Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the determination of the circuit court that the security agreement between Harvey Haynes, the debtor, covered future advances made by Farmers Tobacco Warehouse (Farmers) so as to have priority over the security interest claimed by Versailles Farm Home and Garden, LLC (Versailles) in Haynes' 2013 tobacco crop, holding that there was no error.In 2014, Versailles brought this action against Haynes to collect on the balance due under the agreement. Versailles joined Farmers as a party to assert its claim against Farmers for conversion to the extent Farmers retained any proceeds in excess of the amount Haynes owed. Farmers admitted selling a portion of Haynes' 2013 tobacco crop and retaining the proceeds but denied doing so in violation of Versailles' security interest. The trial court granted Versailles' motion for summary judgment against Haynes and then granted Farmers' motion for summary judgment as to its cross-claim against Haynes asserting a first and superior lien in Haynes' 2013 tobacco crop. The Supreme Court affirmed, holding that the trial court did not err. View "Versailles Farm Home & Garden, LLC v. Haynes" on Justia Law

The Supreme Court affirmed the decision of the court of appeals that a real property contract entered into by Henry Gray and William, Mary and Frank Stewart in this case was unenforceable under the statute of frauds but held that this decision did not apply equally to William, Mary and Frank.Henry entered into a real estate contract with Frank, his brother William, and William's wife, Mary. Later, Henry filed a complaint against Frank, William and Mary alleging breach of contract and requesting specific performance and damages. The trial court entered judgment in favor of Henry and awarded $19,286 in damages. The court of appeals reversed in part. The Supreme Court affirmed, holding (1) the contract at issue did not satisfy the statute of frauds; (2) the trial court's findings of fact may not serve as a basis to reverse the court of appeals' decision as to William and Mary; and (3) the court of appeals did not err when it reversed the trial court's damage award. View "Gray v. Stewart" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing order of the circuit court denying the motion of Legacy Health Services, Inc. Cambridge Place Group, LLC, and Cambridge Place Properties, LLC (collectively, Defendants) to dismiss or stay this lawsuit and compel arbitration of the medical malpractice claims brought by Christopher Jackson, as guardian for Christine Jackson, his mother, holding the court of appeals erred.At issue was whether Christopher possessed the authority, as his mother's guardian, to enter a voluntary arbitration agreement that was not a prerequisite to the provision of care or services to his ward. The circuit court concluded that Christopher did not have that authority. The court of appeals reversed, holding that a guardian's authority to enter into contracts generally is within the ambit of what is reasonably inferable from the relevant statutes. The Supreme Court reversed, holding (1) guardians have the authority to bind their wards to contracts that limit or deprive the civil rights of their wards only to the extent necessary to provide needed care and services to the ward; and (2) because the arbitration agreement was not necessary to provide care or services to Christine, Christopher lacked the authority to enter into the arbitration agreement. View "Jackson v. Legacy Health Services, Inc." on Justia Law

The Supreme Court affirmed the decision of the court of appealsaffirming the judgment of the trial court denying a motion to compel arbitration in this insurance dispute, holding that the trial court did not err in denying the motion to compel.Grace McGaughey, the trustee of a trust, entered into a contract with Money Concepts Capital Corporation and Legacy Consulting Group, LLC to purchase a variable annuity with Jackson National Life Insurance Company. The contract contained an arbitration agreement. Following McGaughey's death, the executrix of her estate sued Money Concepts, Legacy Conultants, and Jackson, alleging several common law and statutory claims. Money Concepts and Legacy Consulting moved to compel arbitration, which the trial court denied. The court of appeals affirmed. The Supreme Court affirmed, holding that McGaughey's investment was insurance, and therefore, the arbitration provision was unenforceable under Ky. Rev. Stat. 417.050(2). View "Legacy Consulting Group, LLC" on Justia Law

