William Vernon Matthews, Appellant v. Commonwealth of Kentucky, Appellee

Summary

The court affirmed Matthews's rape and persistent-felony-offender convictions, holding that the trial court did not abuse its discretion by denying a mistrial after an unsolicited reference to prior incarceration or by admitting evidence of a prior misdemeanor charge to show motive. The court held that the West Virginia hospital records were improperly admitted because the applicable Kentucky statute did not cover out-of-state records and the records were not properly authenticated under the applicable self-authentication rule, but it found the error harmless. Cooper, J., concurring, agreed with the result because the authentication issue was unpreserved, disagreed with the majority's authentication analysis and treatment of precedent, and would apply more differentiated standards of review to other-acts evidence.