RENDERED: AUGUST 30, 2024; 10:00 A.M.

NOT TO BE PUBLISHED

Commonwealth of Kentucky

Court of Appeals

NO. 2022-CA-0975-MR

KEITH BRADLEY APPELLANT 

v. 

APPEAL FROM WARREN CIRCUIT COURT

HONORABLE STEVE ALAN WILSON, JUDGE

ACTION NO. 19-CR-00579

COMMONWEALTH OF KENTUCKY APPELLEE 

AND

NO. 2022-CA-0977-MR

KEITH BRADLEY APPELLANT 

v. 

APPEAL FROM WARREN CIRCUIT COURT

HONORABLE STEVE ALAN WILSON, JUDGE

ACTION NO. 18-CR-00510

COMMONWEALTH OF KENTUCKY APPELLEE 
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OPINION

AFFIRMING

**   **  **

BEFORE: ACREE, KAREM, AND LAMBERT, JUDGES.

ACREE, JUDGE: Appellant, Keith Bradley, appeals the Warren Circuit Court’s 

May 25, 2022 Judgment and Sentence on Plea of Guilty. Bradley alleges (1) he 

was denied both his constitutional and statutory rights to a speedy trial; and (2) the 

circuit court erred in concluding Bradley was not partially exempt from 

prosecution based on Kentucky’s “Good Samaritan Law”, KRS1 218A.133. We 

affirm.

BACKGROUND

On December 18, 2017, Bradley was stopped for speeding in Warren 

County. Bradley had an active warrant and was arrested. During a search incident 

to his arrest, the police discovered on his person suspected methamphetamine and a 

gabapentin pill – a drug for which Bradley did not have a prescription. Suspected 

cocaine and more suspected methamphetamine were discovered in Bradley’s truck. 

Bradley was released on bond. Bradley was indicted for tampering with physical 

evidence, two counts of first-degree possession of a controlled substance, and 

driving under the influence.

1 Kentucky Revised Statutes.
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Two months later, on February 28, 2018, Bradley was with a friend, 

Tessa Reece, when she began to overdose. Bradley asked a neighbor to call 911 

while he stayed with Reece. Paramedics were unable to save Reece. Bradley 

admitted to the police that methamphetamine was in his truck, and he was arrested.

Bradley was indicted on charges of second-degree manslaughter, first-degree 

trafficking in a controlled substance, possession of drug paraphernalia, and firstdegree persistent felony offender.

Bradley’s two cases were consolidated. He pleaded not guilty to all 

charges. Bradley and the Commonwealth began negotiating an Alford2 plea and 

negotiations continued until May 13, 2019. A pretrial conference was set for June 

17, 2019. For unknown reasons, the circuit court continued the trial until July 22, 

2020 and scheduled a pretrial conference for June 22, 2020. On March 20, 2020, 

the parties, by agreement, rescheduled the pretrial conference for July 6, 2020.

Bradley filed a pro se motion to dismiss in June 2020. Apparently, 

Bradley’s appointed counsel declined to file the motion on Bradley’s behalf. 

Bradley argued KRS 218A.133 – commonly called the “Good Samaritan Law” –

exempted him from prosecution for the charges stemming from Reece’s death. 

Bradley wanted to be present at the hearing on the motion, which resulted in 

2 Under North Carolina v. Alford, a defendant is permitted to acknowledge the strength of the 

evidence against him and enter a guilty plea while maintaining his innocence. 400 U.S. 25, 36-37, 

91 S. Ct. 160, 167, 27 L. Ed. 2d 162 (1970).
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another continuance of the pretrial conference and trial. The pretrial conference 

was rescheduled for September 9, 2020, and the trial was continued to December 

15, 2020. The trial did not take place in December 2020, and the Commonwealth 

acknowledges that it “is not clear” why the circuit court did not hold the trial.

Bradley filed a second motion to dismiss in March of 2021, again 

relying on KRS 218A.133. In a letter accompanying the motion, Bradley refiled 

the motion because circuit court staff told him that there was no record of his 

original motion. The circuit court scheduled status conferences for April 26, June 

22, and August 23, 2021.

On August 9, 2021, Bradley filed his speedy trial motion. The circuit 

court considered the motion at the previously scheduled August 23, 2021 status 

conference. The circuit court scheduled another pretrial conference for October 

18, 2021, and set trial for November 3, 2021. The trial was continued to 

November 12. Again, the trial did not take place on that date.