The Supreme Court affirmed the order of the court of appeals granting Defendant's petition for a writ of prohibition of the first class, thereby vacating the circuit court's denial of Defendant's motion to dismiss Plaintiffs' claim for breach of contract, holding that the court of appeals did not err.Plaintiffs were Kentucky landowners who leased their land to Defendant, an oil and gas producer. Plaintiffs filed a breach of contract class action suit alleging that Defendant impermissibly deducted severance taxes as a post-production cost before paying them royalties. Defendant filed a motion to dismiss on grounds that the circuit court lacked subject matter jurisdiction because Plaintiffs did not meet the required amount in controversy. The circuit court denied the motion. Defendant then sought a writ of prohibition. The court of appeals granted the writ. The Supreme Court affirmed, holding that Plaintiffs did not meet the required amount in controversy, and therefore, the circuit court lacked subject matter jurisdiction. View "Imhoff v. Honorable House" on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating an arbitration award and affirmed the circuit court's denial of the motion to vacate the arbitrator's award, holding that the court of appeals exceeded the statutory basis for vacating the award.After she purchased a home, Plaintiff initiated an arbitration proceeding against Defendants, the seller of the home as well as two real estate agents, seeking to recover damages or to rescind the purchase contract. The arbitrator concluded that Plaintiff could not, as a matter of law, prevail on her breach of contract and rescission claims. Plaintiff filed a petition seeking to vacate the arbitration decision pursuant to the provisions of Ky. Rev. Stat. 417.160. The circuit court denied the petition. The court of appeals reversed and remanded for a new arbitration. The Supreme Court reversed, holding that the arbitrator did not exceed his powers. View "Booth v. K&D Builders, Inc." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the circuit court's denial of summary judgment in favor of the University of Louisville in this breach of contract action, holding that Plaintiff brought her action outside of the one-year period following the date of completion of her last written contract.After Plaintiff's employment at the University ended she brought this action alleging that the University breached its employment contract with her. The University moved for summary judgment, asserting that governmental immunity shielded it from liability. The circuit court denied the motion for summary judgment. The court of appeals reversed, holding that the University was shielded from liability due to governmental immunity. The Supreme Court affirmed but on different grounds, holding that Plaintiff's claim was filed outside of the limitations period of Ky. Rev. Stat. 45A.260. View "Britt v. University of Louisville" on Justia Law

In this action brought against a long-term care facility by Kenneth, as administrator of Estate of Tommy Patton, the Supreme Court reversed in part the court of appeals' decision concluding that an arbitration agreement was enforceable as to Kenneth's individual wrongful death claim but that the agreement was not enforceable as to the Estate's claims, holding that the agreement was valid as to both claims.Kenneth signed an arbitration agreement at the time his father, Tommy, was admitted to Signature HealthCARE of East Louisville's long-term care facility. Tommy later suffered a fall and died a few weeks later. Kenneth brought sued Signature, alleging negligence and wrongful death. Signature filed a motion to compel arbitration. The trial court denied the motion in its entirety. The court of appeals reversed in part, concluding that the arbitration agreement was not enforceable against the Estate but that Kenneth's wrongful death claim was arbitrable because he executed the arbitration agreement in his individual capacity. The Supreme Court reversed in part, holding that both the Estate's and Kenneth's individual claims were subject to arbitration because the arbitration agreement was valid and enforceable as to the Estate claim and as to Kenneth's individual wrongful death claim. View "LP Louisville East, LLC v. Patton" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the decision of the trial court granting partial summary judgment in favor of Paul Mostert and partially dismissing The Mostert Group, LLC's (TMG) breach of contract claims, holding that partial summary judgment in favor of Mostert was improper.Mostert agreed to transfer certain computer technology to TMG in exchange for TMG stock, cash, and a promissory note payable in installments. When Mostert refused to deliver to TMG the source code, which was essential to maintaining and updating the software technology, TMG refused to make the final promissory note payment to Mostert. TMG filed two lawsuits against Mostert. The circuit court granted Mostert's motion for partial summary judgment on the grounds that TMG's allegations against Mostert arose after the note was executed and the trial court previously established that Mostert had a security interest in and therefore a right to possess the collateral. The court of appeals reversed, holding that Mostert possessed a security interest in the software but not the source code. The Supreme Court affirmed, holding that Mostert breached the parties' contract, which excused TMG's obligation to further perform under the contribution agreement. View "Mostert v. Mostert Group, LLC" on Justia Law

In this declaratory judgment action the Supreme Court reversed the judgment of the circuit court in favor of the Office of the Attorney General (OAG) on its action seeking to vindicate its right to contract with outside counsel on a contingency-fee basis, holding that the OAG is subject to the contracting-oversight requirements of the Model Procurement Code and that the Government Contract Review Committeee (Committee) of the Legislative Research Commission did not arbitrarily disapprove of the contingency-fee contract at issue in this case.The OAG contracted on a contingency-fee basis with a team of law firms to conduct investigation into and commence litigation on potential statutory violations arising out of the manufacture and distribution of prescription opioid products within the Commonwealth. The Committee recommended that William Landrum, the Secretary of the Finance and Administration Cabinet, disapprove and cancel the contract. Landrum did as the Committee recommended. The OAG then brought this declaratory judgment action. The circuit court granted the OAG all the relief it sought. The Supreme Court reversed, holding that the Committee and Landrum did not act inappropriately in disapproving and canceling the contract. View "Landrum v. Commonwealth ex rel. Beshear" on Justia Law