Commonwealth of Kentucky v. Leah Tramble

Summary

The court reversed the Court of Appeals and reinstated Tramble's conviction for trafficking in marijuana over five pounds. It held that evidence concerning prior marijuana shipments and the prior drug investigation involving Cottrell was admissible to establish knowledge, intent, and the Commonwealth's theory of the transaction. The prosecutor misstated facts during closing argument and the trial court should have admonished the jury, but the error was harmless; the late disclosure of Tramble's incriminating statement was also a discovery violation that caused no prejudice. NOBLE, J., dissenting, would have reversed because the prior-crime evidence and the prosecutor's comment were not harmless.