Mayse v. Commonwealth

Summary

The Kentucky Supreme Court affirmed Samantha Mayse’s convictions for complicity to murder and first-degree complicity to robbery. The court rejected challenges concerning references to co-indictees’ guilty pleas, admission of jail letters, a co-defendant’s assertion of the Fifth Amendment, and the jury’s brief access to improperly submitted exhibits. The court also rejected Mayse’s cumulative-error argument.

Holdings

1. The Commonwealth's incomplete reference during voir dire to anticipated witnesses who had pleaded guilty was not a blatant use of a co-indictee's conviction as substantive evidence of Mayse's guilt; because the statement occurred during voir dire and was directed toward identifying juror bias, the trial court did not abuse its discretion in denying a mistrial.
2. The Commonwealth could question Cooke about his guilty plea after the defense first raised the terms of his agreement to impeach his credibility. The trial court therefore did not abuse its discretion in denying the second mistrial motion.
3. The Commonwealth's references during closing argument to Cooke's and Hartbarger's plea agreements were not a blatant use of their convictions as substantive evidence of Mayse's guilt, particularly after the trial court sustained the objection and prohibited further commentary; denial of the third mistrial motion was not an abuse of discretion.
4. The eighteen letters between Mayse and Parker were relevant and admissible because they tended to show the nature of the parties' relationship and rebut Mayse's claims that she barely knew Parker, that Parker had mental problems, and that she felt threatened by him. Their probative value was not substantially outweighed by the danger of undue prejudice under KRE 403.
5. Parker did not waive his Fifth Amendment privilege against self-incrimination by entering a plea agreement before sentencing, and the trial court correctly allowed him to refuse to testify. Mayse therefore was not denied her Sixth Amendment right to present a defense.
6. The jury's brief and cursory access to improperly delivered defense exhibits did not require a mistrial because the jury did not review one of the exhibits, only one juror briefly reviewed the other, the trial court strongly admonished the jury to disregard both, and there was no evidence that the mistake affected deliberations.
7. Cumulative error did not warrant reversal because the individual alleged errors were not substantial or sufficiently prejudicial, and any potential prejudice was cured by admonitions.

Questions Presented

1. Whether the Commonwealth's references during voir dire, examination, and closing argument to co-indictees' guilty pleas and plea agreements required a mistrial.
2. Whether eighteen jail letters between Mayse and Marion Parker were relevant and admissible under Kentucky Rules of Evidence 401, 402, and 403.
3. Whether Mayse was denied her Sixth Amendment right to present a defense when Parker invoked his Fifth Amendment privilege against self-incrimination and refused to testify.
4. Whether the jury's brief access to improperly delivered, unadmitted defense exhibits required a mistrial.
5. Whether cumulative error required reversal of Mayse's convictions.

Disposition

affirmed