Steven Lawson 12-28-23

Filed 23-CR-00239 12/28/2023 Diane Thompson, Nelson Circuit Clerk
COMMONWEALTH OF KENTUCKY
NELSON CIRCUIT COURT
JUDGE CHARLES C. SIMMS III
CASE NO. 23-CR-0239
COMMONWEALTH OF KENTUCKY PLAINTIFF
v. NOTICE—MOTION—ORDER
Electronically Filed
JOSEPH L. LAWSON DEFENDANT

** ** ** ** **
NOTICE
TO: Shane Young, Esq., or his agent
COMMONWEALTH’S ATTORNEY
Please take notice that the following motion has been filed on this date, the
28th day of December 2023, to be heard at the pretrial conference on January 5,
2024, at 1:30 PM, in the above Court.
DEFENDANT’S MOTION FOR REASONABLE BAIL

AND HOME INCARCERATION
Comes the Defendant, Joseph Lawson, by counsel, Kevin Coleman and
Robert Boyd, pursuant to the 5th, 8th, and 14th Amendments of the United States
Constitution, §§ 2, 3, 16 and 17 of the Kentucky Constitution, KRS Chapter 431, RCr
4.10-4.40 and respectfully moves this Court to set reasonable bail conditions and
detain the Defendant on home incarceration. In support thereof, the Defendant

RB : 000001 of 000004
states as follows:
1. In indictment 23-CR-0183, Mr. Lawson is charged with Tampering with
Physical Evidence and his bail is set as a $50,000 unsecured bond with the condition
Page 1 of 4
of continued cooperation with the Commonwealth. In indictment 23-CR-0239, Mr.
Lawson is charged with Criminal Conspiracy to Commit Murder and his bail is set
as a $500,000 full-cash bond.
2. This Court deemed Mr. Lawson indigent in accordance with KRS Chapter
31 and he is unable to afford $500,000 to post for his freedom.
3. Pursuant to RCr 4.38 and RCr 4.40, a criminal defendant who is unable
to make bond may petition the Court for review.
4. The purpose of bail is to assure the defendant’s appearance in court,
protect the community from danger and to protect the accused against punishment
prior to conviction.
5. Mr. Lawson’s bail as presently set is excessive, oppressive, and amounts
to a denial of bail considering his socio-economic status, his presumption of
innocence, and his anticipated conduct if released. Accordingly, the current bail is
not the least onerous condition(s) reasonably likely to insure his appearance in this
Court. U.S. Const. Amend. VIII; Ky. Const. § 17; KRS 431.525; and RCr 4.12.
6. Mr. Lawson’s anticipated conduct if released would be to remain law
abiding, appear before this Court, and comply with any additional conditions this
Court deems necessary, including GPS monitoring via home incarceration.
Additionally, Mr. Lawson will re-establish his health insurance, social security
RB : 000002 of 000004
disability, and seek out ongoing medical treatment.
7. Mr. Lawson is not a danger to the community or himself. He is
paraplegic--unable to voluntarily move the lower parts of his body. His movement
Page 2 of 4
is constrained to a wheelchair. Simply put, his paraplegia prevents him from even
having the ability to harm another. Additionally, if placed on home incarceration,
Mr. Lawson’s movements would be monitored 24/7.
8. Mr. Lawson is not a flight risk and will appear in this Court as required.
His paraplegia restricts his independent mobility, which makes him less capable of
fleeing. That said, he has no intention of avoiding the jurisdiction of this Court and
looks forward to mounting his defense against these allegations. Additionally, if
placed on home incarceration, Mr. Lawson’s movements would be monitored 24/7.
His whereabouts would always be known.
9. Mr. Lawson requests that the monetary conditions of his bail on 23-CR-
0239 be reduced to a $50,000 unsecured bond, concurrent with 23-CR-0183. KRS
431.066(3). Alternatively, he requests a meaningful reduction in his monetary bond
that considers his socio-economic position, with bail credit assessment pursuant to
KRS 431.066(5)(a) and KRS 431.520(3)(b). Lastly, as discussed above, Mr. Lawson
seeks modification of his non-financial condition(s) of his bail so that he is placed
on home incarceration with GPS monitoring, medical releases, and attorney-office
visit releases.
WHEREFORE, the Defendant moves this Court to enter the attached order
modifying his bail.

