Justia Kentucky Supreme Court Opinion Summaries
St. Clair v. Commonwealth
After a jury trial, Appellant was convicted of capital murder and sentenced to death. The Supreme Court affirmed the conviction but remanded for a new sentencing trial. After a retrial, the jury again returned a death-penalty verdict. Appellant was sentenced in accordance with that verdict. Appellant appealed the denial of his motion for a new trial and his death sentence. The Supreme Court affirmed Appellant’s murder conviction, to the extent it was challenged on appeal, and sentence of death, holding that (1) Appellant’s claims of error were either without merit or did not require reversal; and (2) the jury’s verdict was factually substantiated, and the sentence was valid. View "St. Clair v. Commonwealth" on Justia Law
Linden v. Griffin
Plaintiff filed suit against Defendants alleging fraud, defamation, abuse of process, breach of fiduciary duty, and other claims. Plaintiff also requested declaratory judgment, accounting, and injunctive relief. Pursuant to the parties’ prior agreement, which included an arbitration clause, the trial court granted Defendants’ motion to compel arbitration on all counts with the exception of claims involving defamation and abuse of process. Because Defendants appealed, the trial court refrained from ruling on Plaintiff’s request for injunctive relief. Consequently, Plaintiff petitioned the court of appeals, without success, for a writ of mandamus. The Supreme Court affirmed. Plaintiff also appealed the trial court’s order compelling arbitration. Plaintiff’s and Defendants’ appeals were consolidated. The court of appeals affirmed the entirety of the trial court’s order compelling arbitration. The Supreme Court affirmed in part and reversed in part, holding (1) the Court lacked jurisdiction to consider the merits of Plaintiff’s appeal because Plaintiff attempted to appeal from a non-final order; and (2) the court of appeals correctly determined that the abuse of process and defamation claims fell outside the agreement to arbitrate. View "Linden v. Griffin" on Justia Law
Rumpel v. Skaggs
After a trial, the circuit court dissolved the marriage of Kaven Rumpel and Kathie Rumpel, restored to the parties their non-marital property, apportioned between them the marital debts and assets, and awarded Kathie maintenance and attorneys’ fees. The court of appeals affirmed. The Supreme Court reversed in part the trial court’s judgment and vacated Kathie’s award of attorneys’ fees, holding (1) the trial court abused its discretion by awarding attorneys’ fees as a discovery sanction for a party’s refusal to admit a fact genuinely in dispute; (2) the trial court abused its discretion by substantially amending, in response to Kathie’s post-trial motion, its judgment regarding the value of the principal marital asset, as such a post-judgment motion is not available for the assertion of claims that could have been asserted prior to judgment; and (3) the award of attorneys’ fees must be readdressed by the trial court. View "Rumpel v. Skaggs" on Justia Law
Posted in:
Family Law
Wilson v. Commonwealth
After a jury trial, Defendant was convicted of one count of burglary, three counts of theft by unlawful taking of a firearm, one count of theft by unlawful taking of property having a value of $500 or more, and of being a persistent felony offender in the first degree. Defendant was sentenced to twenty-five years in prison. The Supreme Court reversed, holding (1) the trial court abused its discretion in allowing admission of detailed evidence of Defendant’s past domestic violence, as the evidence became an expose of Defendant’s extensive domestic misconduct, and the probative value of the evidence was clearly outweighed by its prejudicial nature; (2) Defendant’s convictions on the three separate counts of theft by unlawful taking of a firearm violated Defendant’s double jeopardy rights; and (3) the evidence was not sufficient to support the first-degree burglary conviction. View "Wilson v. Commonwealth" on Justia Law
Caniff v. CSX Transp., Inc.
Appellant was injured while working as a carman for CSX Transportation, Inc. (CSXT). Appellant sued CSXT under the Federal Employers’ Liability Act (FELA), asserting that his injuries were, in part, the result of CSXT’s negligence. The trial court granted summary judgment on Appellant’s negligence claims in favor of CSXT. The court of appeals affirmed. The Supreme Court reversed, holding (1) issues of material fact existed as to whether Appellant’s injuries resulted in whole or in part from the negligence of any of the officers, agents, or employees of CSXT, and the issues were within the common knowledge and experience of the jury; and (2) therefore, summary judgment was improper.
View "Caniff v. CSX Transp., Inc." on Justia Law
Posted in:
Injury Law, Labor & Employment Law
Mills v. Dep’t of Corr. Offender Info. Servs.
