Engles v. Commonwealth
373 S.W.3d 456
| Ky. Ct. App. | 2012Background
- Engles entered a conditional guilty plea after the suppression motion was denied.
- Engles statute-indicted for first-degree robbery, felon in possession of a handgun, tampering with evidence, and persistent felony offender in the first degree.
- Gun found in the Mayor’s Training Center during immediate police response to the incident at Save-A-Lot across the street.
- Witnesses identified Engles as the man who brandished the gun.
- Court allowed gun into evidence; Engles pleaded to amended charges of third-degree burglary and PFO in the second degree.
- Appeal challenges admission of the gun; standard of review is abuse of discretion; affirmed on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of the gun as evidence | Engles argues gun not connected to incident | Commonwealth asserts relevance based on proximity and eyewitnesses | Gun admissible; not an abuse of discretion |
Key Cases Cited
- Turner v. Commonwealth, 914 S.W.2d 343 (Ky.1996) (relevance standards for evidence)
- Higgins v. Commonwealth, 134 S.W.1135 (Ky.1911) (relevance near time/place supports admissibility)
- Dillingham v. Commonwealth, 995 S.W.2d 377 (Ky.1999) (evidence weight/credibility determinations)
- Partin v. Commonwealth, 918 S.W.2d 219 (Ky.1996) (abuse of discretion standard (overruled on other grounds))
- Chestnut v. Commonwealth, 250 S.W.3d 288 (Ky.2008) (abuse of discretion standard clarified)
- Commonwealth v. English, 993 S.W.2d 941 (Ky.1999) (abuse of discretion standard)
