William Roy Helm Jr v. Commonwealth of Kentucky

CourtKentucky Supreme Court
DecidedMarch 22, 2018
Docket2017-SC-0084
StatusPublished

This text of William Roy Helm Jr v. Commonwealth of Kentucky (William Roy Helm 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
William Roy Helm Jr v. Commonwealth of Kentucky, (Ky. 2018).

Opinion

RENDERED: MARCH 22, 2018 TO BE PUBLISHED

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COMMONWEALTH OF KENTUCKY APPELLANT/ CROSS-APPELLEE

ON REVIEW FROM COURT OF APPEALS v. CASE NO. 2014-CA-000990 HARDIN CIRCUIT COURT NO. 2006-CR-00602

WILLIAM ROY HELM, JR. APPELLEE/CROSS-APPELLANT

)

OPINION OF THE COURT BY CHIEF JUSTICE MINTON

REVERSING AND REINSTATING

We granted the Commonwealth's motion for discretionary review-to

determine whether the Court of Appeals erred when it reversed the trial court's

denial of William Roy Helm Jr. 's RCrl 11.42 post-conviction motion for a. new

sentencing-phase trial based upon ineffective assistance of trial counsel. .

Remanding for a new sentencing-phase trial for Helm, the Court of Appeals

held that the trial court erred by failing to find Helm's trial ~ounsel's

performance constitutionally deficient for having advised Helm to enter into a

sentencing agreement with the Commonwealth to waive jury sentencing and

accept a plea agreement under which he was sentenced to the maximum

1 Kentucky Rules of Criminal Procedure. penalty to avoid potential risks to his parole eligibility and meritorious credit

against his sentence. We reverse the Court of Appeals' decision· because we

hold that it misapplies our ineffective-assistance-of-counsel standard by failing

to consider, as the trial court properly did, the totality of the circumstances of

Helm's case from the perspective of an objectively reasonable trial attorney, placing too much emphasis on Helm's agreeing to the maximum penalty.

We also granted Helm's cross-motion for discretionary review to consider

his argument that the trial court erred by denying his motion for relief for

ineffective assistance of appellate counsel, who advised him to dismiss an

earlier appeal in favor of pursuing the RCr 11.42 motion now before us on

discretionary review. Because it reversed the trial court on the denial of the

RCr 11.42 motion, the Court of Appeals did not reach the defective-appellate-

-counsel issue Helm presents to us. But we agree on discretionary review with

the trial court's determination that appellate counsel's performance was not

constitutionally deficient.

Accordingly, we reverse the opinion of the Court of Appeals and order

that the trial court's order be reinstated.

I. BACKGROUND. A circuit court jury convicted Helm of five counts of second-degree rape,2

two counts of second-degree sodomy,3 and two counts of firs~-degree sexual

2 Second-degree rape is a Class C felony under KRS 510.050(2), for which a maximum

ten-year imprisonment sentence is imposed under KRS 532.060(2)(c). 3 Second-degree sodomy is also a Class C felony under KRS 510.080(2).

2 abuse4. Before the guilt phase of the jury trial, Helm and the Commonwealth

reached the following sentencing agreement: the trial court would sentence ' Helm to ten years' imprisonm~nt for all crimes committed against each victim

(there were two victims), meaning a 20-year prison sentence, to be served

consecutively, with 20% parole· eligibility.

The events culminating in the sentencing agreement are the source of

Helm's first RCr 11.42 ineffective-assistance-:-of-counsel claim. As the trial court

found, the trial record reflects that Helm's trial counsel and the trial court

acknowledged that 20 years' imprisonment, by law, was the maximum

sentence Helm could receive. 5 The parties were unsure at trial as to whether,

by law, Helm?s convictions would make him 85% parole eligible,6 as opposed to

the 20% eligibility that Helm wanted.

But Helm agreed to these terms partly because his trial counsel asserted

that the Department of Corrections had been classifying si:a~.ilarly situated

prisoners at 85% parole eligibility. 7 In addition to providing his own anecdotal

4 First-degree sexual abuse 'is a Class D felony under KRS 510.110(2) because the victims in this case were not under the age of twelve, for which a maximum five-year imprisonment sentence is imposed under KRS 532.050(2)(d). s See KRS 532.110(1).(c). 6In fact, Helm would fall under the 20% parole eligibility rule, not the 85% rule. The applicable version of KRS 439.3401 did not characterize Helm as being a "violent offender" for which the 85% applies because Helm was not convicted of any of the enumerated offenses in subsection (1) that characterizes a defendant as a "violent offender. So the 85% parole eligibility mandate in KRS 439.3401(3) does not apply. Rather, 501KAR1:030(c)'s 20% parole eligibility rule would apply. See e.g. Mason v. Commonwealth, 7 It appears that this truly is a pervasive problem. 331S.W.3d610 (Ky. 2011); Conley v. Commonwealth, 2014-CA-000053-MR, 2015 WL 4598774 (Ky. App. July 31, 2015).

3 evidence from his experience as an attorney, Helm's counse~ supported the

necessity of this stipulation in the sentencing agreement because of the

foliowing language contained in the Department of Public Advocacy's trial '\

manual:

WARNING!! KRS 439.3401(1) which lists the offenses which can qualify a person as a violent offender, includes offenses which are Class C or D felonies, or even misdemeanors. For example, subsection (l)(d) says that a persori is a violent offender if convicted of or has pled to, "The commissfoQ. or attempted commission of a felony sexual offense described in KRS Chapter 51 ci." Sexual abuse 1st Degree is a Class C or D felony. KRS · 510. 110. Attempted Sexual Abuse 1st Degree is a Class A Misde~eanor. KRS 506.010(4)(d). Although subsection (4) seems to limit 85% parole eligibility to Class A and B felonies, nevertheless, the Department of Corrections has applied it to ALL felony sexual · offenses in the past. DPA Appeals Branch had to do a Declaratory Judgment action. So, have the judge make a finding of parole eligibility at the sentencing hearing and get an agreed order.s

Helm appealed the conviction as a matter of right.9 This Court affirmed

Helm's convictions, but remanded the case to correct two errors.IO The Court

determined that the trial court improperly imposed upon Helm a $1,000 fine

·and that Helm's sentence was illegal because of an error on the face of the

judgment.11 This judgment erroneously stated that on Count 2 Helm was

convicted of second-degree rape, ·when he was ac~ually convicted of first-degree

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Strickland v. Washington
466 U.S. 668 (Supreme Court, 1984)
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474 U.S. 52 (Supreme Court, 1985)
Yarborough v. Gentry
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Harrington v. Richter
131 S. Ct. 770 (Supreme Court, 2011)
Missouri v. Frye
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Bronk v. Commonwealth
58 S.W.3d 482 (Kentucky Supreme Court, 2001)
Rigdon v. Commonwealth
144 S.W.3d 283 (Court of Appeals of Kentucky, 2004)
Mason v. Commonwealth
331 S.W.3d 610 (Kentucky Supreme Court, 2011)

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