Young v. Commonwealth
2014 Ky. LEXIS 154
| Ky. | 2014Background
- Appellant Jonathan Young was convicted of murder by complicity, first-degree robbery by complicity, and second-degree arson by complicity.
- Victim Thomas Max Martin died from gunshot wounds; the fire at his home was investigated as part of the case.
- A neighbor reported Martin was at home with two men, one named 'Jess,' leading investigators to Jesse Parke and Young as suspects.
- Young gave multiple police interviews with evolving accounts, including admissions and later denials of involvement, and sent text messages indicating involvement.
- Police obtained evidence from a recorded phone conversation and a four-page written statement detailing involvement in robbery and the murder.
- The Monroe Circuit Court denied directed-verdict motions and instructed the jury on complicity, but the appellate court reverses and remands for retrial consistent with the opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is there sufficient evidence for murder by complicity? | Young contends insufficient evidence under KRS 502.020(1)/(2). | Young argues no proof he intended or contributed to death. | Evidence could support both complicity theories; no directed verdict required. |
| Was there proper corpus delicti support for robbery by complicity? | Corroboration not required beyond confession once corpus delicti proved. | Confession alone could not prove robbery absent corroboration. | Corroboration existed (recorded phone call); no palpable error in denying directed verdict. |
| Were the jury instructions on complicity reversible error due to missing mental-state elements? | Instructions omitted required mental-state element, constituting palpable error. | Mental-state elements may be inferred; instructions were adequate or harmless. | The omission was palpable error; reversal is required. |
Key Cases Cited
- Commonwealth v. Benham, 816 S.W.2d 186 (Ky. 1991) (directed-verdict standard; sufficiency review)
- Smith v. Commonwealth, 370 S.W.3d 871 (Ky. 2012) (armony of mental-state in complicity instructions)
- Crawley v. Commonwealth, 107 S.W.3d 197 (Ky. 2003) (adequacy of complicity instructions when mental state incorporated by reference)
- Harper v. Commonwealth, 43 S.W.3d 261 (Ky. 2001) (reversal for lack of defined mental state in complicity to murder)
- Miller v. Commonwealth, 391 S.W.3d 857 (Ky. 2013) (jury must find elements of crime; harmless-error analysis)
- Thacker v. Commonwealth, 194 S.W.3d 287 (Ky. 2006) (elements required for conviction; complicity context)
- Watkins v. Commonwealth, 298 S.W.2d 306 (Ky. 1957) (general principles on criminal evidence and corroboration)