Blair v. Commonwealth of Kentucky

Summary

The Supreme Court of Kentucky reviewed Michael C. Blair’s murder conviction and sentence arising from the death of Mary Katherine Johnson. The court held that the admission of certain hearsay statements, exclusion of evidence concerning the investigating detective’s misconduct, and prosecutorial argument involving facts outside the evidence required reversal and remand for a new trial. The court also addressed the sufficiency of the evidence, impeachment with a prior felony conviction, and admission of a poem.

Holdings

1. The evidence was sufficient for a reasonable jury to find that Blair murdered Johnson and stole her money.
2. The victim's statements that she was going to Michigan and wanted her brother to take Blair home were admissible under KRE 803(3) because they reflected her future intentions rather than past events.
3. Statements by Johnson expressing fear of Blair, stating that she had saved money for dental work, and complaining that Blair was borrowing her money and eating her food were inadmissible.
4. Johnson's statements made during a telephone conversation and repeated by Lawson were not admissible as adoptive admissions or under the opening-the-door doctrine.
5. The trial court properly permitted the Commonwealth to impeach Blair with his 1998 felony conviction and properly excluded the misdemeanor probation violation.
6. The trial court did not abuse its discretion by admitting the poem allegedly written by Blair.
7. Blair was entitled to introduce evidence that Detective House had participated in the theft of property from the police evidence room because the evidence supported Blair's alternative-perpetrator theory and was relevant to whether House, rather than Blair, stole Johnson's money.
8. A prosecutor's closing argument must be confined to facts admitted into evidence and reasonable inferences from those facts; the prosecutor improperly relied on an additional fact that was not in evidence.

Questions Presented

1. Whether the evidence was sufficient to support Blair's murder conviction.
2. Whether statements by the victim concerning her plans, fears, finances, and complaints about Blair were admissible hearsay.
3. Whether Blair's prior felony conviction was properly admitted for impeachment.
4. Whether a poem allegedly written by Blair was relevant and admissible.
5. Whether evidence of Detective House's participation in the theft of police evidence was admissible to support Blair's alternative-perpetrator defense.
6. Whether the prosecutor improperly injected extra-judicial facts during closing argument.

Disposition

reversed_and_remanded