Instead of conducting the trial, the circuit court considered Bradley’s 

motion to dismiss. The circuit court granted the motion as to Bradley’s possession 

charge but denied the motion as to his trafficking charge. Yet again, the circuit 

court scheduled a pretrial conference for March 8, 2022, and scheduled trial for 

July 12, 2022.
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Bradley filed a third motion to dismiss on February 14, 2022, arguing 

the Commonwealth failed to prosecute his case. He argued the case should be 

dismissed because his speedy trial motion was still pending, and the 

Commonwealth had taken no action in response to the motion in more than 180 

days. 

The circuit court considered Bradley’s arguments on his motion to 

dismiss for failure to prosecute at the March 8, 2022 pretrial conference. Bradley 

argued his original case had been pending for three years and nine months, that his 

second case had been pending for two years and nine months, and that his speedy 

trial motion had been pending for seven months. He acknowledged that in-person 

court proceedings had been suspended for a year due to COVID. The circuit court 

denied Bradley’s motion, noting that COVID-related delays and a prosecutor’s 

injury provided just cause for the delay.

Bradley entered his Alford plea on May 23, 2022, pleading guilty to 

first-degree possession of a controlled substance, driving under the influence, firstdegree wanton endangerment, and first-degree trafficking in a controlled 

substance. Bradley received a total sentence of eighteen years of incarceration. 

On his motion to enter guilty plea, Bradley handwrote: “does not waive right to 

appeal pretrial motions.” This is the only reference to preservation of his right to 

appeal on any documents relating to his plea, and the circuit court’s order on 
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Bradley’s guilty plea explicitly states that Bradley understood he waived both his 

right to appeal and his right to a speedy trial. Bradley now appeals.

ANALYSIS

I. Preservation of Right to Appeal

We must first address the Commonwealth’s contention that Bradley 

waived his right to appeal by entering his guilty plea, despite his motion to enter 

guilty plea reflecting Bradley’s intention to the contrary. The Commonwealth 

argues that no order or other document of the circuit court reflects that Bradley 

pleaded guilty on the condition he would be able to appeal the circuit court’s 

rulings on his pretrial motions. Indeed, the circuit court’s order explicitly states 

otherwise. The Commonwealth argues Bradley’s handwritten amendment to his 

motion was insufficient to preserve Bradley’s right to appeal.

This issue arose in Dickerson v. Commonwealth, in which the 

Commonwealth argued a defendant, Dickerson, failed to preserve his right to 

appeal. 278 S.W.3d 145, 148 (Ky. 2009). There, too, “nothing in the final 

judgments of conviction in question actually reflects that Dickerson’s guilty plea 

was conditional.” Id. However, because Dickerson’s motion to enter guilty plea 

contained the word “conditional” handwritten at the top, and because similar 

handwritten notations appeared on the Commonwealth’s plea offer and the 
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arraignment order entered after Dickerson’s guilty plea, the Supreme Court of 

Kentucky determined Dickerson had minimally preserved his right to appeal. Id.

The Supreme Court in Dickerson derived the following rule from 

applicable precedent to determine whether a defendant preserved his right to 

appeal:

Synthesizing our precedent in this area leads to the 

conclusion that we will consider issues on appeal from a 

conditional guilty plea only if those issues: (1) involve a 

claim that the indictment did not charge an offense or the 

sentence imposed by the trial court was manifestly infirm, 

or (2) the issues upon which appellate review are sought 

were expressly set forth in the conditional plea documents 

or in a colloquy with the trial court, or (3) if the issues 

upon which appellate review is sought were brought to the 

trial court’s attention before the entry of the conditional 

guilty plea even if the issues are not specifically reiterated 

in the guilty plea documents or plea colloquy.

Id. at 149.

