINION

THIS OPINION IS DESIGNATED “NOT TO BE PUBLISHED.” PURSUANT TO THE RULES OF CIVIL PROCEDURE PROMULGATED BY THE SUPREME COURT, CR 76.28(4)(C), THIS OPINION IS NOT TO BE PUBLISHED AND SHALL NOT BE CITED OR USED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE; HOWEVER, UNPUBLISHED KENTUCKY APPELLATE DECISIONS, RENDERED AFTER JANUARY 1, 2003, MAY BE CITED FOR CONSIDERATION BY THE COURT IF THERE IS NO PUBLISHED OPINION THAT WOULD ADEQUATELY ADDRESS THE ISSUE BEFORE THE COURT. OPINIONS CITED FOR CONSIDERATION BY THE COURT SHALL BE SET OUT AS AN UNPUBLISHED DECISION IN THE FILED DOCUMENT AND A COPY OF THE ENTIRE DECISION SHALL BE TENDERED ALONG WITH THE DOCUMENT TO THE COURT AND ALL PARTIES TO THE ACTION. RENDERED: AUGUST 18, 2022 NOT TO BE PUBLISHED

Supreme Court of Kentucky 2020-SC-0573-MR

VINCENT BERNARD FICKLIN APPELLANT

ON APPEAL FROM WARREN CIRCUIT COURT V. HONORABLE JOHN GRISE, JUDGE NO. 17-CR-00479

COMMONWEALTH OF KENTUCKY APPELLEE

MEMORANDUM OPINION OF THE COURT

AFFIRMING

Vincent Ficklin appeals his conviction for the murder and first-degree

robbery of Tim Massey. He claims the trial court erred (1) by denying his

motion in limine to exclude the testimony or limit the conclusions of the

firearm examiner and (2) by failing to grant a directed verdict on the first-

degree robbery charge. Upon review, we affirm the Warren Circuit Court’s

judgment.

FACTUAL AND PROCEDURAL BACKGROUND

Massey was killed early in the morning of February 10, 2017, in a house

in Bowling Green, Kentucky, which Massey and others used to sell drugs. A

Warren County jury found Ficklin guilty of intentionally murdering Massey by

shooting him and of the first-degree robbery of Massey. The robbery charge stemmed from Ficklin also stealing Massey’s Ford Expedition, later found

abandoned in Alabama. The Commonwealth presented multiple witnesses’

testimony in support of Ficklin’s guilt. The witnesses’ testimony, corroborated

by GPS data from Massey’s vehicle, cell phone tower data from Ficklin’s phone,

and security footage from nearby businesses, provided a timeline for Ficklin’s

whereabouts on the night of February 9, 2017, up through his arrival in

Alabama on February 10 driving Massey’s vehicle.

One witness testified that he was in the house with Ficklin and Massey

and that he had gone to a bedroom to rest. The witness saw Ficklin walk past

the bedroom and shortly afterward heard a loud noise in the kitchen, followed

by the sound of the front door closing. The witness went into the kitchen and

found Massey shot in the head. The witness then saw Massey’s vehicle pull

out of the driveway. Ficklin was gone. Police recovered a 9mm shell casing

near Massey’s body.

A second witness testified that he was in Franklin, Kentucky, near the

American Legion Hall on the night of February 9, 2017, when he was

approached by Ficklin about a drug debt. This witness testified that someone

shot at him and upon retreating to his vehicle, the witness saw Ficklin up the

street. A third witness saw Ficklin on the Franklin street just before the shots

rang out. Police also recovered shell casings from the Franklin shooting scene.

The Commonwealth submitted the shell casings from the two crime

scenes to the Kentucky State Police lab for comparison. Ficklin moved pretrial

to exclude or to limit the firearm and toolmark examiner’s testimony. The

2 motion was denied. The examiner testified that he compared the shell casings

and determined that they had been fired from the same gun.

At the close of the Commonwealth’s case and of all the proof, Ficklin

moved for a directed verdict on the robbery charge.1 The trial court denied

both motions.

Upon finding Ficklin guilty, the jury recommended the maximum

sentence for each crime, fifty years for the murder and twenty years for the

robbery, and that the sentences run consecutively. The trial court, following

the jury’s recommendation, sentenced Ficklin to seventy years in prison.

