Justia Kentucky Supreme Court Opinion Summaries

Appellee worked for the City of Middlesboro. Approximately one month before the last date of his paid employment, Appellant filed for disability retirement benefits as a member of the County Employees Retirement Systems. Appellant based his application on a work-related back injury and "breathing problems," citing his diagnosis of chronic obstructive pulmonary disease (COPD) as the reason for his breathing problems. A hearing officer recommended denial of benefits, concluding that Appellee's COPD was the result of his chronic use of tobacco and that there was no permanent impairment to Appellee's back. The Disability Appeals Committee adopted the hearing officer's recommended order. The court of appeals reversed and remanded, concluding that the hearing officer had failed to consider the cumulative effect of Appellee's various impairments and that the hearing officer improperly considered Appellee's chronic tobacco use as a "pre-existing condition." The Supreme Court reversed, holding (1) the hearing officer did, in fact, consider the combined effect of Appellee's impairments as required by Ky. Rev. Stat. 61.600; and (2) the hearing officer's conclusion that Appellee's COPD was a pre-existing condition was reasonable. View "Ky. Ret. Sys. v. West" on Justia Law

Defendant pleaded guilty to charges of murder, first-degree burglary, and two counts of first-degree sexual abuse. After a sentencing hearing, the trial judge sentenced Defendant to death. Defendant subsequently filed a Ky. R. Crim. P. 11.42 motion collaterally attacking his sentence and conviction, claiming that his guilty plea should be set aside as involuntary because he believed the trial judge had agreed to sentence him to life without parole and because his trial counsel bullied him into entering the guilty plea. The trial judge denied the motion without an evidentiary hearing. The Supreme Court remanded the matter for an evidentiary hearing on whether there was judicial interference in the plea process and whether Defendant was coerced by his counsel. After an evidentiary hearing on remand, the trial judge denied Defendant's motion for relief. The Supreme Court affirmed, holding that the proof showed no judicial interference in the plea process and that Defendant's counsel did not threaten or otherwise coerce him into pleading guilty. View "Johnson v. Commonwealth" on Justia Law

Sarah Crossett was employed by Jackson Purchase Medical Associate (JPMA), which leased space within a medical pavilion. Crossett was injured when she slipped and fell in snow that had accumulated outside of the building. Crossett filed for workers' compensation. JPMA disputed Crossett's claim, asserting that the injury did not occur on its operating premises under the going and coming rule, which provides that injuries that occur while an employee is on the way to or from a worksite are not compensable. An ALJ concluded that Crossett's injury was compensable, finding that Crossett fell within the operating premises of JPMA. The court of appeals affirmed. The Supreme Court affirmed, holding that because JPMA could assert control over the parking area and because Crossett was not taking an unreasonable path between her car and her office, she was entitled to workers' compensation benefits for her injury. View "Jackson Purchase Med. Assocs. v. Crossett" on Justia Law

Appellee, an inmate, allegedly assaulted another inmate. After a disciplinary report was submitted against Appellee, the Adjustment Committee (Committee) determined that Appellee was guilty of the infraction and sentenced Appellee accordingly. Appellee appealed the decision and filed a petition for declaration of rights, arguing that the Committee's reliance on information obtained from confidential informants violated his constitutional due process rights. After a rehearing, the Committee again declared Appellee guilty of the infraction. The trial court ultimately dismissed Appellee's petition, concluding that the Committee did not violate Appellee's due process rights. The court of appeals reversed, determining that there was insufficient evidence of the disciplinary charge against Appellee to pass the "some evidence" standard pronounced in Superintendent, Massachusetts Correctional Institution, Wadpole v. Hill. The Supreme Court affirmed, holding (1) the Committee, relying solely on the confidential informants' information, failed to supply some evidence to support its finding that the confidential informants and their information were credibl; and (2) accordingly, Appellee's due process rights were violated. View "Haney v. Thomas" on Justia Law

After a jury trial, Defendant was convicted of tampering with physical evidence, possession of drug paraphernalia, criminal littering, and carrying a concealed deadly weapon. The court of appeals reversed and remanded Defendant's criminal littering conviction but otherwise affirmed. Defendant sought discretionary review, challenging the constitutional validity of the initial traffic stop, the pat-down of his person, and the vehicle search which led to the evidence supporting his convictions. The Supreme Court reversed and remanded, holding (1) Defendant was arrested after the officer conducted an unlawful Terry pat-down of his person, resulting in the discovery of a bag of marijuana; and (2) therefore, the vehicle search incident to the unlawful arrest was also unlawful. View "Frazier v. Commonwealth" on Justia Law

