Blades v. Commonwealth
2011 Ky. LEXIS 73
Ky.2011Background
- Blades was convicted by a McCracken Circuit Court jury of complicity to manufacture methamphetamine, first-degree possession of methamphetamine, possession of marijuana, and possession of drug paraphernalia, plus first-degree persistent felony offender (PFO).
- The convictions stemmed from a March 23, 2009 incident where Brokaw’s uninsured vehicle was searched after consent, revealing drugs; Blades, a passenger, admitted ownership.
- Deputy Vallelunga found a hotel room key in Brokaw’s vehicle; hotel management allowed a warrantless search of the room after checkout time, deeming items abandoned.
- In the hotel room search, officers found drug paraphernalia, a coffee grinder with powder, batteries, foil, a brillo pad, and other documents including Appellant’s and Brokaw’s drivers’ licenses.
- Evidence from the searches led to Blades’ convictions and a lengthy prison sentence; Blades appealed alleging Fourth Amendment suppression error and a directed-verdict issue.
- The Supreme Court of Kentucky affirmed, holding the hotel-room search after checkout did not violate the Fourth Amendment and addressing PFO status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of hotel-room search after checkout | Blades contends search of hotel room was unlawful without a warrant. | Commonwealth argues no reasonable privacy interest existed post-checkout; Croft controls. | Conviction affirmed; no Fourth Amendment violation given expired rental period. |
| Sufficiency of proof of first-degree PFO | Blades claims insufficient proof of two prior felonies for PFO. | Commonwealth shows two prior felonies and applies Williams to permit PFO status. | Convictions and PFO status affirmed; concurrent-sentence break not applicable to Blades. |
Key Cases Cited
- Katz v. United States, 389 U.S. 347 (1967) (establishes Fourth Amendment baseline for reasonable privacy)
- Stoner v. California, 376 U.S. 483 (1964) (guests have privacy rights in hotel rooms)
- United States v. Allen, 106 F.3d 695 (6th Cir.1997) (privacy interests after hotel checkout)
- United States v. Rahme, 813 F.2d 31 (2d Cir.1987) (no privacy interest after expiration of rental period)
- United States v. Croft, 429 F.2d 884 (10th Cir.1970) (post-checkout searches do not invade privacy)
- Williams v. Commonwealth, 639 S.W.2d 788 (Ky.App.1982) (concurrent-sentence-break interpretation under KRS 532.080(4))
- Hall v. Hospitality Resources, Inc., 276 S.W.3d 775 (Ky.2008) (statutory interpretation not to yield absurd results)
- Commonwealth v. Jones, 217 S.W.3d 190 (Ky.2006) (standard for reviewing suppression orders (CrR 9.78))
- Commonwealth v. Hinton, 678 S.W.2d 388 (Ky.1984) (KRS 532.080 prior-conviction rule context)