Ficklin raises two arguments on appeal. These claims are addressed in

turn.

ANALYSIS

I. The Trial Court Did Not Err by Denying the Motion in Limine.

Ficklin moved to exclude the firearm examiner’s testimony or limit the

testimony so that the examiner did not convey to the jury that he was able to

determine with “certainty” that the casings from Massey’s shooting and the

Franklin shooting were fired from one particular firearm. Ficklin, citing the

2009 National Research Council’s report titled Strengthening Forensic Science

in the United States (NRC Report) and the President’s Council of Advisors on

Science and Technology report titled Forensic Science in Criminal Courts:

Ensuring Scientific Validity of Feature-Comparison Methods (PCAST Report),

1 Ficklin also moved for a directed verdict on the murder charge, but the trial

court’s denial of that motion was not appealed.

3 argued that the analysis performed by the firearm examiner is no longer

deemed scientifically reliable. Criticism of firearm examination includes no

definite guidelines or standards for examination, reliance on subjective rather

than objective analysis, and no scientific validity to the assertion that any

specific firearm produces unique identifiable markings. Prior to trial, the trial

court conducted a Daubert2 hearing as to the firearm examiner’s qualifications

and experience.

The firearm examiner explained the process the Kentucky State Police

Forensic Laboratory uses to determine whether two shell casings were likely

fired from the same gun, a process which involves the examiner’s subjective

analysis. The examiner looks at the shell casings through a comparison

microscope to identify individual characteristics caused by the firing process.

Under the Association of Firearm and Toolmark Examiners (AFTE) guidelines,3

the examiner should comparatively examine the two casings’ surface contour

patterns. If the examiner, based upon his experience and training, finds

“significant agreement” between corresponding individual characteristics on

both casings that “significant agreement” supports the conclusion that the

casings were discharged from the same firearm.

2 Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (1993). 3 The PCAST Report examined a 2011 AFTE journal article and scrutinized the

examiner’s subjective conclusions.

4 The examiner also testified to the scientific reliability of the process. The

Kentucky State Police Forensic Laboratory is accredited by the ANAB4 to

perform firearm and toolmark analysis. The examiner stated that the analysis

is supported by over 100 years of research and that peer review studies and

research papers had found that firearm and toolmark examination had an

error rate of near zero percent. The examiner testified that although the

Kentucky State Police Forensic Laboratory established protocols for its

comparative analysis, AFTE had not created uniform standards to be employed

in every laboratory.

A number of factors derived from Daubert are recognized as helpful to the

trial court when determining whether the expert’s testimony rests on a reliable

foundation before allowing its admission. Futrell v. Commonwealth, 471

S.W.3d 258, 282 (Ky. 2015).

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Related

Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Brewer v. Commonwealth
206 S.W.3d 343 (Kentucky Supreme Court, 2006)
Bowling v. Commonwealth
942 S.W.2d 293 (Kentucky Supreme Court, 1997)
Commonwealth v. Benham
816 S.W.2d 186 (Kentucky Supreme Court, 1991)
Hobson v. Commonwealth
306 S.W.3d 478 (Kentucky Supreme Court, 2010)
Anastasi v. Commonwealth
754 S.W.2d 860 (Kentucky Supreme Court, 1988)
Martin v. Commonwealth
207 S.W.3d 1 (Kentucky Supreme Court, 2006)
Parker v. Commonwealth
952 S.W.2d 209 (Kentucky Supreme Court, 1997)
United States v. Nelson Otero
557 F. App'x 146 (Third Circuit, 2014)
Jerard Garrett v. Commonwealth of Kentucky
534 S.W.3d 217 (Kentucky Supreme Court, 2017)
Rayburn v. Commonwealth
476 S.W.2d 187 (Court of Appeals of Kentucky, 1972)
Commonwealth v. O'Conner
372 S.W.3d 855 (Kentucky Supreme Court, 2012)
Acosta v. Commonwealth
391 S.W.3d 809 (Kentucky Supreme Court, 2013)
Meskimen v. Commonwealth
435 S.W.3d 526 (Kentucky Supreme Court, 2013)
Futrell v. Commonwealth
471 S.W.3d 258 (Kentucky Supreme Court, 2015)
United States v. Otero
849 F. Supp. 2d 425 (D. New Jersey, 2012)

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