Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the circuit court opining on the constitutionality of the Governor's 2021 COVID-19 legislation and enjoining the Governor from interfering with Plaintiffs' business operations, holding that Plaintiff lacked standing to bring this action.In its 2021 regular session, the General Assembly passed three bills amending the Governor's emergency powers under Ky. Rev. Stat. 39A. Plaintiff, a business, sought to enjoin the Governor from any action contrary to the 2021 legislation. The circuit court entered an amended judgment declaring the constitutionality of the 2021 COVID-19 legislation, holding any orders to the contrary imposed by the Governor unconstitutional, and prohibiting the three named defendants from enforcing any emergency order, decree or regulation in conflict with the 2021 legislation. The Supreme Court reversed, holding that Plaintiff plainly had no standing to bring this action, and the circuit court had no jurisdiction. View "Beshear v. Ridgeway Properties, LLC" on Justia Law

The Supreme Court granted a writ of mandamus sought by The Cincinnati Enquirer, a Division of Gannett GP Media, Inc., and directed at two judges of the Kentucky Court of Appeals who presided over separate trials in which the Enquirer was denied leave to intervene, holding that the Court of Appeals erred.These matters concerned constitutional challenges to Casey's Law, Ky. Rev. Stat. 222.430. Because all proceedings in such actions are confidential and not open to the general public the Court of Appeals entered orders in each action directing the record to remain confidential and restricting access to the Court. The Enquirer moved to intervene in each action to obtain access in order to court records. Intervention was denied. The Supreme Court reversed, holding that the Court of Appeals erroneously denied access to the record. View "Cincinnati Enquirer v. Honorable Dixon" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Defendant's motion to suppress evidence of cocaine discovered after a dog sniff of the vehicle in which Defendant was a passenger, holding that the stop was extended, and that extension was not justified by reasonable, articulable suspicion.Defendant was charged with first-degree possession of cocaine. He pled not guilty and filed a motion to dismiss, claiming that he was illegally detained and that the police did not have reasonable, articulable suspicion to call the dog. The trial court determined that it was a valid stop and that the evidence should not be suppressed. The Supreme Court affirmed, holding (1) the traffic stop was extended; (2) the Commonwealth failed to establish simultaneous missions that permitted the seizure; and (3) the Commonwealth did not meet its burden of establishing reasonable, articulable suspicion. View "Commonwealth v. Clayborne" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the trial court's denial of Defendant's motion to suppress evidence found in a drug dog sniff search during a traffic stop of the vehicle in which Defendant was a passenger, holding that the trial court erred by denying the motion to suppress.In reversing the denial of Defendant's motion to suppress, the court of appeals concluded that the investigating officer unconstitutionally extended the duration of the traffic stop to accommodate the dog-sniff search. The Supreme Court affirmed, holding that the Commonwealth failed to establish that the extension of the traffic stop was supported by reasonable, articulable suspicion. View "Commonwealth v. Conner" on Justia Law

The Supreme Court reversed the judgment of the trial court denying Defendant's motion to suppress, holding that the traffic stop in this case was extended, and the extension was not justified by reasonable, articulable suspicion.Defendant was charged with first-degree possession of cocaine. Defendant pled not guilty and filed a motion to suppress the evidence of cocaine, claiming that he was illegally detained and the the police did not have a reasonable, articulable suspicion to call for a K-9 unit to come and search the scene. The trial court denied the motion to suppress, concluding that the initial stop was valid. The Supreme Court reversed, holding that no reasonable articulable suspicion existed to permit the K-9 unit search and that the search unconstitutionally extended the traffic stop, in violation of Defendant's Fourth Amendment rights. View "Commonwealth v. Clayborne" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals upholding the constitutionality of the 2018 amendment to Ky. Rev. Stat. 342.730(4), which terminates workers' compensation income benefits when the recipient reaches the age of seventy or four years from the date of injury or last injurious exposure, holding that the statute is constitutional.Plaintiffs brought separate appeals arguing that the amendment (1) was unconstitutional under the state and federal Equal Protection Clauses because it discriminates based on the income-benefit recipient's age, and (2) was unconstitutional special legislation because it applied only to older income-benefits recipients. The court of appeals upheld the constitutionality of the statute's age classification. The Supreme Court affirmed, holding that the court of appeals correctly rejected the constitutional challenges to the statute. View "Cates v. Kroger" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding the 2018 amendment to Ky. Rev. Stat. 342.730(4), holding that the statutory amendment did not violate the Contracts Clause of the federal and state constitutions.The statutory amendment at issue terminates workers' compensation income benefits when the recipient of the benefits reaches the age of seventy or four years from the date of injury or last injurious exposure, whoever occurs last. Plaintiffs challenged the constitutionality of the amendment. The court of appeals held that the amendment did not violate the Contracts Clause of the state and federal constitutions and that the statute was reasonable. The Supreme Court affirmed, holding that the 2018 amendment did not violate the Contracts Clause of the Federal or Kentucky Constitutions. View "Dowell v. Matthews Contracting" on Justia Law

The Supreme Court reversed the judgment of the circuit court granting a temporary injunction against implementation of House Bill 1, Senate Bill 1, Senate Bill 2, and House Joint Resolution 77, which the General Assembly enacted during the 2021 regular session and which amended the Governor's power to respond to emergencies, as granted in Ky. Rev. Stat. 39A, holding that the circuit court abused its discretion in issuing the injunction.The Governor and the Secretary of the Cabinet for Health and Family Services filed this declaratory action seeking a declaration that the recently-passed legislation unconstitutionally infringed on the Governor's executive powers under the Kentucky Constitution. The circuit court temporarily enjoined implementation of the challenged legislation. Thereafter, the Governor sought modification of the temporary injunction to cover HJR 77, to which the Attorney General objected. The circuit court granted the request and put on hold the implementation of HJR 77 as well. The Supreme Court reversed, holding (1) this case presented a justiciable case or controversy; and (2) the temporary injunction was not warranted. View "Cameron v. Beshear" on Justia Law

The Supreme Court held that the amendments that the legislature made in 2017 to Ky. Rev. Stat. Chapter 109 to give home rule cities located in a county containing a consolidated local government certain rights with respect to the waste management district in the county did not comply with the requirement of Kentucky Constitution Section 156a.At issue on appeal was whether the legislature's amendment to Chapter 109 in HB 246 (the Act) complied with the requirement of Section 156a, which permits the legislature to classify cities on certain bases but requires that all legislation relating to cities with a certain classification shall apply equally to all cities within the same classification. The circuit court concluded that the balance of Act was unconstitutional. The court of appeals affirmed in part and reversed in part. The Supreme Court affirmed in part and reversed in part, holding that Sections 1, 3 and 4 of the Act violated Kentucky Constitution Section 156a. View "Louisville/Jefferson County Metro Government Waste Management District v. Jefferson County League of Cities, Inc." on Justia Law

The Supreme Court affirmed the circuit court's judgment convicting Defendant of complicity to murder and tampering with physical evidence, holding the trial court did not err in admitting unreacted out-of-court statements in which Defendant's co-defendant incriminated herself and Defendant to a cellmate who testified at trial.Specifically, the Supreme Court held (1) the trial court did not err in ruling that the Confrontation Clause was not implicated because the co-defendant's out-of-court statements to her cellmate were not testimonial and sufficient corroboration otherwise supported the admissibility of the statements; (2) the trial court did not err in admitting a jail phone call of Defendant; and (3) the Commonwealth's Attorney improperly questioned a witness, but the error did not render Defendant's trial fundamentally unfair. View "Fisher v. Commonwealth" on Justia Law