Woolfolk v. Commonwealth, 339 S.W.3d 411

1984: A.C., 17, accuses Woolfolk, then 51, a pastor, of raping her after he picked her up from school.
Woolfolk allegedly took A.C. to the church office; A.C. reported a rape and later attempted an abortion with a coat hanger.
A.C.'s mother confronted Woolfolk; Woolfolk admitted touching but denied rape or forced penetration.
About 23 years later, A.C. attempted suicide; her mother contacted police; Woolfolk admitted a sexual encounter but denied force/penetration.
Woolfolk was indicted on February 4, 2008; trial began January 26, 2010; jury convicted him of first-degree rape and recommended 20-year sentence.
During a lunch break, Woolfolk contradicted prior statements; his counsel sought a competency evaluation which the court did not order; Woolfolk argued the court discouraged him from testifying and that pretrial delays violated speedy-trial rights.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Right to testify: improper coercion by perjury warnings	Woolfolk argues the judge’s perjury warning coerced him from testifying.	Woolfolk contends the warning was error and infringed his right to testify.	Warning was error but harmless beyond a reasonable doubt.
Competency evaluation required	Woolfolk asserts the court should have ordered a competency evaluation.	Commonwealth argues no reasonable grounds required a continuance for competency testing.	No abuse of discretion; no compelled continuance for competency evaluation.
Speedy-trial pre-indictment delay	Woolfolk claims 24-year delay before indictment violated due process.	Commonwealth argues speedy-trial rights do not attach before indictment; delay not intentional.	No due-process violation from pre-indictment delay.

Hillard v. Commonwealth, 158 S.W.3d 758 (Ky.2005) (perjury warnings to witnesses may be improper when coercive.)
Webb v. Texas, 409 U.S. 95 (U.S. 1972) (warnings about perjury can be coercive if they intimidate testimony.)
United States v. Blackwell, 694 F.2d 1325 (D.C. Cir.1982) (warnings about perjury cannot be so severe as to deter testimony.)
Davis v. Texas, 831 S.W.2d 426 (Tex.App.1992) (perjury warnings outside the proper scope.)
Chapman v. California, 386 U.S. 18 (U.S. 1967) (harmless-error standard for constitutional errors.)
Padgett v. Commonwealth, 312 S.W.3d 336 (Ky.2010) (distinguishes statutory vs. due-process competency standards.)
Turner v. Commonwealth, 153 S.W.3d 823 (Ky.2005) (standard for reviewing competency determinations.)
Rock v. Arkansas, 483 U.S. 44 (U.S.1987) (defendant’s right to testify needed for a fair trial.)
Quarels v. Commonwealth, 142 S.W.3d 73 (Ky.2004) (denial of right to testify is trial-type error subject to harmless-error analysis.)