2024-SC-0335
Ky.Jun 25, 2026Background
- Baker was convicted of murder, first-degree burglary, and PFO 2nd, and sentenced to life without parole. 1
- The victim, Robert Claunch, was shot and killed at Ronald Baker’s home after an argument between Baker and Ronald earlier that week. 2
- On the day of the murder, Baker arrived at Ronald’s trailer, argued with Ronald, and gunshots were heard moments after Ronald went to bed. 3
- Police recovered 9mm shell casings and later linked a firearm found after a Casey County chase to Baker by DNA and to the shell casings. 4
- At trial, the jury heard evidence of the March 14 incident, the Casey County pursuit, and Baker’s later flight from Kentucky with stolen property and firearms. 5
- Baker requested a criminal trespass instruction as a lesser included offense of burglary, but the trial court refused. 6
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admission of March 14 incident under KRE 404(b) 7 | Baker said the prior argument and gunfire were irrelevant propensity evidence. | Commonwealth said it showed motive and the relationship leading to murder. | Admitted; directly relevant and proper motive evidence. 8 |
| Admission of Casey County pursuit and charges 9 | Baker said the chase and charges showed criminal propensity. | Commonwealth said the chase was flight and part of the same course of conduct. | Admitted; relevant flight evidence and inextricably intertwined. 10 |
| Admission of later flight from Kentucky and Kansas offenses 11 | Baker said the later multi-state crimes were irrelevant and unfairly prejudicial. | Commonwealth said they showed consciousness of guilt and complete context. | Admitted; probative value outweighed prejudice. 12 |
| Refusal to instruct on criminal trespass 13 | Baker said the jury could find unlawful entry without intent to commit a crime. | Commonwealth said no evidence supported trespass only; Baker’s defense was alibi. | No abuse of discretion; instruction properly refused. 14 |
Key Cases Cited
- Burdette v. Commonwealth, 664 S.W.3d 605 (Ky. 2023) (KRE 404(c) notice and relevance framework 15)
- Clark v. Commonwealth, 223 S.W.3d 90 (Ky. 2007) (prior bad acts generally inadmissible and closely scrutinized 16)
- Bell v. Commonwealth, 875 S.W.2d 882 (Ky. 1994) (three-part inquiry for KRE 404(b) admissibility 17)
- Jenkins v. Commonwealth, 496 S.W.3d 435 (Ky. 2016) (probative value and prejudice analysis under KRE 403/404(b) 18)
- Brewer v. Commonwealth, 206 S.W.3d 313 (Ky. 2006) (abuse-of-discretion standard for evidentiary rulings 19)
- McGuire v. Commonwealth, 368 S.W.3d 100 (Ky. 2012) (motive is relevant and admissible in murder trials 20)
- White v. Commonwealth, 178 S.W.3d 470 (Ky. 2005) (motive exception requires a direct connection to the charged crime 21)
- Day v. Commonwealth, 361 S.W.3d 299 (Ky. 2012) (flight may be admitted as evidence of guilt 22)
- Rodriguez v. Commonwealth, 107 S.W.3d 215 (Ky. 2003) (flight and related theft can show consciousness of guilt 23)
- Stanford v. Commonwealth, 793 S.W.2d 112 (Ky. 1990) (evidence necessary to give the jury a complete, unfragmented picture may be admissible 24)
- Sargent v. Shaffer, 467 S.W.3d 198 (Ky. 2015) (review of refusal to give an instruction is for abuse of discretion 25)
- Taylor v. Commonwealth, 995 S.W.2d 355 (Ky. 1999) (trial courts must instruct on the whole law supported by the evidence 26)
- Colwell v. Commonwealth, 37 S.W.3d 721 (Ky. 2000) (definition of lesser included offense and trespass analysis 27)
- McClellan v. Commonwealth, 715 S.W.2d 464 (Ky. 1986) (criminal trespass can be a lesser included offense of burglary when evidence supports it 28)