In our view, Bradley’s handwritten amendment to his motion to enter 

his guilty plea adequately preserved his right to appeal the circuit court’s handling 

of his pretrial motions. By doing so, he expressly set forth the issues he sought to 

appeal as the rule in Dickerson contemplates. Both the Commonwealth and the 

circuit court had notice that Bradley intended his guilty plea to be conditioned 

upon his right to appeal the denial of his pretrial motions. Accordingly, the issues 

raised in Bradley’s appellate brief are properly before us for our review.
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II. Speedy Trial

Bradley first argues the circuit court erred by denying his motion for a 

speedy trial because the circuit court deprived him of both his statutory and 

constitutional rights to a speedy trial. The Sixth Amendment to the United States 

Constitution guarantees criminal defendants “the right to a speedy and public 

trial[.]” UNITED STATES CONST. amend VI. This right applies to the states by 

application of the Due Process Clause of the Fourteenth Amendment to the United 

States Constitution. Barker v. Wingo, 407 U.S. 514, 515, 92 S. Ct. 2182, 2184, 33 

L. Ed. 2d 101 (1972) (citations omitted). The Kentucky Constitution also 

guarantees “a speedy public trial” to criminal defendants. KY. CONST. § 11. In 

furtherance of this right, the General Assembly enacted KRS 500.110:

Whenever a person has entered upon a term of 

imprisonment in a penal or correctional institution of this 

state, and whenever during the continuance of the term of 

imprisonment there is pending in any jurisdiction of this 

state any untried indictment, information or complaint on 

the basis of which a detainer has been lodged against the 

prisoner, he shall be brought to trial within one hundred 

and eighty (180) days after he shall have caused to be 

delivered to the prosecuting officer and the appropriate 

court of the prosecuting officer’s jurisdiction written 

notice of the place of his imprisonment and his request for 

a final disposition to be made of the indictment, 

information or complaint; provided that for good cause 

shown in open court, the prisoner or his counsel being 

present, the court having jurisdiction of the matter may 

grant any necessary or reasonable continuance.
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KRS 500.110. Trial courts, therefore, have “the ability to grant continuances 

extending the disposition of the untried indictment beyond 180 days after the 

statutory right is invoked.” Darcy v. Commonwealth, 441 S.W.3d 77, 83 (Ky. 

2014). Further, because the statute empowers trial courts to grant “any necessary 

or reasonable continuance,” the General Assembly clearly intended trial courts to 

have broad power in granting such continuances. KRS 500.110 (emphasis added); 

see Darcy, 441 S.W.3d at 84.

As KRS 500.110 states, unless good cause existed for the circuit court 

to grant a reasonable or necessary continuance, the circuit court was required to 

bring Bradley to trial within 180 days of his invocation of the statute. Bradley 

invoked the statute in his August 9, 2021 motion for speedy trial. The circuit court 

never held a trial; after Bradley filed his motion, the circuit court continued the 

trial from November 3, 2021, to November 12, 2021, and, again, to July 12, 2022. 

The circuit court set Bradley’s ultimate trial date for nearly a year after he filed his 

motion.

However, the circuit court had good cause for this delay. Apparently, 

the Commonwealth’s Attorney suffered a serious injury, which both Bradley and 

the Commonwealth describe in their briefs as “life-threatening.” This is analogous 

to a delay in Barker v. Wingo, wherein the Supreme Court of the United States 

described the illness of the sheriff in charge of the investigation as a “strong 
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excuse” for a seven-month period of delay. Barker, 407 U.S. at 533-34, 92 S. Ct. 

at 2194. While the circuit court subjected Bradley to multiple continuances of his 

trial date prior to his motion, KRS 500.110 only contemplates continuances made 

after the statute’s invocation which cause a defendant to wait for trial for more than 

180 days. We therefore cannot say the circuit court deprived Bradley of his 

statutory right to a speedy trial.

As for Bradley’s constitutional right to a speedy trial, “[w]e analyze a 

defendant’s constitutional rights to a speedy trial, under both the Federal and 

Kentucky constitutional provisions, by applying the four-factor Barker test.” 

Dunaway v. Commonwealth, 60 S.W.3d 563, 569 (Ky. 2001) (citing Barker, 407 

U.S. 514, 92 S. Ct. 2182). These factors are: “(1) length of the delay; (2) reason 

for the delay; (3) the defendant’s assertion of his right to a speedy trial; and (4) 

prejudice to the defendant.” Tamme v. Commonwealth, 973 S.W.2d 13, 22 (Ky. 

1998) (citing Barker, 407 U.S. 514, 92 S. Ct. 2182). “We regard none of the four 

factors . . . as either a necessary or sufficient condition to the finding of a 

deprivation of the right of speedy trial.” Barker, 407 U.S. at 533, 92 S. Ct. at 2193. 

“Rather, they are related factors and must be considered together with such other 

circumstances as may be relevant.” Id.

