Kentucky Supreme Court

Jonathan Young v. Commonwealth of Kentucky

April 17, 20142014 Ky. LEXIS 154

Summary

The Court held that sufficient evidence supported the convictions for murder and robbery by complicity, so the trial court properly denied directed-verdict motions on those charges. It nevertheless reversed because the complicity instructions for murder, robbery, and arson failed to require the jury to find that Young acted with the mental state required for accomplice liability, an omission constituting palpable error. On retrial, the complicity instructions for robbery and arson should be drafted under the provision governing conduct crimes.