Kentucky Supreme Court
Mark Padgett, Appellant v. Commonwealth of Kentucky, Appellee
March 18, 20102010 Ky. LEXIS 71
Summary
The Court affirmed Appellant's convictions, holding that the trial court did not compel self-incrimination by requiring admissible evidence to support an extreme-emotional-disturbance instruction, and adequately investigated Appellant's dissatisfaction with counsel. It further held that Appellant neither requested hybrid counsel nor demonstrated a due-process violation from the absence of a competency hearing, and that the prosecutor's closing arguments did not constitute reversible misconduct. The Court clarified that statutory and constitutional competency-hearing rights are distinct and expressly overruled inconsistent prior approaches.