First, for a defendant to be deprived of his speedy trial right, he must 

have experienced a delay of such a length that the delay was “presumptively 
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prejudicial.” Dunaway, 60 S.W.3d at 569 (citing Barker, 407 U.S. at 530, 92 S. Ct. 

at 2192). Presumptively prejudicial delay is found by balancing the complexity of 

the charges against the delay; “the delay that can be tolerated for an ordinary street 

crime is considerably less than for a serious, complex conspiracy charge.” Id. 

(quoting Barker, 407 U.S. at 531, 92 S. Ct. at 2192).

In Dunaway, Dunaway was charged with three counts of first-degree 

robbery and one count of being a persistent felony offender. Id. The Kentucky 

Supreme Court considered these charges to be “serious and of moderate 

complexity.” Id. When the Kentucky Supreme Court weighed the seriousness and 

complexity of the charges against Dunaway’s thirteen and one-half month delay, it 

determined the delay was presumptively prejudicial. Id. In Goben v. 

Commonwealth, a defendant’s multiple drug possession, drug trafficking, drug 

manufacture, and felon in possession of a firearm charges, when weighed against a 

five-year delay, “easily qualifie[d] as presumptively prejudicial[.]” 503 S.W.3d 

890, 898, 905 (Ky. 2016).

Both of Bradley’s underlying cases experienced long delays: fiftythree months and seventeen days for the 2018 arrest, and fifty months and twentyseven days for the 2019 arrest. A delay of over four years is plainly presumptively 

prejudicial. As such, we must “inquire further as to who was responsible for the 

delay – [Bradley], the Commonwealth or, as is often the case, both.” Id. at 905.
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When examining the reasons offered for delay under the second 

Barker factor, “different weights should be assigned to different reasons.” Barker, 

407 U.S. at 531, 92 S. Ct. at 2192. The government’s deliberate efforts to impede 

the defense are “weighed heavily” against the prosecution. Id. Neutral reasons for 

delay can also exist, which include negligence or an overburdened court; though 

these reasons are neutral and less weight is applied to them, “the ultimate 

responsibility for such circumstances must rest with the government rather than 

with the defendant.” Id. “[A] valid reason, such as a missing witness, should serve 

to justify appropriate delay.” Id. In short, this examination requires us to 

determine “whether the government or the criminal defendant is more to blame for 

[the] delay[.]” Doggett v. United States, 505 U.S. 647, 651, 112 S. Ct. 2686, 2690, 

120 L. Ed. 2d 520 (1992) (citing Barker, 407 U.S. at 530, 92 S. Ct. at 2192).

In the analogous Henderson v. Commonwealth, though a fifty-sixmonth delay was “clearly presumptively prejudicial,” the Kentucky Supreme Court 

determined Henderson’s own actions – including multiple pro se motions and his 

insistence on a new attorney – constituted most of the delay in bringing his case to 

trial. 563 S.W.3d 651, 664 (Ky. 2018). On balance, Henderson’s speedy trial right 

was not violated, despite the trial court’s failure to rule on pending suppression 

motions. Id.
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In Bradley’s case, much of the delay he experienced was a result of 

his own pretrial motions. As the Commonwealth notes, Bradley filed multiple 

motions on his own behalf between 2018 and 2022. The circuit court granted 

continuances after each, apparently to allow it to evaluate Bradley’s motions prior 

to trial. The other sources of delay included scheduling complications with the 

circuit court due to COVID, which is a neutral reason for delay and weighs slightly 

against the government. Additionally, the Commonwealth Attorney’s serious 

injury, which we already determined to be good cause for delay, also weighs 

slightly against the government. However, as in Henderson, we believe the bulk of 

the delay in this case resulted from Bradley’s multiple pretrial motions.

It is clear Bradley asserted his right to a speedy trial – the third Barker 

factor. He did so first on August 9, 2021, when he filed his motion for speedy trial. 

Bradley again asserted this right as a component of his February 14, 2022 motion 

to dismiss. Those asserting their right to a speedy trial must do so “vigorously.” 

