Robinson v. Commonwealth
325 S.W.3d 368
| Ky. | 2010Background
- Deputy Coroner Hall investigated HL's death at the Robinson home on November 2, 2005; HL was pronounced dead the same evening.
- Autopsy showed approximately twenty-six bruises, skull base fractures causing hypoxic brain injury, arm injuries, and fractures with long-standing bone issues; toxicology revealed promethazine and alprazolam at toxic levels.
- Medical examiner Dr. Rolf attributed death to skull fractures (subdural/subarachnoid hematomas) from a severe blow; drugs could cause respiratory depression and death.
- Appellant and HL's biological mother Amber were to be tried jointly; Amber pled guilty open to a life sentence; Appellant was convicted of murder and received a life sentence.
- The trial court instructed the jury that murder could be based on beating, overmedicating, or failing to provide medical care, and required a unanimous verdict; the defense challenged sufficiency of evidence for the alternative theories.
- The Kentucky Supreme Court held there was sufficient evidence to support both theories (beating and overmedicating) and affirmed the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there sufficient evidence to support murder by beating? | Robinson | Robinson | Yes; sufficient evidence supported beating as a theory of causation. |
| Was there sufficient evidence to support murder by overmedicating? | Robinson | Robinson | Yes; jury could reasonably find overmedication caused HL's death. |
Key Cases Cited
- Cannon v. Commonwealth, 291 Ky. 50, 163 S.W.2d 15 (1942) (unanimous verdict required; multiple theories may support a conviction)
- RCr 9.82(1), — (—) (unanimity requirement governs verdicts in Kentucky trials)
- Johnson v. Commonwealth, 12 S.W.3d 258, 265-66 (Ky.1999) (combination theories do not defy unanimity if evidence supports either)
- Miller v. Commonwealth, 77 S.W.3d 566, 574 (Ky.2002) (affirming admissibility of alternative theories with sufficiency)
- Wells v. Commonwealth, 561 S.W.2d 85, 88 (Ky.1978) (jury may rely on alternative interpretations of evidence)
- Gillispie v. Commonwealth, 212 Ky. 472, 279 S.W.671, 672 (1926) (jury may believe any portion or none of a witness's testimony)
- Ratliff v. Commonwealth, 194 S.W.3d 258 (Ky.2006) (credibility weighing of witnesses for the jury)
- Webb v. Commonwealth, 904 S.W.2d 226 (Ky.1995) (jury credibility determinations are for the jury)
- Commonwealth v. Benham, 816 S.W.2d 186 (Ky.1991) (evidence may support alternative causation theories)