Michael Vaughan v. Commonwealth of Kentucky
2016 SC 000205
| Ky. | Aug 22, 2017Background
- In Dec. 2013 Michael Vaughan barricaded himself in his home, fired at police, and was arrested after a multi-day standoff; indicted Feb. 27, 2014 and arraigned Mar. 10, 2014.
- Numerous pretrial delays followed: defense counsel issues (failure to file mental‑incapacity notice, late turnover of files, change of counsel), voluminous electronic discovery from ATF provided late, a hunger strike by Vaughan requiring additional KCPC evaluation, and collateral witness‑intimidation proceedings.
- First trial was set one year after arraignment (Mar. 10, 2015) but continued; final trial date was scheduled for Feb. 23, 2016.
- On Feb. 15, 2016 Vaughan entered a conditional guilty plea to six counts of first‑degree wanton endangerment, reserving the right to appeal a speedy‑trial claim.
- Trial court sentenced Vaughan to 20 years; Vaughan appealed alleging a Sixth Amendment speedy‑trial violation based on a 26‑month delay from arrest to plea.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a 26‑month delay violated Vaughan's Sixth Amendment right to a speedy trial | Vaughan: 26‑month delay between arrest/arraignment and plea was presumptively prejudicial and deprived him of a speedy trial | Commonwealth: Delay was largely caused by Vaughan or neutral/valid reasons (defense counsel failures, federal ATF processing, Vaughan's hunger strike, competency and docket issues) | Court held no violation: delay triggered Barker inquiry but balanced factors favor Commonwealth; no reversible error |
| Who bears blame for the delay | Vaughan: Commonwealth delayed by late disclosure of voluminous electronic discovery | Commonwealth: Many delays attributable to defense counsel’s inaction, counsel changes, Vaughan’s hunger strike, and neutral causes outside Commonwealth control | Court found most delay attributable to Vaughan or neutral/valid reasons |
| Whether Vaughan sufficiently asserted his speedy‑trial right | Vaughan: made multiple pro se and counsel‑filed speedy‑trial requests | Commonwealth: defense counsel acquiesced to continuances; Vaughan did not vigorously assert the right | Court: Vaughan asserted the right but not vigorously; factor does not weigh in his favor |
| Whether Vaughan showed prejudice from the delay | Vaughan: pretrial incarceration caused loss of job, custody, education, anxiety, and impaired defense due to late discovery and laptop removal | Commonwealth: imprisonment due to inability to post bond; laptop removal resulted from Vaughan’s misconduct; late discovery was produced promptly upon receipt by Commonwealth | Court: Vaughan failed to show oppressive incarceration, unusual anxiety, or actual impairment of defense |
Key Cases Cited
- Gabow v. Commonwealth, 34 S.W.3d 63 (Ky. 2000) (adopts Barker balancing for Kentucky speedy‑trial claims)
- Barker v. Wingo, 407 U.S. 514 (1972) (four‑factor balancing test for speedy‑trial claims)
- Dunaway v. Commonwealth, 60 S.W.3d 563 (Ky. 2001) (defines length of delay and complexity weighting)
- Dillingham v. United States, 423 U.S. 64 (1975) (measuring delay from arrest or indictment)
- Bratcher v. Commonwealth, 151 S.W.3d 332 (Ky. 2004) (18‑month delay in complex murder case triggered presumptive prejudice)
- Doggett v. United States, 505 U.S. 647 (1992) (focus on who is to blame for delay)
- Stacy v. Commonwealth, 396 S.W.3d 787 (Ky. 2013) (assessment of defendant’s assertion and prejudice factors)
- Goncalves v. Commonwealth, 404 S.W.3d 180 (Ky. 2013) (sets out speedy‑trial prejudice interests)
- Miller v. Commonwealth, 283 S.W.3d 690 (Ky. 2009) (speculative claims of impaired defense are insufficient)