In 2017, Daquan N. Lampkins was convicted of two counts of murder, possession of a handgun by a convicted felon, tampering with physical evidence and violation of an Emergency Protective Order in Jefferson County, Kentucky. The victims were his previous girlfriend, Carron, – who had an extensive history of abuse and domestic violence at the hands of Lampkins– and her current boyfriend, Jones. At the time of the murders, Carron had an active Emergency Protective Order (EPO) against Lampkins.
On April 13, 2017, Lampkins tried to contact Carron who refused to see him, prompting Lampkins to go to her apartment complex, where he shot and killed Carron and Jones. Upon his conviction, Lampkins appealed his case to the Kentucky Supreme Court on grounds that certain evidence was omitted concerning marijuana in the victim’s system at the time of death, allowance of potentially biased jury members, and the allowance of evidence of a prior bad act. The Kentucky Supreme Court affirmed the judgment of the Jefferson Circuit Court on June 13, 2024, on the following grounds:
Lampkins’ main defense in his trial was that there was an alleged alternate perpetrator – Carron’s drug dealer, whose DNA evidence was found outside her apartment complex. With this evidence, Lampkins argued that the presence of marijuana in Carron’s and Jones’s toxicology reports should have been allowed as evidence in the trial. However, per the Kentucky rules, a defendant cannot present proof of unsupported theories that would invite the jury to speculate.
Additionally, Lampkins sought judicial notice of the fact that DNA from Carron’s drug dealer was found at her apartment complex, but was not disclosed to him for 18 months. Judicial Notice allows the introduction of commonly known facts as evidence. However, it must be a fact “not subject to reasonable dispute.” The date that evidence was provided to the defense does not affect the jury’s determination of the guilt or innocence of a defendant, so the Court determined it was not appropriate to take judicial notice of the date.
Lampkins argued that the Circuit Court allowed two jurors “incapable of accepting the presumption of innocence” to weigh in on his trial. To prove a juror unfit, the court must weigh the probability the juror(s) had bias based on their responses during jury selection. The Kentucky Supreme Court found no evidence that the jurors in question had exhibited a false understanding of the presumption of innocence and therefore were fit to serve on the jury in this case.
Finally, Lampkins argued that the admittance of testimony regarding the history of violence between him and Carron was a “Prior Bad Act” that should not have been allowed. Under the Kentucky Rules, evidence of prior bad acts is inadmissible to prove a person acted in conformity on the day of the alleged crimes. However, if relevant, they can be used to demonstrate a motive. Where the defendant denied committing the crimes, his prior abuse of the victim demonstrated his motive to commit her murder.
After hearing Lampkins’ appeal, the Kentucky Supreme Court decided that the Jefferson County Circuit Court had made no error in his trial and their judgment was affirmed.
Criminal trials can be very complicated, so it is important to hire an attorney with experience. Contact criminal defense attorney Eric Ray for help reviewing your criminal case.
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