Stacy v. Commonwealth, 396 S.W.3d 787, 798 (Ky. 2013). Bradley asserted his 

right to a speedy trial and continued to do so until entering his plea. However, 

Bradley apparently never objected to the circuit court’s repeated continuances, and 

one continuance was granted to accommodate his desire to be present at a pretrial 

conference. Though we believe Bradley sincerely and somewhat vigorously 

asserted his right to a speedy trial, a defendant’s assertion of this right must be 
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viewed in the context of his other conduct. Dunaway, 60 S.W.3d at 571 (citations 

omitted). While we find Bradley’s assertion weighs in his favor, it does not weigh 

heavily.

As Barker notes, the fourth factor, prejudice, “should be assessed in 

the light of the interests of defendants which the speedy trial right was designed to 

protect.” 407 U.S. at 532, 92 S. Ct. at 2193. Barker identifies three of these 

interests: “(i) to prevent oppressive pretrial incarceration; (ii) to minimize anxiety 

and concern of the accused; and (iii) to limit the possibility that the defense will be 

impaired.” Id. (citations omitted). “Of these, the most serious is the last, because 

the inability of a defendant adequately to prepare his case skews the fairness of the 

entire system.” Id.

As the Commonwealth notes and as the trial court found, Bradley was 

incarcerated for reasons unrelated to the charges in the instant case. On the night 

Reece died, Bradley was arrested for a parole violation. His parole was revoked,

and he returned to state custody. Accordingly, Bradley’s incarceration does not 

constitute oppressive pretrial incarceration. As to the second interest, though 

Bradley’s brief says the pendency of his cases caused him anxiety, Bradley 

acknowledged before the circuit court he suffered from anxiety and depression 

prior to these underlying charges. Additionally, “speculative and generic claims 

are insufficient to support a claim of prejudice.” Dickerson, 278 S.W.3d at 152. 
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Bradley’s brief does not demonstrate his anxiety or concern with sufficient 

particularity. Nor can we say Bradley’s defense was impaired by the circuit 

court’s delay. He has not shown that his delay led to spoliation of evidence, 

caused witnesses to become unavailable, or otherwise hindered him in defending 

against his charges. 

On balance, the four Barker factors weigh against concluding Bradley 

was deprived of his speedy trial right. Though the lengthy delay was 

presumptively prejudicial, a sizable portion of the delay resulted from Bradley’s 

own motions. Though the Commonwealth’s Attorney’s injury and difficulties with 

COVID weigh in favor of Bradley, these are outweighed by Bradley’s pretrial 

motions and their resultant continuances. Further, though Bradley did 

continuously assert his speedy trial right beginning in August of 2021, Bradley 

never objected to the circuit court’s continuances made prior to the speedy trial 

motion. And, upon examination of the circumstances of this case, Bradley has not 

demonstrated prejudice of such a degree that it would outweigh the other Barker 

considerations. For these reasons, we hold Bradley was not deprived of his right to 

a speedy trial.

III. Good Samaritan Statute

Bradley argues the circuit court erred in denying his motion pursuant 

to the Good Samaritan statute, KRS 218A.133. He argues this statute exempts him 
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from prosecution for the drug trafficking charge he received following the death of 

Tessa Reece.

As relevant to this appeal, KRS 218A.133 provides:

(2) A person shall not be charged with or prosecuted for a 

criminal offense prohibiting the possession of a controlled 

substance or the possession of drug paraphernalia . . . if:

(a) In good faith, medical assistance with a drug 

overdose is sought from a public safety answering 

point, emergency medical services, a law 

enforcement officer, or a health practitioner because 

the person:

1. Requests emergency medical assistance 

for himself or herself or another person;

2. Acts in concert with another person who 

requests emergency medical assistance; or

3. Appears to be in need of emergency 

medical assistance and is the individual for 

whom the request was made;

(b) The person remains with, or is, the individual 

who appears to be experiencing a drug overdose 

until the requested assistance is provided; and

(c) The evidence for the charge or prosecution is 

obtained as a result of the drug overdose and the 

need for medical assistance.

KRS 218A.133(2). The statute defines “drug overdose” to include “death which 

reasonably appears to be the result of consumption or use of a controlled 

substance,” and defines “good faith” to exclude “seeking medical assistance during 
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the course of the execution of an arrest warrant, or search warrant, or a lawful 

search.” KRS 218A.133(1)(a)-(b). Important to this case, the statute also 

provides: “The provisions of subsection (2) of this section shall not extend to the 

investigation and prosecution of any other crimes committed by a person who 

otherwise qualifies under this section.” KRS 218A.133(3).

