Justia Kentucky Supreme Court Opinion Summaries

Two business partners were traveling on Interstate 65 in Kentucky when their rental car hydroplaned during a heavy rainstorm, resulting in a crash that killed one partner and seriously injured the other. The decedent’s widow, on behalf of herself, her children, and her husband’s estate, along with the surviving partner, brought suit against the engineering firms responsible for the design of a highway-widening project completed years earlier. The plaintiffs alleged that the engineers negligently designed the widened highway, causing increased water pooling and a greater risk of hydroplaning in the area where the accident occurred.The Fayette Circuit Court granted summary judgment for the engineers, holding that they were immune from suit as contractors for a governmental entity and that the claims were preempted by federal law because the design complied with required state and federal standards. The Court of Appeals reversed, concluding that contractors do not automatically share the immunity of the state, that government approval of the design did not insulate the engineers from potential liability for negligent design, and that the state negligence and wrongful death claims were not preempted by federal law.The Supreme Court of Kentucky affirmed the Court of Appeals. It held that private engineering firms hired by a state agency are not entitled to the Commonwealth’s sovereign or derivative immunity simply by virtue of their contract. The court also found that summary judgment was inappropriate on the ground of the engineers’ work being “mandated” by the government because there were genuine issues of material fact regarding whether the design was required or whether the engineers exercised independent judgment. Finally, the court held that Kentucky’s negligence and wrongful death claims were not preempted by federal law, as the state claims did not impose standards more stringent than those required by federal regulations. View "HMB PROFESSIONAL ENGINEERS, INC. V. IVES" on Justia Law

A nonprofit organization requested that a state commission produce all emails and text messages sent between certain commission members, agency officials, and two legislators from June 2020 onward, including those sent or received on private devices or accounts. The commission responded by producing hundreds of documents from its own records but did not produce communications held exclusively on the private cell phones or private email accounts of individual commission members, stating that these were not public records under the Open Records Act (ORA). The nonprofit organization then brought suit, alleging a willful violation of the ORA for the commission’s failure to provide these additional communications, arguing that commission members used their private accounts to conduct all commission business and that such communications should be disclosed.The Franklin Circuit Court granted summary judgment in part to both sides. The court determined that emails sent or received by commission members on their private email addresses concerning commission business were public records and ordered their disclosure, but found that text messages on private devices, while public records, were exempt from disclosure due to the impracticality and privacy concerns of retrieval. The court also found that the commission had not willfully violated the ORA. Both the commission and the nonprofit appealed, and the Kentucky Court of Appeals largely rejected the commission’s position, holding that both emails and texts on private devices were subject to disclosure and that the agency’s asserted burdens and privacy interests required more fact-specific analysis.The Supreme Court of Kentucky held that private records in the exclusive ownership and control of individual commission members and former members, kept on their personal devices or accounts, are not “public records” held by a “public agency” for purposes of the ORA and are not subject to disclosure. The court affirmed in part, reversed in part, and remanded with instructions to dismiss the action and grant summary judgment to the commission. View "KENTUCKY DEPARTMENT OF FISH AND WILDLIFE RESOURCES COMMISSION V. KENTUCKY OPEN GOVERNMENT COALITION, INC." on Justia Law

A sitting circuit court judge was the subject of an impeachment petition submitted to the Kentucky House of Representatives by a former legislator who was not a party to any of the cases he cited. The petition alleged that the judge abused her discretion in six cases; five of these cases were still pending in the judicial system at the time. The petition did not include an affidavit, as required by Kentucky statute. The House referred the matter to its Impeachment Committee, which held a hearing and ultimately issued articles of impeachment against the judge. The Kentucky Senate scheduled a trial on these articles.The judge sought a temporary injunction in Franklin Circuit Court to stop the impeachment proceedings. The Franklin Circuit Court denied the injunction. She then sought emergency relief and review from the Kentucky Court of Appeals, which also denied relief. The judge subsequently filed emergency motions and a petition for a supervisory writ with the Supreme Court of Kentucky, seeking a declaration that the impeachment articles and proceedings violated the separation of powers and her due process rights, and requesting that they be declared void from the outset.The Supreme Court of Kentucky granted the petition for a supervisory writ. The Court held that the impeachment petition was invalid because it was not verified by affidavit, as required by statute. The Court further held that the allegations concerned discretionary judicial acts subject to correction through the appellate process or Judicial Conduct Commission proceedings, not impeachment, and that the Legislature’s actions violated the separation of powers. The Court also found that the impeachment process denied the judge due process, and that further proceedings would cause her irreparable harm. The Court enjoined the General Assembly from continuing the impeachment proceedings and ordered dismissal of the pending articles. View "GOODMAN V. NEMES" on Justia Law

