Clifford D. Rawls v. Commonwealth of Kentucky

Summary

The Kentucky Supreme Court affirmed Rawls's convictions and thirty‑four‑year sentence, holding that the trial court was correct in refusing a lesser‑included offense instruction on possession of a methamphetamine precursor and in denying a suppression hearing because the warrant affidavit established probable cause and satisfied the particularity requirement through incorporation. The Court also clarified that Franks does not require a hearing absent intentional or reckless falsehoods and that an evidentiary hearing was not preserved on the attachment issue.