We decline Bradley’s invitation to interpret this statute to exempt his 

drug trafficking charge from prosecution. The Court is instructed that “[a]ll 

statutes of this state shall be liberally construed with a view to promote their 

objects and carry out the intent of the legislature[.]” KRS 446.080(1). However, 

“where the language of a statute is clear and unambiguous on its face, we are not 

free to construe it otherwise even though such construction might be more in 

keeping with the statute’s apparent purpose.” MPM Fin. Grp., Inc. v. Morton, 289 

S.W.3d 193, 197 (Ky. 2009) (citing Whittaker v. McClure, 891 S.W.2d 80, 83 (Ky. 

1995)). Simply put, KRS 218A.133 clearly contemplates the offenses of 

possession of drugs and drug paraphernalia and does not contemplate other 

offenses where such possession is incidental to the offense. This is particularly so 

in light of 218A.133(3) explicitly prohibiting the statute’s application to crimes 

other than drug or drug paraphernalia possession.

We confronted similar circumstances in Commonwealth v. Kenley, 

where Kenley, an inmate, was indicted on charges of first-degree promoting 
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contraband after fentanyl was discovered on her person while Kenley was 

overdosing. 516 S.W.3d 362, 363 (Ky. App. 2017). Kenley obtained a dismissal 

of this charge based on application of KRS 218A.133, and the Commonwealth 

appealed. Id. at 364. We reversed because KRS Chapter 218A unambiguously did 

not include first-degree promoting contraband within its scope. Id. at 365. We 

noted the statute prohibiting promotion of contraband – KRS 520.050 – prohibits, 

among other actions, possession of dangerous contraband and, though contraband 

could include drugs, KRS 520.050 does not directly criminalize possession of 

drugs. Id. at 365.

Additionally, we determined KRS 520.050 “is not a statute aimed at 

criminalizing mere possession of drugs.” Id. Rather, “the First-Degree Promoting 

Contraband statute on its face evidences an intent by the General Assembly to 

combat the harm created by any dangerous contraband” including drug markets 

inside prisons and violence and intimidation resulting therefrom. Id. Nor were we 

convinced application of KRS 218A.133 to KRS 520.050 fulfilled the public 

policy objectives of combating the heroin epidemic and rehabilitating drug users; 

to the contrary, Kenley’s drug possession “endangered those who worked and 

resided at the detention facility” and “perpetuated an ongoing and serious problem” 

inside our detention facilities. Id. at 366.
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We do not believe Bradley’s case is a closer call than Kenley. The 

plain language of KRS 218A.1412 – Kentucky’s statute prohibiting trafficking in 

controlled substances in the first degree – does not directly include possession of 

drugs as an element of the offense. See KRS 218A.1412. Rather, “[a] person is 

guilty of trafficking in a controlled substance in the first degree when he or she 

knowingly and unlawfully traffics in” a series of specified quantities of certain 

drugs. KRS 218A.1412(1). The words “possess,” “possession,” or any variant 

thereof do not appear in the statute, nor do any synonymous terms. 

However, trafficking is defined as relevant elsewhere in Chapter 218A 

as follows: “to manufacture, distribute, dispense, sell, transfer, or possess with 

intent to manufacture, distribute, dispense, or sell a controlled substance[.]” KRS 

218A.010(56). This is directly analogous to our discussion of KRS 520.050 in 

Kenley – though trafficking under KRS 218A.1412 could include possession of 

controlled substances, the statute does not directly criminalize drug possession. 

Nor can we say exemption of drug trafficking would serve the public policy 

purpose of combating the heroin epidemic. As should be abundantly clear, drug 

trafficking activity directly exacerbates Kentucky’s struggle with drug abuse. For 

these reasons, KRS 218A.1412 falls under the category of crimes for which an 

individual could still be indicted per KRS 218A.133(3) and, therefore, the 
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circumstances of Bradley’s drug trafficking charge do not exempt him from 

prosecution.

CONCLUSION

Based on the foregoing, we affirm the Warren Circuit Court’s May 

25, 2022 Judgment and Sentence on Plea of Guilty.

ALL CONCUR.

BRIEF FOR APPELLANT:

Adam Meyer

Frankfort, Kentucky

BRIEF FOR APPELLEE:

Daniel Cameron

Attorney General of Kentucky

Harrison Gray Kilgore

Assistant Attorney General

Frankfort, Kentucky