Douglas Hodge and Timothy Shane, both parolees, challenged the procedures used by the Kentucky Parole Board to revoke parole. Hodge’s parole was revoked after he failed to report his new address and absconded, following difficulties with his living arrangements and subsequent lack of communication with his parole officer. Shane was revoked after being caught driving under the influence and violating a condition prohibiting alcohol use. In each case, the final evidentiary hearing was conducted by an Administrative Law Judge (ALJ), not the Parole Board itself, with both parolees represented by counsel and able to present evidence and witnesses.For Hodge, the Kenton Circuit Court dismissed his petition, finding the two-hearing process and the Board’s review complied with Morrissey v. Brewer, and the Kentucky Court of Appeals affirmed, holding due process was satisfied and the Board did not abuse its discretion. Hodge sought discretionary review in the Supreme Court of Kentucky. Shane’s claim was denied by the Franklin Circuit Court, which concluded the Board could delegate the final hearing to an ALJ. The Kentucky Court of Appeals reversed, holding statutory and constitutional requirements mandate the Parole Board itself conduct final revocation hearings, but found Shane’s appeal moot due to his release, applying the public interest exception.The Supreme Court of Kentucky reviewed both cases to resolve conflicting appellate rulings. It held that the Kentucky Parole Board is authorized to delegate the conduct of final parole revocation hearings to ALJs, provided the Board retains the ultimate decision-making authority. However, the Court determined that due process is not fully satisfied unless parolees have an avenue, such as the ability to file exceptions to the ALJ’s findings, to present arguments directly to the Board. Accordingly, the Supreme Court reversed the Court of Appeals in Hodge’s case and affirmed the appellate decision in Shane’s case. View "HODGE V. KENTUCKY PAROLE BOARD" on Justia Law

Jeremy Starr, a delivery driver for Graybar Electric, claimed workers’ compensation for a back injury sustained in March 2018 while unloading pipes. Starr had a history of lumbar issues stemming from a 2004 motor vehicle accident, including a disc herniation documented by MRI. After his workplace injury, Starr underwent further imaging and treatment, ultimately receiving lumbar fusion surgery in 2022. Medical opinions diverged: some attributed the need for surgery to degenerative changes originating from the earlier accident, while others suggested the work injury was a significant cause. Starr provided additional evidence, including new medical evaluations and a deposition from his surgeon, to argue the surgery was compensable.The Administrative Law Judge (ALJ) initially found Starr suffered only a lumbar strain from the workplace incident and ruled the fusion surgery was not work-related, thus non-compensable. The ALJ awarded temporary total disability benefits for a limited period and later amended the award upon reconsideration. The Workers’ Compensation Board affirmed the ALJ’s findings, concluding that any factual misstatement was not so unreasonable as to compel a different result and that new evidence submitted by Starr did not meet the standard for “newly-discovered evidence,” having been available with due diligence.The Court of Appeals reversed, holding that the ALJ should have considered Starr’s additional evidence and correcting factual misstatements, reasoning that interlocutory orders are not final and that contested issues remained open for adjudication. Upon review, the Supreme Court of Kentucky reversed the Court of Appeals and reinstated the Board’s decision. The Supreme Court held that under Bowerman v. Black Equipment Co., dispositive interlocutory factual findings cannot be reversed in a subsequent final opinion absent newly-discovered evidence, fraud, or mistake. The Court found no gross injustice from the ALJ’s factual misstatement and determined the additional evidence was merely cumulative and not newly discovered. View "GRAYBAR ELECTRIC V. STARR" on Justia Law

