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St. Clair v. Commonwealth

140 S.W.3d 510 (2004)

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St. Clair v. Commonwealth

Kentucky Supreme Court
140 S.W.3d 510 (2004)

SC

Facts

Michael St. Clair (defendant) was convicted of two murders in Oklahoma. In September 1991, while awaiting sentencing, St. Clair escaped from jail. St. Clair was eventually caught and was charged with murdering Frances Brady in Kentucky while he was on the run. Final judgments for the Oklahoma murders were not entered until November 1991, after the Brady murder. The jury convicted St. Clair of the Brady murder and found aggravating circumstances based on the Oklahoma murders. As a result, St. Clair was sentenced to death based on a Kentucky law that included a prior record of conviction for murder as an aggravating circumstance for the crime of murder. St. Clair appealed, arguing that he did not have a prior record of conviction for murder because final judgments for the Oklahoma murders had not yet been entered at the time of the Brady murder.

Rule of Law

Issue

Holding and Reasoning (Waller, J.)

Concurrence/Dissent (Keller, J.)

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