## Facts

- Michael D. St. Clair escaped from an Oklahoma jail in 1991 while awaiting sentencing after being found guilty of two murders.
- During a multi-state flight, St. Clair and an accomplice stole vehicles and weapons and committed additional crimes, including kidnappings and other violent acts.
- After arriving in Kentucky, St. Clair kidnapped Frances Brady and murdered him.
- Kentucky prosecuted St. Clair for the Brady kidnapping and murder and sought the death penalty.
- In the penalty phase, the Commonwealth relied on St. Clair’s Oklahoma murder cases as a statutory aggravator requiring a “prior record of conviction for murder,” although final Oklahoma judgments were entered after the Brady murder.
- The trial court admitted extensive evidence of the escape and multi-state offenses as part of a continuous course of conduct explaining the context of the Kentucky crimes.
- A jury convicted St. Clair of capital murder and recommended a death sentence.

## Issues

1. Whether the statutory aggravator “prior record of conviction for murder” required entry of final judgment on the earlier murders before the Kentucky homicide, or whether prior guilty verdicts were sufficient.
2. Whether evidence of the escape and other crimes committed during the multi-state flight was inadmissible other-crimes evidence, or admissible as part of a continuous course of conduct necessary to explain the charged offenses.
3. Whether alleged additional errors in jury selection, instructions, argument, and evidentiary rulings required reversal of the conviction or death sentence.

## Decision

- The Kentucky Supreme Court affirmed the capital murder conviction and the death sentence.
- The court held that the Oklahoma guilty verdicts constituted a “prior record of conviction for murder” for purposes of Kentucky’s aggravating-circumstance statute, even though final judgments were entered later.
- The court upheld admission of the “crime spree” evidence as part of a continuous course of conduct that provided necessary context for the Kentucky offenses and was not admitted solely to prove propensity.
- The court rejected remaining claims of trial and penalty-phase error as meritless, non-prejudicial, or harmless.

## Legal Principles

- For Kentucky capital sentencing, “conviction” in a “prior record of conviction for murder” aggravator may include an adjudication of guilt by verdict or guilty plea, even if formal judgment is entered after the capital offense.
- Other-crimes evidence may be admissible when the acts are intrinsic to the charged offense and part of a continuous course of conduct such that exclusion would materially impair the jury’s understanding of the sequence, context, or explanation of the charged crime.
- On direct review in capital cases, asserted errors warrant relief only when they affected substantial rights; otherwise, errors may be deemed harmless.

## Conclusion

The court upheld St. Clair’s conviction and death sentence, ruling that prior out-of-state guilty verdicts satisfied Kentucky’s “prior conviction” aggravator and that evidence of a connected multi-state crime spree was properly admitted to present a coherent account of the charged Kentucky kidnapping and murder.


St. Clair v. Commonwealth, 140 S.W.3d 510 (Ky. 2004)