A firefighter employed by a city filed a legal action seeking a declaration that a city ordinance requiring firefighters to live within a certain distance of a fire station was invalid. He argued that state law, specifically KRS 311A.027(1), prohibits publicly funded emergency medical service first response providers from imposing residency requirements on employees or volunteers, and that the city's firefighters, who are certified to provide emergency medical services, fall within this category.The McCracken Circuit Court granted summary judgment in favor of the city, holding that the statute in question was not intended to apply to firefighters, but rather to those whose primary duties are as emergency medical service first response providers. The trial court reasoned that firefighters are primarily governed by a different chapter of Kentucky law, which does not prohibit residency requirements. The Kentucky Court of Appeals affirmed this decision, agreeing with the trial court’s interpretation and analysis.On discretionary review, the Supreme Court of Kentucky examined whether the statute applies to the city’s fire department and its personnel. The Court held that KRS 311A.027(1) applies to institutions, not individuals, and that the term “emergency medical service first response provider” as used in the statute refers to entities that provide ambulance services and are regulated as such under Kentucky law. Because the city’s fire department does not operate ambulances or provide ambulance services, it is not an emergency medical service first response provider within the meaning of the statute. Therefore, the residency ordinance is not preempted by KRS 311A.027(1). The Supreme Court of Kentucky affirmed the decision of the Court of Appeals. View "TORIAN V. CITY OF PADUCAH, KENTUCKY" on Justia Law

A police officer employed by a city in Kentucky worked a rotating schedule of 36 and 44 hours per week, but was paid for 40 hours each week without overtime for hours worked beyond 40 in a given week. After a state audit revealed the city’s payroll practices violated overtime requirements, the city issued back pay to affected employees and revised its procedures. The officer, believing the back pay was insufficient and that certain categories of compensation were miscalculated, rejected the payment and filed suit for unpaid overtime, vacation, and sick leave, as well as liquidated damages and attorney’s fees. The relevant period for the claim was limited by statute to the officer’s last three years of employment.The Bullitt Circuit Court, after a bench trial, found the city liable for unpaid overtime and vacation pay, but denied liquidated damages and retirement hazardous duty pay, and initially awarded sick leave. Upon the city’s motion to amend, the trial court corrected calculation errors, eliminated the sick leave award based on a city ordinance, and reduced the overtime award. The court also awarded only $2,500 in attorney’s fees, far less than the amount requested and supported by detailed billing records. The Kentucky Court of Appeals affirmed the denial of liquidated damages, sick leave, and retirement hazardous duty pay, but reversed and remanded for reconsideration of statutory interest and attorney’s fees.The Supreme Court of Kentucky affirmed the Court of Appeals in full. It held that the trial court properly amended its judgment to correct errors based on evidence presented at trial, that liquidated damages under the wage statute are discretionary when the employer acts in good faith, that statutory interest applies from the date of judgment, and that the trial court abused its discretion by arbitrarily reducing attorney’s fees without explanation. The case was remanded for proper calculation of interest and attorney’s fees. View "WHEELER V. CITY OF PIONEER VILLAGE, KENTUCKY" on Justia Law

A local government enacted an ordinance that completely prohibited its police officers from seeking or executing no-knock warrants within its jurisdiction. This ordinance was adopted after the state legislature passed a statute (SB 4, now codified in KRS 455.180 and related provisions) that did not ban no-knock warrants outright, but instead imposed strict conditions and procedural safeguards for their issuance and execution. The statute allowed no-knock warrants only in limited circumstances, subject to a clear and convincing evidentiary standard, approval by a superior officer, consultation with prosecutors, and time-of-day restrictions.The Fraternal Order of Police challenged the ordinance in Fayette Circuit Court, arguing that it conflicted with state law. The trial court found no express or implied conflict, reasoning that the statute did not require the use of no-knock warrants, but merely set conditions for their issuance, and thus the ordinance’s total ban did not conflict with the statute. On appeal, the Kentucky Court of Appeals reversed the trial court, but did not definitively resolve the conflict issue, instead remanding for further proceedings, particularly in light of collective bargaining questions.The Supreme Court of Kentucky granted discretionary review and held that the local ordinance directly conflicted with the state statute. The Court reasoned that the statute authorizes law enforcement officers to seek no-knock warrants under certain conditions, while the ordinance prohibits them from ever doing so, making it impossible for officers to comply with both. The Court concluded that when a local ordinance prohibits what a state statute permits, the ordinance is void. The Supreme Court of Kentucky reversed the Court of Appeals and declared the ordinance null, void, and of no effect. View "LEXINGTON-FAYETTE URBAN COUNTY GOVERNMENT V. FRATERNAL ORDER OF POLICE" on Justia Law