Brian and Lori Peay purchased a home manufactured by Energy Homes, Division of Southern Energy Homes, Inc. (SEHI). At closing, SEHI offered the Peays certain warranties on the home in exchange for the Peays' agreement that any disputes over the home would be submitted to binding arbitration. Brian Peay accepted the warranties and signed the arbitration agreement. After discovering flaws in the home, the Peays filed suit against SEHI, among other defendants. SEHI moved to enforce the arbitration agreement by ordering the parties to arbitrate the dispute. The circuit court denied the motion. The court of appeals affirmed the order denying enforcement of the arbitration agreement. The Supreme Court reversed, holding, contrary to the findings of the court of appeals, (1) the arbitration agreement was not prohibited by the merger and integration clause of the purchase contract; (2) the arbitration agreement was not unconscionable; and (3) Lori Peay was bound to the arbitration agreement even though she did not sign the agreement. Remanded. View "Energy Home, Div. of S. Energy Homes, Inc. v. Peay" on Justia Law

After a jury trial, Defendant was convicted of second-degree burglary. Defendant was placed on probation, which was later revoked due to Defendant's noncompliance with the terms of the county's drug court program. Defendant appealed both his burglary conviction and his probation revocation. The court of appeals reversed Defendant's conviction, concluding that the trial court erred in failing to conduct a Faretta v. California hearing to inquire into Defendant's desire to serve as his own attorney. The Supreme Court reversed, holding that because Defendant did not unequivocally request to dispense with counsel and to proceed pro se, the trial court was under no obligation to engage Defendant in a Faretta colloquy. Remanded. View "Commonwealth v. Martin" on Justia Law

In 1992, Defendant pled guilty to illegal possession of a controlled substance in the first degree. In 2010, Defendant filed a motion to void her felony conviction, which the circuit court granted. Thereafter, Defendant moved to expunge the newly voided felony conviction. The Commonwealth opposed the motion, asserting that neither Ky. Rev. Stat. 431.076 nor Ky. Rev. Stat. 431.078 provide for expungement of a voided conviction. The trial court expunged Defendant's record pursuant to Ky. R. Civ. P. 60.02(f), which permits a court to relieve a party from its final judgment for any reason of an extraordinary nature that justifies such relief. The court of appeals affirmed but on different grounds, concluding that Defendant's voided conviction amounted to the underlying charge being dismissed with prejudice, thereby qualifying for expungement under section 431.076. The Supreme Court reversed, holding (1) the trial court lacked authority under section 431.076 to expunge Defendant's newly voided conviction, as voiding Defendant's conviction was not the same as her charges being dismissed with prejudice; and (2) the use of the catch-all provision found in Rule 60.02(f) was error. View "Commonwealth v. Jones" on Justia Law

The City of Fort Thomas, through its police department, denied a request by the Cincinnati Enquirer to inspect and copy the entire police file generated during a homicide investigation. In denying the request, the City relied on the law-enforcement exemption to the Kentucky Open Records Act (Act). The circuit court upheld the City's denial of the Enquirer's request. The court of appeals reversed, thereby rejecting the City's claim of a blanket exemption for its investigatory file, and remanded with instructions that the file be parsed into exempt and non-exempt portions of the investigatory file, with the non-exempt portions to be released to the newspaper. The Supreme Court affirmed in part and reversed in part, holding (1) the court of appeals correctly determined that the law enforcement exemption does not create a blanket exclusion from the Act's disclosure provisions for all law enforcement records pertinent to a prospective law enforcement action; and (2) to invoke the exemption, the City must show the disclosure of such records would harm or interfere with a prospective enforcement action in some significant and concrete way. Remanded. View "City of Fort Thomas v. Cincinnati Inquirer" on Justia Law

Appellant pled guilty to four counts of complicity to rape (victim under twelve years of age) and one count each of first-degree rape, first-degree sodomy, and first-degree sexual abuse pursuant to a conditional guilty plea. Appellant subsequently appealed the trial court's denial of his motion to suppress statements he made to a social worker on the grounds that Appellant was not provided with Miranda warnings. The trial court determined that, under the totality of the circumstances, Appellant was not entitled to Miranda warnings. The Supreme Court affirmed, holding that, considering the totality of the circumstances, Appellant was not subjected to custodial interrogation for purposes of Miranda, and therefore, the trial court properly denied Appellant's motion to suppress. View "Buster v. Commonwealth" on Justia Law