Justia Kentucky Supreme Court Opinion Summaries

Appellant was severely injured in an automobile collision in Kentucky while driving a truck for Miller Pipeline Corporation. Appellant received workers’ compensation benefits and settled with the tortfeasor and then sought to recover the remainder of his damages from underinsured motorist (UIM) coverage in Miller’s policy with Zurich American Insurance Company. Zurich denied coverage because Miller had allegedly rejected UIM coverage in Kentucky. The trial court ultimately granted summary judgment in favor of Zurich, concluding that the inclusion of UIM coverage in the policy was a mutual mistake by Miller and Zurich. The court of appeals affirmed. The Supreme Court reversed, holding that the doctrine of mutual mistake was erroneously applied by the courts below. Remanded for an order granting Appellant’s motion for partial summary judgment on the issue of UIM coverage. View "Nichols v. Zurich Am. Ins. Co." on Justia Law

Appellee was an inmate when he was allegedly involved in a riot. During an interview with an investigating officer, Appellee requested that three witnesses be questioned who could corroborate his version of events, but the witnesses were not interviewed. After a disciplinary hearing, at which Appellee did not call witnesses or present evidence in his defense, Appellee was disciplined for his participation in the riot. Appellee subsequently filed a petition for declaration of rights in the circuit court, arguing that Appellants violated his due process rights by failing to interview the three purported witnesses and by denying him the right to call witnesses and present evidence in his defense. The trial court dismissed the complaint, concluding that the hearing complied with the minimal requirements of procedural due process as outlined in Wolff v. McDonnell. The court of appeals reversed. The Supreme Court affirmed, holding (1) the interviewing officer’s failure to interview the requested witnesses did not deprive Appellant of procedural due process as outlined in Wolff; but (2) while Appellee did not have had the right to remain silent or the right to an attorney during his disciplinary hearing, he deserved a new disciplinary hearing because he was erroneously informed that he enjoyed the rights espoused in Miranda. View "White v. Boards-Bey" on Justia Law

The City of Lebanon sought to annex several hundred acres of nearby property. The owners of the property subject to the annexation, including Appellees, filed a lawsuit against the City to invalidate the annexation ordinance. The trial court granted Appellees’ motion for summary judgment, concluding that the City, by intentionally manipulating the annexation boundaries to guarantee a successful annexation, violated Appellees’ constitutional rights. The court of appeals affirmed, holding that the boundaries of territory to be annexed must be “natural or regular” and that the boundaries of the proposed annexation in this case did not meet this standard. The Supreme Court reversed and declared the annexation valid, holding (1) the court of appeals erred in applying a “natural or regular” standard; and (2) the City’s annexation fully complied the the statutory requirements and did not violate Appellees’ constitutional rights. View "City of Lebanon v. Goodin" on Justia Law

After a jury trial in 1993, Appellant was found guilty of murdering two brothers, Rodney Vaughn and Lynn Vaughn. The trial court sentenced Appellant to death for both murders. In 2013, Appellant filed a motion for post-conviction relief alleging that he was entitled to a new trial based on “newly discovered evidence.” Appellant’s challenge to his convictions was founded upon a report prepared by John Nixon, a forensic expert on firearms and ballistics, who concluded that new information supported Appellant’s version of events, thereby supporting Appellant’s claim that he acted in self-defense in shooting Rodney and that Rodney shot Lynn. The trial court summarily denied Appellant’s motion without conducting an evidentiary hearing. The Supreme Court affirmed, holding that the “newly discovered evidence” presented by Appellant fell short of the standards that must be met to obtain such relief. View "Foley v. Commonwealth" on Justia Law

After a jury trial, Appellant was found guilty of one count of complicity to murder and one count of first-degree complicity to robbery. Appellant was sentenced to life imprisonment on the murder count and to twenty years on the robbery count. The Supreme Court affirmed Appellant’s convictions and sentences, holding (1) the trial court did not err by denying Appellant’s motions for mistrial after the Commonwealth referenced two of the three co-indictees’ guilty pleas in the presence of the jury; (2) the trial court did not err by admitting eighteen jail letters written by Appellant and her co-indictee into evidence; and (3) the trial court did not err by denying Appellant’s motion for a mistrial after the jury briefly accessed inadmissible evidence during deliberations. View "Mayse v. Commonwealth" on Justia Law

