Justia Kentucky Supreme Court Opinion Summaries

After a trial, Appellant was convicted of first-degree sodomy, intimidating a participant in the legal process, second-degree wanton endangerment, third-degree terroristic threatening, and being a persistent felony offender in the first degree. Appellant was sentenced to thirty years’ imprisonment. The Supreme Court affirmed, holding (1) the trial court did not commit reversible error admitting testimony of a sexual assault nurse examiner; and (2) the trial court did not err by failing to grant Appellant’s motion for a directed verdict on the charge of intimidating a witness in the legal process. View "Edmonds v. Commonwealth" on Justia Law

Defendant was charged with manufacturing methamphetamine and possession of drug paraphernalia. Defendant filed to sequential motions to suppress evidence, contending that the warrantless search of his mobile home was illegal and that the Commonwealth did not establish the proper chain of custody for the evidence seized from his home. Both motions were denied, and Defendant was found guilty as charged. The Supreme Court reversed and remanded, holding that the warrantless search of Defendant's mobile home satisfied neither the textual directives of the Fourth Amendment and Section 10 of the Kentucky Constitution nor the judicially-created exception under Maryland v. Buie.View "Brumley v. Commonwealth" on Justia Law

Appellee filed suit against Appellants, seeking personal property damages and lost business income resulting from a vehicle collision in which a truck was damaged. The truck was owned by Appellee individually and used in his trucking business, an LLC. The LLC was not named as a plaintiff in the lawsuit. After the trial court granted Appellants' motion for summary judgment as to the lost business income, the court granted Appellants a judgment on the pleadings due to Appellee's failure to comply with discovery orders. The court of appeals reversed, concluding, inter alia, that (1) Appellee could properly pursue his lost business claim in his own name because he was the sole owner of the LLC, and (2) Appellee had presented sufficient evidence to overcome the motion for summary judgment. The Supreme Court vacated the judgment of the court of appeals and remanded, holding (1) the court of appeals erred in determining that Appellee could bring a claim in his own name for any trucking business lost by the LLC; and (2) the discovery sanction imposed on Appellee was the functional equivalent of an order dismissing both claims, and as such, findings of fact and conclusions of law were required.View "Turner v. Andrew" on Justia Law

James Taylor sued Chase Bank for failure to comply with the Uniform Commercial Code in regard to a check that had been returned for insufficient funds. The trial court concluded that there was an arbitration agreement between the parties and referred the case to arbitration. The arbitrator later granted Chase’s motion to dismiss the claim because of Taylor’s delay in filing the arbitration claim. Thereafter, the trial court set aside its earlier order finding that an arbitration agreement existed and its referral of the case to arbitration and denied Chase’s motion to confirm the arbitration award. Chase took an interlocutory appeal of the order denying its motion to confirm the arbitration order, arguing that the trial court was bound to confirm the arbitrator’s decision. The court of appeals affirmed the trial court. The Supreme Court affirmed, holding that the trial court had the authority to set aside the order compelling arbitration after the arbitrator had rendered a dispositive order because the matter was not final and there was insufficient proof of the existence of a valid arbitration agreement. View "JPMorgan Chase Bank, N.A. v. Bluegrass Powerboats" on Justia Law

Ann Shannon was the sole member of a limited liability company (LLC). In 2004, Shannon signed a lease for commercial space with the property’s owner, Rick Pannell, on behalf of the LLC. In 2005, the LLC was administratively dissolved. In 2006, Shannon and Pannell entered into a release of the old lease and a new lease. The new lease expressly stated that the LLC was the tenant and was signed by Shannon but did not mention Shannon’s company capacity in any direct way. Pannell subsequently sued for breach of the lease, naming the LLC and Shannon individually. Shortly after, the LLC was reinstated. The circuit court concluded that Shannon was entitled to immunity from personal liability and awarded Pannell damages against the LLC under the lease. The court of appeals affirmed. The Supreme Court affirmed, holding (1) based on the facts of this case, Shannon did not directly obligate herself because she clearly signed the lease in her representative capacity and the lease was expressly with the company; and (2) Shannon could not be personally liable under Kentucky’s Limited Liability Company Act or under the theory that she exceeded her authority as an agent of the LLC during the dissolution. View "Pannell v. Shannon" on Justia Law

After a prison disciplinary hearing, Appellant, a prisoner, was found guilty of committing physical action against another inmate resulting in death or serious physical injury. Appellant subsequently filed a declaration of rights action in circuit court appealing the finding of guilt, contending that his due process rights were violated because the prison’s disciplinary hearing officer refused to allow him to call the victim of the assault and declined to view surveillance camera footage of the incident. The circuit court denied the petition. The court of appeals affirmed. The Supreme Court reversed, holding (1) if a prison challenges the denial of a prisoner’s request for a particular witness in a disciplinary proceeding by appealing the discipline imposed, the adjustment officer (AO) must provide for the record on review the AO’s reason for denying the witness; (2) if requested by the prisoner in a disciplinary proceeding an AO must review surveillance footage or similar documentary evidence; and (3) Appellant was found guilty and subject to prison discipline as a result of a process that failed to comport with the minimum requirements of due process. Remanded. View "Ramirez v. Nietzel" on Justia Law

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