Ronald Lynn Craft v. Commonwealth of Kentucky, 483 S.W.3d 837

On Dec. 24, 2010, Ronald Lynn Craft stabbed Leonard Dixon; Dixon died from a single six‑inch chest wound. A bloody knife found in Craft’s bedroom tested positive for Dixon’s DNA. Craft admitted being at the store and said, "I ain't killed nobody," but defense counsel conceded the stabbing at opening and asserted self‑defense.
Craft was indicted for murder, tampering with physical evidence, and first‑degree persistent felony offender (PFO); the jury convicted him of murder and PFO but acquitted on tampering; the trial court later reduced the sentence to 20 years (PFO enhancement set aside as inapplicable to murder).
At trial the Commonwealth exercised nine peremptory challenges granted by the trial court; Craft contended he was entitled to none under his reading of KRS 29A.290(2)(b) and RCr 9.40.
Craft appealed raising two issues: (1) statute KRS 29A.290(2)(b) unconstitutionally delegates legislative power to the judiciary by letting the Court prescribe the number of prosecutorial peremptory challenges, and (2) the evidence was insufficient to support an intentional/wanton murder conviction (he sought a directed verdict).
The Supreme Court of Kentucky declined to reach the statutory separation‑of‑powers claim because Craft failed to comply with KRS 418.075 (notice to the Attorney General required for statutory constitutional challenges), and affirmed the denial of a directed verdict, holding the evidence could support intent or wantonness.

Issue	Plaintiff's Argument (Craft)	Defendant's Argument (Commonwealth)	Held
Whether KRS 29A.290(2)(b) and court discretion under RCr 9.40 unlawfully delegate legislative power by allowing the Court to set prosecutorial peremptory challenges	KRS 29A.290(2)(b) impermissibly delegates a legislative function to judiciary; Commonwealth not entitled to peremptory strikes absent clear legislative grant	Statute recognizes Court authority and RCr 9.40 sets baseline; issue raises rule/statute interplay and has been litigated before	Not reached on merits: appeal barred for failure to serve the Attorney General under KRS 418.075; court declined review of statutory constitutional challenge
Whether evidence was insufficient to sustain murder conviction (directed verdict)	Lack of eyewitness account makes mental state (intent or wantonness) unknowable; thus directed verdict required	Intent/wantonness can be inferred from the act and surrounding circumstances (depth/character of wound, conduct before/after); jury may infer requisite mental state	Affirmed: under the totality of circumstances, a reasonable jury could find intent or wantonness beyond a reasonable doubt; directed verdict properly denied

Glenn v. Commonwealth, 436 S.W.3d 186 (Ky. 2014) (permitted narrow appellate review of Court‑created procedural rule without AG notice; distinguishes statute‑based challenges)
Benet v. Commonwealth, 253 S.W.3d 528 (Ky. 2008) (strict compliance with KRS 418.075 notice requirement is mandatory)
Grider v. Commonwealth, 404 S.W.3d 859 (Ky. 2013) (applied KRS 418.075 to bar review of RCr 9.40 when argued with KRS 29A.290 challenge)
In re Winship, 397 U.S. 358 (U.S. 1970) (Due Process requires proof beyond a reasonable doubt of every element)
Mills v. Commonwealth, 996 S.W.2d 473 (Ky. 1999) (intent may be inferred from surrounding circumstances)
Hudson v. Commonwealth, 979 S.W.2d 106 (Ky. 1998) (extent and character of injuries can support inference of intent)