Woolfolk v. KentuckyAnnotate this Case
Appellant Prince Wilbert Woolfolk was convicted of first-degree rape. On the jury's recommendation, he was sentenced to twenty years' imprisonment. In 1984, the victim was seventeen years old and an active member in her church's choir. On the date of the crime, the victim learned from her mother that Appellant, the pastor of the church, had called to say he would pick her up from school and take her to church, presumably for a choir activity. According to the victim, Appellant took her to his office and raped her. Twenty-three years later, the victim attempted suicide. Believing that the rape may have played a part in the attempt, the victim's mother contacted police about the 1984 incident. On investigation, Appellant admitted to police that a sexual encounter with the victim occurred. In 2008, Appellant was indicted for first-degree rape. During a lunch break at trial, Appellant's defense counsel conferred to discuss how to best cross-examine the victim about her claim; to counsel's surprise, and contrary to all prior statements Appellant had made on the subject, Appellant told his counsel he raped the victim. Counsel became concerned on his ethical duty to the court should Appellant take the stand and deny the rape. Counsel contacted the Kentucky Bar Association and requested an ex parte in camera conference with the court. Counsel moved the court to order a competence examination of Appellant, and to delay proceedings pending such an examination. The court denied both requests. On appeal, Appellant claims: that the trial court erred by discouraging Appellant from exercising his constitutional right to testify; that the trial court erred by failing to order a competency evaluation; and that there was a violation of his right to a speedy trial because of the twenty-four year lapse of time between the crime and the bringing of the indictment. Upon review, the Supreme Court concluded that the lower court did not abuse its discretion in failing to order a competency hearing; and though constitutional error occurred in the trial court's effort to discourage Appellant from testifying falsely, the error was harmless beyond a reasonable doubt. The Court affirmed the lower court's conviction and sentence.