Rankin v. Commonwealth
2010 Ky. LEXIS 287
| Ky. | 2010Background
- Rankin was convicted by a Fayette Circuit Court jury of first-degree criminal abuse and wanton murder in connection with the death of his girlfriend's six-month-old daughter, C.A., with concurrent 10- and 20-year sentences.
- Rankin argued the trial was unfair due to (a) the court's refusal to strike Juror 462 for cause, who disclosed childhood sexual abuse, and (b) admission of a social worker's video experiment involving C.A.'s brother, M.A.
- Rankin claimed his mild mental retardation rendered him incapable of acting wantonly, and the court should have directed a verdict on the wanton murder charge.
- The Commonwealth contended Juror 462 could be impartial and that the video experiment was probative and not unduly prejudicial.
- Autopsy showed multiple rib and appendicular fractures and a fatal head injury; timing of some injuries was uncertain, but immediate cause was blunt force trauma to the head; Rankin had access to C.A. and the evidence supported that he caused the fatal injury.
- Rankin's claim of insufficient evidence to sustain wanton murder rested on his retardation, but the court held the evidence supported a finding of wantonness.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the trial court abuse its discretion by not striking Juror 462 for cause? | Rankin argues Juror 462's abuse history created bias. | Rankin contends juror's trauma made fair assessment unlikely. | No abuse; juror could consider evidence dispassionately. |
| Was the social worker's video experiment admissible evidence? | Rankin asserts the experiment misleads and is prejudicial. | Commonwealth contends it is probative of reliability of Rankin's statements. | Admissible; limitations affect weight, not admissibility. |
| Was there sufficient evidence Rankin acted wantonly given mild retardation? | Rankin claims lack of capacity to perceive a grave risk. | Evidence showed Rankin understood potential harm and risk to the infant. | Sufficient evidence supported wanton murder; Rankin not entitled to relief. |
Key Cases Cited
- Shane v. Commonwealth, 243 S.W.3d 336 (Ky. 2007) (impartiality requires more than general assurances of fairness)
- Marsch v. Commonwealth, 743 S.W.2d 830 (Ky. 1988) (improper bias from relationships or ongoing counsel ties)
- Ratliff v. Commonwealth, 194 S.W.3d 258 (Ky. 2006) (implied bias and respectful handling of juror relationships)
- Brown v. Commonwealth, 313 S.W.3d 577 (Ky. 2010) (victim of similar crime does not automatically imply bias; must show additional bias evidence)
- Benham v. Commonwealth, 816 S.W.2d 186 (Ky. 1991) (directed-verdict standard on preserved claims; rational-view standard on appeal)
- Cecil v. Commonwealth, 297 S.W.3d 12 (Ky. 2009) (trial court discretion in admitting evidence reviewed for abuse)