complicity instruction (Kentucky) · Go Syfert
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complicity instruction in Kentucky

9 Kentucky opinions name it 2 courts 2008–2025 3 in the last five years

The cases below were cited by Kentucky courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Dixon v. Commonwealthgreen
ky · 2008 · cited in 1 Kentucky opinions naming this issue, 2025–2025
1 sentence

2025Dixon 24 v. Commonwealth, 263 S.W.3d 583, 586 (Ky. 2008).

11
Marshall v. Commonwealthgreen
ky · 2001 · cited in 1 Kentucky opinions naming this issue, 2024–2024
1 sentence

2024According to Carr, his participation in the theft of the Hummer was not sufficient evidence to substantiate complicity in Rader’s murder citing to Marshall v. Commonwealth, 60 S.W.3d 513, 518 (Ky. 2001), where we stated “although intent that a victim 1 The complicity instruction made Carr’s conviction dependent on the jury finding: (a) “. . .

11
Beaumont v. Commonwealthgreen
ky · 2009 · cited in 1 Kentucky opinions naming this issue, 2024–2024
1 sentence

2024Beaumont v. Commonwealth, 295 S.W.3d 60, 69 (Ky. 2009) (“Complicit conduct can be shown through . . . the existence of a basic conspiracy . . . .”), he was not also entitled to a facilitation instruction because he was not “wholly indifferent to the actual completion of the crime, i.e., without the intent that the crime be committed.” Thompkins v. Commonwealth, 54 S.W.3d 147, 151 (Ky. 2001).

11
Thompkins v. Commonwealthgreen
ky · 2001 · cited in 1 Kentucky opinions naming this issue, 2024–2024
1 sentence

2024Beaumont v. Commonwealth, 295 S.W.3d 60, 69 (Ky. 2009) (“Complicit conduct can be shown through . . . the existence of a basic conspiracy . . . .”), he was not also entitled to a facilitation instruction because he was not “wholly indifferent to the actual completion of the crime, i.e., without the intent that the crime be committed.” Thompkins v. Commonwealth, 54 S.W.3d 147, 151 (Ky. 2001).

11
Cheatham v. Chabalgreen
kyctapphigh · 1946 · cited in 1 Kentucky opinions naming this issue, 2020–2020
1 sentence

2020When presented with a complicity instruction, the jury may disbelieve the evidence supporting a finding that the defendant intended the crime be committed and consequently find the defendant not guilty of complicity. 178 S.W.3d at 490 (quoting Cheatham, 192 S.W.2d at 814).

11
Futrell v. Commonwealthgreen
ky · 2015 · cited in 1 Kentucky opinions naming this issue, 2016–2016
1 sentence

2016The misdrafting of Part C deprived the Commonwealth of a theory of guilt that was amply supported by the evidence because, literally read, it does not present the option of finding Appellant guilty if he acted in complicity with Megan; it states the opposite— Megan acting in complicity with him, making it redundant to Parts A and B. 3 Relief under palpable error review "may be granted if the error resulted in 3 Futrell v. Commonwealth, 471 S.W.3d 258, 280-81 (Ky. 2015), provides another example of misdrafted complicity to murder instructions wherein the defendant was identified in the complici

11
Chumbler v. Commonwealthgreen
ky · 1995 · cited in 1 Kentucky opinions naming this issue, 2012–2012
1 sentence

2012Chumbler v. Commonwealth, 905 S.W.2d 488, 499 (Ky.1995) (defendant did not adequately preserve for appellate review the issue of whether the complicity instruction presented to jury was improper where, although defendant tendered alternative instruction, she did not make specific objection to complicity instruction given by the trial court, and did not state specifically grounds on which she believed the court’s instruction was improper); Luckett v. Commonwealth, 550 S.W.2d 517, 520 (Ky.1977) (“Appellant’s failure to properly object constituted a waiver of his right to later complain.”); Commo

11
Luckett v. Commonwealthgreen
ky · 1977 · cited in 1 Kentucky opinions naming this issue, 2012–2012
1 sentence

2012Chumbler v. Commonwealth, 905 S.W.2d 488, 499 (Ky.1995) (defendant did not adequately preserve for appellate review the issue of whether the complicity instruction presented to jury was improper where, although defendant tendered alternative instruction, she did not make specific objection to complicity instruction given by the trial court, and did not state specifically grounds on which she believed the court’s instruction was improper); Luckett v. Commonwealth, 550 S.W.2d 517, 520 (Ky.1977) (“Appellant’s failure to properly object constituted a waiver of his right to later complain.”); Commo

11
Commonwealth v. Dukegreen
ky · 1988 · cited in 1 Kentucky opinions naming this issue, 2012–2012
1 sentence

2012Chumbler v. Commonwealth, 905 S.W.2d 488, 499 (Ky.1995) (defendant did not adequately preserve for appellate review the issue of whether the complicity instruction presented to jury was improper where, although defendant tendered alternative instruction, she did not make specific objection to complicity instruction given by the trial court, and did not state specifically grounds on which she believed the court’s instruction was improper); Luckett v. Commonwealth, 550 S.W.2d 517, 520 (Ky.1977) (“Appellant’s failure to properly object constituted a waiver of his right to later complain.”); Commo

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Kentucky. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
White v. Commonwealth green
ky · 2006
1 sentence

2020When presented with a complicity instruction, the jury may disbelieve the evidence supporting a finding that the defendant intended the crime be committed and consequently find the defendant not guilty of complicity. 178 S.W.3d at 490 (quoting Cheatham, 192 S.W.2d at 814).

12020–2020
Wolbrecht v. Commonwealth green
ky · 1997
1 sentence

2017Id. at 536-37 .

12017–2017
Smith v. Commonwealth green
ky · 2012
2 sentences

2014For example, in Smith v. Commonwealth, 370 S.W.3d 871 (Ky.2012), the Court considered a complicity instruction for second-degree assault that, on its face, omitted the intent element.

2014The Court nevertheless held that the instructions were adequate because the requisite mental state was incorporated by reference into the main instruction by the separate definition of “complicity.” Id. at 879 .

12014–2014
Parks v. Commonwealth green
ky · 2006
2 sentences

2008Appellant next argues that the trial court erred by giving the jury an alternative instruction whereby they could find him guilty either of intending to manufacture methamphetamine or of complicity, citing Parks v. Commonwealth, 192 S.W.3d 318 (Ky.2006).

2008Appellant next argues that the trial court erred by giving the jury an alternative instruction whereby they could find him guilty either of intending to manufacture methamphetamine or of complicity, citing Parks v. Commonwealth, 192 S.W.3d 318 (Ky.2006).

12008–2008

Statutes the citing opinions construe

KY § Ky. Rev. Stat. § 502.020 (6)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

OH 60 (1994–2025) CO 28 (1975–2026) IL 17 (1976–2012) KY 9 (2008–2025) WA 7 (1994–2020) AL 6 (1991–2023) MN 4 (1984–2000) SD 3 (1991–2013) OR 3 (2000–2018) CA 2 (2015–2015) IA 2 (1983–1990) NJ 2 (1986–1992)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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