RB : 000003 of 000004
Page 3 of 4
CERTIFICATE
This is to certify that a copy of the foregoing notice was delivered via KCOJ
electronic service to Shane Young, Esq. ([email protected]),
Commonwealth’s Attorney, or his agent, on today’s date, December 28, 2023.
_____________________________ ______________________________
Robert E. Boyd, Esq. Kevin J. Coleman, Esq.
6708 Shepherdsville Rd., Ste. 3 401 W. Main St., Ste. 1710
Louisville, KY 40228 Louisville, KY 40202
(502) 785-4457 (502) 442-2072
[email protected] [email protected]
RB : 000004 of 000004
Page 4 of 4
Tendered 23-CR-00239 12/28/2023 Diane Thompson, Nelson Circuit Clerk
COMMONWEALTH OF KENTUCKY
NELSON CIRCUIT COURT
JUDGE CHARLES C. SIMMS III
CASE NO. 23-CR-0239
COMMONWEALTH OF KENTUCKY PLAINTIFF
v. ORDER SETTING CONDITIONS OF BAIL
JOSEPH L. LAWSON DEFENDANT

** ** ** ** **
Motion having been made and the Court being sufficiently advised;
IT IS HEREBY ORDERED the Defendant’s bail shall be modified on the
following conditions:
(1) Non-financial conditions of bail:
a. The Defendant shall be placed on home incarceration with 24/7
GPS monitoring. He is to be confined at the location of home
incarceration, with the following exceptions: (1) medical
releases, (2) attorney-office visit releases and (3) court
appearances.
b. The Defendant shall remain law abiding, appear before this
court when instructed, and have no contact with the alleged
victim’s family.
(2) Financial conditions of bail: $50,000 unsecured, concurrent with the
monetary bond set in Nelson County indictment 23-CR-0183.
________________________________________
HON. CHARLES C. SIMMS III
NELSON CIRCUIT COURT JUDGE
Distribution
TD : 000001 of 000001
Shane Young, Esq., Commonwealth Attorney

Kevin Coleman, Esq., Counsel for Defendant
Robert Boyd, Esq., Counsel for Defendant
Nelson County Jail
KY-Department of Corrections (KDOC)
Page 1 of 1
Tendered 23-CR-00239 12/28/2023 Diane Thompson, Nelson Circuit Clerk

Steven Lawson 12-28-23

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Steven Lawson 12-28-23

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Filed 23-CR-00239 12/28/2023 Diane Thompson, Nelson Circuit Clerk

COMMONWEALTH OF KENTUCKY PLAINTIFF

JOSEPH L. LAWSON DEFENDANT

28th day of December 2023, to be heard at the pretrial conference on January 5,

2024, at 1:30 PM, in the above Court.

DEFENDANT’S MOTION FOR REASONABLE BAIL

Comes the Defendant, Joseph Lawson, by counsel, Kevin Coleman and

Constitution, §§ 2, 3, 16 and 17 of the Kentucky Constitution, KRS Chapter 431, RCr

detain the Defendant on home incarceration. In support thereof, the Defendant

1. In indictment 23-CR-0183, Mr. Lawson is charged with Tampering with

of continued cooperation with the Commonwealth. In indictment 23-CR-0239, Mr.

as a $500,000 full-cash bond.

31 and he is unable to afford $500,000 to post for his freedom.

to make bond may petition the Court for review.

4. The purpose of bail is to assure the defendant’s appearance in court,

5. Mr. Lawson’s bail as presently set is excessive, oppressive, and amounts

to a denial of bail considering his socio-economic status, his presumption of

6. Mr. Lawson’s anticipated conduct if released would be to remain law

Court deems necessary, including GPS monitoring via home incarceration.

disability, and seek out ongoing medical treatment.

7. Mr. Lawson is not a danger to the community or himself. He is

having the ability to harm another. Additionally, if placed on home incarceration,

Mr. Lawson’s movements would be monitored 24/7.

looks forward to mounting his defense against these allegations. Additionally, if

placed on home incarceration, Mr. Lawson’s movements would be monitored 24/7.

His whereabouts would always be known.

0239 be reduced to a $50,000 unsecured bond, concurrent with 23-CR-0183. KRS

431.066(3). Alternatively, he requests a meaningful reduction in his monetary bond

seeks modification of his non-financial condition(s) of his bail so that he is placed

on home incarceration with GPS monitoring, medical releases, and attorney-office

modifying his bail.

electronic service to Shane Young, Esq. ([email protected]),

Commonwealth’s Attorney, or his agent, on today’s date, December 28, 2023.

COMMONWEALTH OF KENTUCKY PLAINTIFF

v. ORDER SETTING CONDITIONS OF BAIL

JOSEPH L. LAWSON DEFENDANT

Shane Young, Esq., Commonwealth Attorney

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