Haynes v. Commonwealth
1983 Ky. LEXIS 283, 657 S.W. 2d 948 (1983)
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Rule of Law:
A trial court's erroneous failure to compel production of a witness's written statement under RCr 7.26 is a harmless error that does not require reversal of a conviction unless the defendant can show the error was prejudicial, meaning the unavailable information could have reasonably altered the verdict.
Facts:
- On the night of March 14 and early morning of March 15, 1980, several buildings in Elkhorn City, Kentucky, including a grocery store, a medical center, and a house, were burglarized and set on fire.
- A deputy sheriff arrested Terry Dean Haynes for public intoxication near the scene of one fire after noticing him by the road with a lunch pail from which money had spilled.
- In May 1980, after being charged with burglary and arson, Haynes escaped from jail.
- Haynes was located in West Virginia and extradited back to Kentucky in February 1982.
- During the car ride from West Virginia, after being read his rights twice, Haynes initiated a conversation with police officers and confessed to the crimes, stating he committed them while under the influence of drugs.
- One of the burglarized buildings was a house owned by the heirs of Lundy Elswick; after the last permanent resident died in January 1980, a relative, John Elswick, would occupy it for a day or two at a time during visits to the city.
- The Elswick house was unoccupied on the night of the break-in.
Procedural Posture:
- Terry Dean Haynes was tried in Pike Circuit Court for multiple counts of burglary and arson.
- During the trial, Haynes's counsel moved for the production of a written report made by the primary investigating officer, which the trial court denied.
- A jury found Haynes guilty on two counts of third-degree burglary, one count of first-degree burglary, and three counts of second-degree arson.
- The trial court sentenced Haynes to a total of thirty years' imprisonment.
- Haynes (as appellant) filed a direct appeal of his convictions to the Supreme Court of Kentucky.
- The Commonwealth (as appellee) filed a cross-appeal concerning other evidentiary rulings.
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Issue:
Does a trial court's erroneous refusal to order the production of a police officer's investigative report, in violation of a rule of criminal procedure, require reversal of a conviction if the defendant cannot demonstrate that the error was prejudicial?
Opinions:
Majority - Aker, Justice
No. A trial court's erroneous failure to compel production of a witness's report does not require reversal unless the error is prejudicial. Under RCr 9.24, errors that do not affect substantial rights must be disregarded. The court acknowledged that the trial court's refusal to produce Detective Phipps's signed investigative report was a clear error under RCr 7.26, as there is no 'work product' exception for such reports. However, the court found the error was not prejudicial because, after reviewing the report, it determined the report contained no information that could have been used to impeach a witness or establish a fact that might have reasonably altered the verdict. Evidence regarding the appellant's intoxication, which he claimed was exculpatory, was already presented at trial through other testimony. Since the report added nothing new that could have aided the defense, the error was harmless. The court also held that the appellant's confession was voluntary and admissible because he initiated the conversation after a knowing and intelligent waiver of his rights, and the burglarized house qualified as a 'dwelling' because it was customarily, if not continuously, occupied.
Analysis:
This case reinforces the application of the harmless error doctrine to procedural discovery violations in criminal cases. It clarifies that a clear violation of a rule, such as failing to produce a witness statement, does not automatically result in a new trial. The decision places a burden on the appellate court to review the withheld evidence and determine its potential impact, preventing convictions from being overturned on technicalities that did not affect the defendant's substantial rights or the trial's outcome. This approach balances the need for procedural fairness with the principles of judicial economy and finality.
