Jackson v. Commonwealth
2013 Ky. LEXIS 39
| Ky. | 2013Background
- Five people were found dead in the Sturgill trailer: Chris, Amanda, and their three children; Amanda’s body was used to ignite the fire and the children died from smoke inhalation; Chris Sturgill’s truck was found burned nearby.
- Appellant Clayton Jackson was implicated through circumstantial and witness evidence, including statements to associates, a letter obtained in custody, and testimonies linking him to the trailer and arson.
- The jury convicted Appellant of three counts of murder (the children) and one count of first-degree arson; the jury could not reach verdicts on the murders of Chris and Amanda or on theft.
- The Clay Circuit Court sentenced Appellant to life imprisonment without parole for the murder/arson convictions.
- Appellant challenged multiple trial rulings, focusing on juror impartiality (E.K.), motions to suppress a confession, admissibility of expert testimony, and several jury instruction issues; the appellate court ultimately focused on the juror impartiality issue and reversed the convictions.
- The court held that the trial court abused its discretion by not removing Juror E.K. for cause and failure to designate him as an alternate, reversing the convictions and remanding for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Juror E.K. impartiality | Appellant argues E.K. could not be fair due to a past relationship with a victim’s family. | Commonwealth contends E.K. could be rehabilitated and remained impartial. | Trial court abused discretion; juror must be removed and E.K. should have been designated an alternate. |
| Directed verdict denial | Appellant contends the evidence failed to prove guilt beyond a reasonable doubt on all charged counts. | Commonwealth contends the evidence was sufficient for a reasonable juror to convict. | Trial court properly denied directed verdict; not clearly unreasonable to find guilt. |
| Preservation of issues related to confession | Appellant preserved the confession issue sufficiently to review. | Commonwealth contends the issue was not properly preserved for review. | Issue not reviewed on appeal due to preservation concerns. |
| Alternates and for-cause challenges | Failure to designate E.K. as an alternate deprived Appellant of a fair panel. | Court acted within the rules for selecting alternates when no agreement existed. | See Juror E.K. impartiality holding; issue encompassed in reversal. |
Key Cases Cited
- Commonwealth v. Benham, 816 S.W.2d 186 (Ky. 1991) (directed-verdict standard; weigh evidence in favor of Commonwealth)
- Commonwealth v. Sawhill, 660 S.W.2d 3 (Ky. 1983) (standard for denial of directed verdicts)
- Lester v. Commonwealth, 132 S.W.3d 857 (Ky. 2004) (abuse-of-discretion review for removal of juror for cause)
- Shane v. Commonwealth, 243 S.W.3d 336 (Ky. 2007) (rehabilitation and impartiality; evaluation of juror responses)
- Brown v. Commonwealth, 313 S.W.3d 577 (Ky. 2010) (close relationship between juror and victim may require removal for cause)
- Mabe v. Commonwealth, 884 S.W.2d 668 (Ky. 1994) (trial judge’s assessment of juror’s statements; credibility matters)
- Adkins v. Commonwealth, 96 S.W.3d 779 (Ky. 2003) (limits of appellate scrutiny on juror rehabilitation)
- Marsch v. Commonwealth, 743 S.W.2d 830 (Ky. 1988) (implications of juror relationships and impartiality)