Michael D. St. Clair v. Commonwealth of Kentucky

Summary

The Kentucky Supreme Court affirmed St. Clair’s murder conviction and death sentence following a retrial of the penalty phase. It held that most challenges to the underlying conviction were barred or procedurally defaulted, that newly discredited comparative bullet lead analysis did not warrant a new trial because the remaining evidence of guilt was compelling, and that numerous sentencing objections either lacked merit, were waived, or were harmless. The court found that victim-impact testimony from a victim of an unrelated murder was improperly admitted and violated constitutional protections, but concluded the error was harmless beyond a reasonable doubt. Justice Cunningham, concurring, agreed with the result and emphasized that the same defendant had twice previously received death sentences without the challenged victim-impact testimony.