Beaty v. Commonweath
Supreme Court of Kentucky
125 S.W.3d 196 (2003)
Police stopped a car driven by Roger Beaty (defendant), with his girlfriend Marion Ann Hanks in the passenger seat. Beaty failed a field sobriety test, and a search turned up drugs on his person and methamphetamine-manufacturing items in the car, which the couple had borrowed from its owner, Pamela Kuhl. The Commonwealth of Kentucky charged Beaty with nine counts, including manufacturing methamphetamine. At trial, Beaty tried to introduce evidence that Kuhl planted the methamphetamine items herself, motivated by jealousy over Hanks's relationship with Kuhl's boyfriend, and that Kuhl had the opportunity to plant them before loaning out the car. The trial court excluded this evidence, and Beaty was convicted. He appealed, arguing he was denied his right to present a defense.
Whether excluding a criminal defendant's evidence that a third party had both motive and opportunity to commit the charged offense is reversible error.