Appellant was convicted of rape in the first degree, sodomy in the first degree, and assault in the fourth degree, third offense. The trial in this case was trifurcated. During the first phase, the jury convicted Appellant of fourth-degree assault, and during the second phase, the jury convicted Appellant of fourth-degree assault, third offense based on two prior convictions of fourth-degree assault. The Supreme Court reversed the portion of the judgment convicting Appellant of fourth-degree assault, third offense, and vacated the corresponding sentence for that offense, holding that the evidence was insufficient to support the charge and that retrial for the charge was precluded under the double jeopardy clause of the Fifth Amendment. Because Appellant was not sentenced for the fourth-degree assault conviction, however, the case was remanded for sentencing for that conviction. View "Galloway v. Commonwealth" on Justia Law

After a jury trial, Appellant was found guilty of murdering his wife and sentenced to life in prison. On appeal, Appellant alleged, inter alia, that he was entitled to a directed verdict and that the trial court erred in admitting evidence of other acts. The Supreme Court reversed Appellant’s conviction and remanded for further proceedings, holding (1) Appellant was not entitled to a directed verdict of acquittal and therefore may be retried; and (2) the trial court’s admission of the other acts evidence was error under Ky. R. Evid. 404(b) given the Commonwealth’s failure to establish proof of the factual condition necessary to make it relevant, and the error was not harmless and prejudiced Appellant. View "Southworth v. Commonwealth" on Justia Law

Judith Burton filed a complaint against Dr. Philip Trover, a radiologist, and the Trover Clinic Foundation (TCF), Dr. Trover’s employer, alleging (1) Dr. Trover misread CT scans of her lungs, thereby delaying the diagnosis of her lung cancer, and (2) TCF was vicariously liable for Dr. Trover’s alleged negligence and was negligent itself in credentialing. Burton died before tried, and her Estate revived the complaint with respect to TCF, which impleaded Dr. Trover. A jury entered a verdict for Dr. Trover, and the trial court dismissed all of the Estate’s claims. The court of appeals reversed, concluding that the trial court erred by not allowing the Estate to cross-examine Dr. Trover regarding the status of his Kentucky medical license, and the error was not harmless. The Supreme Court reversed, holding that the trial court did not abuse its its discretion by excluding the license-status evidence, given the potential for confusing the issues to be tried and the strong likelihood that it would cause unfair prejudice. View "Trover v. Estate of Burton" on Justia Law

Appellant was injured while working for Employer, which had an insurance policy issued by Zurich American Insurance Company. The policy included an underinsured motorist (UIM) endorsement. After settling with the tortfeasor, Appellant sought damages from the UIM coverage in the Zurich policy. After Zurich refused Appellant’s claim, Appellant sued Zurich. Ultimately, the trial court granted summary judgment in favor of Zurich on the grounds that the UIM coverage included in the policy was the result of a mutual mistake in the making of the insurance contract. The Supreme Court reversed and remanded for entry of an order granting Appellant’s motion for partial summary judgment on the issue of UIM coverage, holding that reformation of the insurance contract on the grounds of mutual mistake was improper because (1) the facts did not establish that at the time the insurance contract was formed, the minds of the contracting parties met with the common intent to execute a policy that excluded UIM coverage; and (2) Zurich did not assert the mistake or deny the existence of UIM coverage until after Appellant had released the tortfeasor. View "Nichols v. Zurich Am. Ins. Co." on Justia Law

Mary Bell was a disabled person who drew Social Security Insurance benefits and participated in a federally-funded, community-based program operated by the Cabinet for Health and Family Services. When Thomas Bell, Mary’s father, retired and began to draw his Social Security benefits, Mary became eligible for Old Age, Survivor and Disability Insurance. Consequently, Mary was charged $60 per month for her continued program participation. Thomas filed an administrative appeal on Mary’s behalf. The matter ultimately reached the circuit court, which held that Mary could not be charged to participate in the program. Thereafter, the circuit court (1) awarded attorney’s fees against the Cabinet due to the Cabinet’s “egregious government behavior,” and (2) ordered the Cabinet to disclose the personal information of all other participants in the program. The court of appeals reversed. The Supreme Court affirmed, holding that the trial court erred by (1) ordering the payment of attorney’s fees solely for egregious conduct without statutory authorization or a contract providing for such fees; and (2) ordering the disclosure of records of all persons participating in the program without the other persons having filed claims and no class action being certified. View "Bell v. Commonwealth" on Justia Law