Joel David Searcy v. Commonwealth of Kentucky, 2015 SC 000357

Defendant Joel David Searcy, high on methamphetamine, became paranoid while driving with a friend and her children, forcibly took control of an elderly motorist Donald Cooke's car during a physical struggle, and was later apprehended with Cooke's keys.
Cooke (82) sustained severe blunt trauma (rib fractures, pneumothorax, subdural hematoma) and died about a week later; autopsy attributed death to blunt impacts and multisystem organ failure.
Searcy was indicted for capital murder, robbery, and unlawful imprisonment; convicted of second-degree manslaughter, first-degree robbery, and multiple counts of unlawful imprisonment and sentenced to 25 years.
On matter-of-right appeal, Searcy challenges only the first-degree robbery conviction, arguing (1) the trial court should have granted a directed verdict on robbery because he lacked intent to permanently deprive, and (2) the court should have instructed the jury on attempted robbery as a lesser-included offense.
The trial court denied both requested reliefs; the Supreme Court of Kentucky affirmed, holding the evidence supported a robbery conviction and that attempt instruction was unnecessary.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether directed verdict on first-degree robbery was required	Commonwealth: evidence supports robbery conviction (force, keys, statements)	Searcy: drug-induced paranoia meant he lacked intent to permanently deprive; fled on foot, so no completed theft	Denied — reasonable juror could find intent and completed robbery; evidence supports conviction
Whether jury should have been instructed on attempted robbery as lesser-included offense	Commonwealth: robbery instruction included attempt language; evidence shows completed robbery	Searcy: evidence supported only attempt, not completed theft	Denied — trial court properly refused attempt instruction because evidence permits a finding of completed robbery

In re Winship, 397 U.S. 358 (Due process requires proof beyond a reasonable doubt)
Commonwealth v. Fletcher, 59 S.W.3d 920 (standard for directed verdict review)
Commonwealth v. Benham, 816 S.W.2d 186 (directed verdict principles)
Commonwealth v. Jones, 283 S.W.3d 665 (construing evidence for appellate review)
Manning v. Commonwealth, 23 S.W.3d 610 (duty to instruct on theories reasonably deducible from evidence)
Sargent v. Schaffer, 467 S.W.3d 198 (party entitled to instruction on its theory if evidence sustains it)
Springfield v. Commonwealth, 410 S.W.3d 589 (review standard for refusal to give an instruction)
Commonwealth v. English, 993 S.W.2d 941 (abuse-of-discretion standard for jury instructions)
Travis v. Commonwealth, 327 S.W.3d 456 (force plus intent can support robbery even if property not taken)
Kirkland v. Commonwealth, 53 S.W.3d 71 (robbery conviction may rest on attempted taking with force)