Several individuals who allegedly owed debts to Kentucky public institutions—either for medical services at the University of Kentucky or for educational services at the University of Kentucky, Morehead State University, or the Kentucky Community & Technical College System—challenged the referral of their debts to the Kentucky Department of Revenue for collection. The plaintiffs argued that the statutes used to justify these referrals did not apply to their debts and that the Department unlawfully collected the debts, sometimes without prior court judgments or adequate notice. The Department used its tax collection powers, including garnishments and liens, to recover these debts, and in some cases, added interest and collection fees.In the Franklin Circuit Court, the plaintiffs sought declaratory and monetary relief, including refunds of funds collected. The Circuit Court ruled that the Department was not authorized by statute to collect these debts and held that sovereign immunity did not protect the defendants from the plaintiffs’ claims. The court also certified the medical debt case as a class action. The Court of Appeals reviewed these interlocutory appeals and held that while sovereign immunity did not bar claims for purely declaratory relief, it did bar all claims for monetary relief, including those disguised as declaratory relief.The Supreme Court of Kentucky reviewed the consolidated appeals. It held that sovereign immunity does not bar claims for purely declaratory relief or for a refund of funds that were never due to the state, nor does it bar constitutional takings claims. However, the court held that sovereign immunity does bar claims for a refund of funds that were actually due to the state, even if those funds were unlawfully or improperly collected. The court affirmed in part, reversed in part, and remanded for further proceedings to determine which funds, if any, were never due to the state and thus subject to refund. The court also found that statutory changes rendered prospective declaratory relief in the medical debt case moot, but not retrospective relief. View "LONG V. COMMONWEALTH OF KENTUCKY" on Justia Law

A man named Donald Prater, Jr. was found partially nude and behaving erratically after leaving a hospital, having previously told a deputy he had used methamphetamine and was hallucinating. Law enforcement officers from the City of Paintsville and Johnson County, along with emergency medical personnel, responded to reports of his behavior. When officers attempted to arrest Prater on a public street, he resisted and force was used, including a taser, pepper spray, and baton strikes. After being handcuffed, Prater stopped breathing and, despite immediate lifesaving efforts, died. The medical examiner found no lethal trauma and attributed the death to excited delirium syndrome, with other health factors possibly contributing.The personal representative of Prater’s estate filed a wrongful death suit in Johnson Circuit Court against various city and county entities and their employees, alleging excessive force, negligence, and wrongful death. The circuit court granted summary judgment to all defendants, finding the officers and emergency personnel were entitled to qualified official immunity, that the force used was reasonable, and that there was no evidence their actions caused Prater’s death. The court also dismissed claims against the city and county entities, including those for negligent hiring and supervision, on the basis that no underlying tort had been established.On appeal, the Kentucky Court of Appeals affirmed in part and reversed in part, holding that some claims against the city and police department for negligent hiring and supervision could proceed, and that the officers’ entitlement to qualified immunity required further factual findings. The Supreme Court of Kentucky reviewed the case and held that all defendants were properly dismissed. The Court concluded that the officers’ actions were discretionary, performed in good faith, and within the scope of their authority, entitling them to qualified official immunity. The Court reversed the Court of Appeals in part, affirmed in part, and remanded for any necessary proceedings. View "CITY OF PAINTSVILLE V. HANEY" on Justia Law