William Patrick Evans v. Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedNovember 22, 2024
Docket2023-CA-1428
StatusUnpublished

This text of William Patrick Evans v. Commonwealth of Kentucky (William Patrick Evans 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
William Patrick Evans v. Commonwealth of Kentucky, (Ky. Ct. App. 2024).

Opinion

RENDERED: NOVEMBER 22, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-1428-MR

WILLIAM P. EVANS APPELLANT

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE PATRICIA MORRIS, JUDGE ACTION NO. 84-CR-001398

COMMONWEALTH OF KENTUCKY APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, KAREM, AND TAYLOR, JUDGES.

TAYLOR, JUDGE: William P. Evans, pro se, appeals an order of the Jefferson

Circuit Court entered October 26, 2023, denying his request for relief pursuant to

Kentucky Rules of Civil Procedure (CR) 60.02. We affirm.

In 1985, Evans was convicted of first-degree rape, first-degree

sodomy, and first-degree persistent felony offender status and was sentenced to life

imprisonment. His conviction was affirmed by the Kentucky Supreme Court on

direct appeal. Evans v. Commonwealth, 702 S.W.2d 424 (Ky. 1986). In December 1986, Evans filed a motion to have his conviction vacated pursuant to Kentucky

Rules of Criminal Procedure (RCr) 11.42. The trial court denied his motion and

this Court dismissed the appeal for being untimely. (Appeal No. 1987-CA-0237-

MR). In June 2000, Evans filed a motion for relief pursuant to CR 60.02, which

was denied by the trial court. This Court affirmed, ruling that all issues raised by

Evans were known to him during the jury trial and should have been brought up on

direct appeal. (Appeal No. 2000-CA-2399-MR). The Kentucky Supreme Court

denied discretionary review. In 2007, Evans filed another motion that challenged

the Commonwealth’s expert witness testimony during the trial and demanded

DNA testing of pubic hairs found during the investigation. Although Evans did

not cite legal authority for bringing the post-conviction motion, the trial court

treated it as a motion pursuant to CR 60.02 and denied relief. Evans did not appeal

that order.

In September of 2023, Evans filed his third post-conviction motion for

relief pursuant to CR 60.02. He argued that biological evidence had been

destroyed by the Commonwealth which constituted “newly discovered evidence.”

He also raised issues regarding the sufficiency of evidence introduced at the trial;

the testimony of the Commonwealth’s expert; and jury selection issues related to

race. The trial court found that all issues except the destruction of evidence were

untimely and should have been raised on direct appeal. Regarding DNA testing of

-2- biological evidence and destruction of said evidence, the trial court found that it

did not pertain to the discovery of new evidence and did not constitute

extraordinary circumstances contemplated by CR 60.02(f). This appeal followed.

On appeal, the trial court’s denial of a motion pursuant to CR 60.02

will not be overturned absent an abuse of discretion. Foley v. Commonwealth, 425

S.W.3d 880, 886 (Ky. 2014). 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).

Evans first argues he is entitled to a presumption of innocence based

on newly discovered evidence. This “newly discovered evidence,” he asserts, is

the fact that the biological evidence was destroyed after the trial. Evans also (1)

argues the evidence presented at trial was insufficient to convict him; (2) takes

issue with the testimony of the Commonwealth’s expert witness; and (3) argues

jurors were struck solely due to race.

CR 60.02 provides:

On motion a court may, upon such terms as are just, relieve a party or his legal representative from its final judgment, order, or proceeding upon the following grounds: (a) mistake, inadvertence, surprise or excusable neglect; (b) newly discovered evidence which by due diligence could not have been discovered in time to move for a new trial under Rule 59.02; (c) perjury or falsified evidence; (d) fraud affecting the proceedings, other than

-3- perjury or falsified evidence; (e) the judgment is void, or has been satisfied, released, or discharged, or a prior judgment upon which it is based has been reversed or otherwise vacated, or it is no longer equitable that the judgment should have prospective application; or (f) any other reason of an extraordinary nature justifying relief. The motion shall be made within a reasonable time, and on grounds (a), (b), and (c) not more than one year after the judgment, order, or proceeding was entered or taken. A motion under this rule does not affect the finality of a judgment or suspend its operation.

Notably, “CR 60.02 does not permit successive post-judgment

motions, and the rule may be utilized only in extraordinary situations when relief is

not available on direct appeal or under RCr 11.42.” Foley, 425 S.W.3d at 884

(citation omitted). CR 60.02 “is not a separate avenue of appeal to be pursued in

addition to other remedies, but is available only to raise issues which cannot be

raised in other proceedings.” McQueen v. Commonwealth, 948 S.W.2d 415, 416

(Ky. 1997); see also Stoker v. Commonwealth, 289 S.W.3d 592, 597 (Ky. App.

2009).

We agree with the trial court that most of Evans’ arguments are either

successive, untimely, or both, being brought thirty-eight years after his conviction.

Moreover, with the exception of the argument related to destruction of evidence,

each argument was known to Evans at the time of the trial and should have been

raised on direct appeal. The trial court did not abuse its discretion in denying

relief.

-4- We now turn to Evans’ argument regarding destruction of biological

evidence (namely, pubic hairs that were discovered during the investigation).

Evans cites CR 60.02(f) while at the same time arguing that destruction of the

evidence in and of itself is “newly discovered evidence” as referenced in CR

60.02(b). The trial court treated the argument as though it was made pursuant to

CR 60.02(f) and we shall do the same.

We note the following from the trial court’s order from 2007, which

denied relief to Evans in response to what it treated as his second post-conviction

motion pursuant to CR 60.02. At the time, Evans requested DNA testing of the

pubic hairs found during the investigation.

According to [Evans’] motion, the expert for the prosecution testified that there were no sperm cells present in the swabs from the victim and there was insufficient blood found on the knife for any type of testing to be done. Additionally, [Evans’] motion asserted that the only hairs found on the victim were determined to be her own or that of an unknown party. None were attributed to [Evans]. As such, it appears that there would be no probative value in DNA testing in this matter. None of the physical evidence was used to connect [Evans] to the crime and, therefore, DNA could not be used to contradict any of the evidence presented at trial.

October 26, 2023, Order at 3 (emphasis added).1

1 Because the trial proceedings do not appear in the record before us as either a recording or transcript, and the Kentucky Supreme Court opinion affirming William P. Evans’ conviction is scant regarding the factual and procedural background of the case, we do not know what

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Related

Stoker v. Commonwealth
289 S.W.3d 592 (Court of Appeals of Kentucky, 2009)
McQueen v. Commonwealth
948 S.W.2d 415 (Kentucky Supreme Court, 1997)
Commonwealth v. English
993 S.W.2d 941 (Kentucky Supreme Court, 1999)
Chestnut v. Commonwealth
250 S.W.3d 288 (Kentucky Supreme Court, 2008)
Gross v. Commonwealth
648 S.W.2d 853 (Kentucky Supreme Court, 1983)
Evans v. Commonwealth
702 S.W.2d 424 (Kentucky Supreme Court, 1986)
Cardwell v. Commonwealth
354 S.W.3d 582 (Court of Appeals of Kentucky, 2011)
Foley v. Commonwealth
425 S.W.3d 880 (Kentucky Supreme Court, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
William Patrick Evans v. Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-patrick-evans-v-commonwealth-of-kentucky-kyctapp-2024.