Brian Dewayne Edmonds v. Commonwealth of Kentucky

Summary

The Kentucky Supreme Court affirmed Edmonds’s convictions, holding that the sexual-assault nurse examiner’s testimony was admissible either under the medical-treatment hearsay exception or as testimony based on her independent observations and expertise. The Court also held that the evidence permitted a jury to find Edmonds intimidated a participant in the legal process because the statutory scheme includes potential witnesses and does not require a pending or imminent official proceeding. Justice Venters, joined by Justices Cunningham and Scott, dissented, arguing that the Court improperly overruled Moreland and that the evidence did not establish either participation in the legal process or actual hindrance of police communication.