Commonwealth v. Melton
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The Supreme Court reversed the judgment of the court of appeals concluding that the trial court acted within its discretion in excluding evidence of a guardianship order in a prior criminal prosecution against Defendant for custodial interference and other related charges, holding that the trial court abused its discretion by failing to apply the proper Ky. R. Evid. 403 analysis.
Defendant allegedly broke into a residence where her child lived with the child's father and his girlfriend, assaulted the girlfriend, and fled with the child. Defendant filed a motion in limine to exclude any reference to the guardianship order at issue, asserting that it would be unduly prejudicial. The trial court granted Defendant's motion and excluded the guardianship order. The court of appeals affirmed. The Supreme Court reversed and remanded the case for further proceedings, holding that the trial court erred in determining that evidence in the guardianship order would unduly prejudice Defendant by confusing the jury and that the guardianship evidence was vital to the Commonwealth's case.
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