Daquan N. Lampkins v. Commonwealth of Kentucky, 701 S.W.3d 99

Daquan N. Lampkins was convicted by a Jefferson County jury of two counts of murder, possession of a handgun by a convicted felon, and violation of a protective order, and was sentenced to life imprisonment without parole.
The prosecution's case relied on circumstantial evidence, including motive, cellphone and surveillance evidence, witness testimony, and Lampkins's incriminating statements to the victim’s mother.
Lampkins claimed a local drug dealer (referred to as "John Smith") was the actual perpetrator, pointing to the presence of Smith’s DNA on a cigar wrapper near the scene and alleged drug activity.
The murders followed a documented pattern of Lampkins’s domestic violence against one of the victims, Delivia Carron, including violations of protective orders and prior assaults.
Lampkins appealed, asserting trial court errors on evidentiary rulings, jury instructions, jury selection, admission of prior bad acts, and the prosecution's use of a dramatized reenactment at trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Exclusion of Toxicology Reports	Evidence of victims' marijuana use relevant to alternate perpetrator theory	Irrelevant/speculative w/ no proof of drug deal causing conflict	Exclusion proper; no abuse of discretion
Failure to Instruct Jury on Judicially Noticed Fact	Jury should be instructed to accept fact about timing of DNA discovery disclosure	Timing of discovery not relevant to guilt/defense	No error; timing not adjudicative fact
Failure to Strike Jurors for Cause	Two jurors could not accept presumption of innocence	Jurors, when fully questioned, showed no bias	No abuse of discretion; refusal to strike was appropriate
Admission of Prior Bad Acts Evidence	Prior abuse evidence inadmissible character evidence	Admissible to show motive, intent, identity	Admission proper under KRE 404(b)
Use of Dramatized Demonstration	Reenactment with prop gun unduly prejudicial, improper foundation	Demonstrative evidence to help explain autopsy findings	Admission was erroneous, but harmless error

Malone v. Commonwealth, 364 S.W.3d 121 (Ky. 2012) (Victim’s drug use evidence must have direct relevance to perpetrator; speculative theories are not permitted)
Commonwealth v. Melton, 670 S.W.3d 861 (Ky. 2023) (Standard for reviewing evidentiary admissions/exclusions)
Sturgeon v. Commonwealth, 521 S.W.3d 189 (Ky. 2017) (Standard for striking jurors for cause: reasonable ground for bias)
Jenkins v. Commonwealth, 496 S.W.3d 435 (Ky. 2016) (Prior threats and violence admissible under KRE 404(b) to show motive)
Rankin v. Commonwealth, 327 S.W.3d 492 (Ky. 2010) (Standard for admission of demonstrative/experiment evidence)
Johnson v. Commonwealth, 105 S.W.3d 430 (Ky. 2003) (Admonitions generally cure trial error unless overwhelming prejudice)