Appellant pleaded guilty to several offenses, including manufacturing methamphetamine while in possession of a firearm and being a first-degree persistent felony offender, and received a maximum sentence of twenty years’ imprisonment. Based on his convictions, the Department of Corrections classified Appellant as a violent offender, which required Appellant to serve a greater part of his sentence before reaching parole eligibility. Appellant sued the Department in circuit court to block the violent-offender classification’s application to him, arguing that his convictions were all non-violent drug offenses. The circuit court dismissed Appellant’s suit, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the Controlled Substances Act operates to enhance the conviction, not simply the sentence; and (2) the firearm-enhancement provision of the Act served to elevate Appellant’s conviction for manufacturing methaphetamine from a Class B to a Class A felony conviction, which qualified Appellant for classification as a violent offender. View "Mills v. Dep’t of Corr. Offender Info. Servs." on Justia Law
Posted in:
Criminal Law
Hon. George W. Davis, III v. Hon. Thomas D. Wingate
Marc Rosen, a retired senior status special judge who sought to become a candidate for circuit judge in the 2014 election, filed a declaratory judgment action contesting the constitutionality of HB 427, a statute that prohibits judges who have chosen to retire as a senior status special judge from becoming candidate for an elected office for five years after retirement. The circuit court found Rosen was disqualified from being a candidate under the terms of HB 427 without ruling on the constitutionality of the statute. Rosen petitioned the court of appeals to set aside the circuit court order, and the court granted the motion. George W. Davis then initiated a writ action in the court of appeals, arguing that the circuit court lacked jurisdiction to decide Rosen’s constitutional challenge. The court of appeals denied the petition. The Supreme Court affirmed, holding that the circuit court had jurisdiction to hear Rosen’s declaratory action regarding the constitutionality of HB 427. View "Hon. George W. Davis, III v. Hon. Thomas D. Wingate" on Justia Law
Posted in:
Constitutional Law, Election Law
Watts v. Danville Housing Auth.
Appellant represented Claimant in a workers’ compensation case. The Chief Administrative Law Judge (CALJ) entered an interlocutory order, which resulted in Claimant receiving temporary total occupational disability benefits. The claim was later returned to the active docket, and the parties reached a settlement. Appellant subsequently filed two motions for approval of attorney fees, requesting approval of $12,000 for work performed in obtaining the lump sum payment and requesting approval of $8,369 for work performed in obtaining the benefits which Claimant recovered from the interlocutory award. The CALJ granted Appellant’s motion for $12,000 but denied the motion for $8,369 in fees, concluding that Ky. Rev. Stat. 342.320(2)(a) caps attorney fees to a total of $12,000. On appeal, Appellant argued that an interlocutory proceeding in a workers’ compensation case should be considered separate from a claim for income benefits and therefore not subject to the statutory cap on attorneys fees established in section 342.320(2)(a). The Workers’ Compensation Board and Court of Appeals affirmed. The Supreme Court affirmed, holding that the attorney fee for the entire proceeding in this matter was subject to the statutory maximum of $12,000 under section 342.320(2)(a). View "Watts v. Danville Housing Auth." on Justia Law
Furtula v. Univ. of Ky.
Appellants, former employees of the University of Kentucky, filed suit against the University alleging that, by rejecting their applications for disability status, the University breached a written contract consisting of a staff handbook and associated personnel policy documents defining the disability compensation programs. The court of appeals dismissed Appellants’ claims on the basis of governmental immunity, concluding that the documents establishing the University’s employee disability compensation did not constitute a written contract, and therefore, the University was shielded from Appellants’ claims by the doctrine of governmental immunity. The Supreme Court affirmed, holding (1) Appellants did not establish that the General Assembly expressly waived sovereign immunity in claims based upon implied contracts arising from a state university’s employee handbooks and personnel policies, and the relevant University personnel documents specifically disclaimed the creation of a contract; and (2) therefore, sovereign immunity remained a valid affirmative defense under the circumstances presented. View "Furtula v. Univ. of Ky." on Justia Law
Posted in:
Contracts, Labor & Employment Law
Henderson v. Commonwealth
After a jury convicted Appellant of possession of a handgun by a convicted felon Appellant entered a conditional guilty plea to various other charges. On appeal, Appellant challenged the trial court’s exclusion of prior-bad-acts evidence and hearsay testimony. The court of appeals affirmed, concluding that the trial court erred by excluding the evidence but that Appellant did not properly preserve the issue for appellate review. The Supreme Court affirmed Appellant’s conviction and sentence, holding (1) counsel’s offer of proof about the excluded testimony was insufficient to preserve appellate review; and (2) regardless of any preservation misstep, the trial court’s exclusion of the testimony was harmless. View "Henderson v. Commonwealth" on Justia Law
Posted in:
Criminal Law