Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals affirming the decision of the Workers' Compensation Board affirming an administrative law judge's finding that Claimant's total knee replacement was compensable, holding that Claimant was not entitled to relief on his claims of error.Claimant injured his knee while at work and received workers' compensation benefits. Claimant continued to experience knee pain after surgery and ultimately underwent a total knee replacement. Employer filed a medical fee dispute, and an ALJ found that the total knee replacement was compensable. The Board and court of appeals affirmed. The Supreme Court affirmed, holding that the ALJ had sufficient evidence to conclude that Claimant's total knee replacement was reasonable and necessary and was within his discretion to make inferences. View "Perry County Bd. of Education v. Campbell" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellants' request for post-conviction relief from their murder convictions, holding that the trial court did not err in denying relief.At issue were three post-conviction collateral attack motions seeking to vacate the murder convictions of three appellants (collectively, Appellants). Appellants requested post-conviction relief on the grounds that the combination jury instructions rendered their verdicts non-unanimous. Specifically, Appellants argued that the instructions ran afoul of the unanimity requirement set forth in Ramos v. Louisiana, 140 S. Ct. 1390 (2020). The Supreme Court affirmed, holding that the trial court did not err in determining that Ramos did not apply retroactively to these cases and that Appellants' claims were time-barred. View "Halvorsen v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the trial court's judgment ordering McMichael to pay $62,493 in restitution jointly and severally with his co-defendant after he pled guilty to theft by unlawful taking over $500 but less than $10,000, holding that there was insufficient evidence to support the restitution award.Defendant's conviction stemmed from Defendant and his co-defendant removing several pieces of stainless-steel siding from an old diner and selling them for $155.81. In reversing, the court of appeals concluded that there was insufficient evidence to support the restitution amount. The Supreme Court affirmed, holding that there was no evidence as to the diner's worth at the time of the theft, the diner's worth after the theft, or the value of the recovered stainless-steel, the case must be remanded for a retrial on restitution. View "Commonwealth v. McMichael" on Justia Law

The Supreme Court held that the federal Food Security Act of 1985 (FSA) was preemptive of Kentucky's Uniform Commercial Code (UCC) and that thoroughbreds and the right to breed them are farm products within the meaning of the FSA and, as a result, any security interest in those products was extinguished when they were sold to their respective buyers.The FSA abrogated a common exception in the UCC allowing for a security interest to remain when a farm product pass from seller to buyer. At issue in this case was (1) whether the FSA applies when the product at issue was a thoroughbred horse with particularly valuable breeding rights, and (2) whether breeding rights are farm products within the FSA. The Supreme Court held (1) the FSA preempts Kentucky's farm products exception; and (2) the plain language of the FSA demonstrates that thoroughbred horses are farm products within the meaning of the FSA, and breeding rights are also farm products under the FSA. View "MGG Investment Group LP v. Bemak N.V., Ltd." on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Appellant's convictions for first-degree wanton endangerment and first-degree persistent felony offender and his sentence of seventeen years in prison, holding that the trial court abused its discretion in failing to give a jury instruction on second-degree wanton endangerment.At issue on appeal was whether the trial court erred in failing to instruct the jury on the lesser-included offense of second-degree wanton endangerment. The Supreme Court agreed and reversed, holding (1) when a defendant has pled not guilty and restricted his defense to disputing the circumstances of the elements of the crime charged, his uncorroborated testimony in support of that defense will generally merit a jury instruction, but there is no bright-line rule that a defendant has to testify, much less that his testimony be corroborated, to received a lesser-included offense instruction; and (2) because Defendant's uncorroborated testimony in this case was evidence in the record that would support a guilt determination on second-degree wanton endangerment, the trial court erred by not giving that instruction to the jury. View "Taylor v. Commonwealth" on Justia Law

The Supreme Court affirmed Defendant's convictions of wanton murder and other crimes and his sentence of thirty years' imprisonment, holding that Defendant was not entitled to relief on his allegations of error.Defendant was driving a 2006 Ford Mustang when he t-boned a golf cart that killed the golf cart's passenger. After a jury trial, Defendant was convicted of wanton murder, first-degree assault, wanton endangerment, operating a motor vehicle while under the influence of alcohol, and operating a motor vehicle without an operator's license. The Supreme Court affirmed, holding that the trial court did not err by (1) excluding evidence for lack of relevance as to additional signage placed in the cart path after the date of the collision; (2) failing to instruct the jury in accordance with its order taking judicial notice; (3) failing to conduct a Daubert hearing before denying Defendant's motion in limine to exclude the testimony of two experts; and (4) did not err by declining to instruct the jury on reckless homicide. View "Pozo-Illas v. Commonwealth" on Justia Law

In this case arising the death of James Savage after he was thrown from his motorcycle and run over by Oscar Ramos, the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals remanding this case back to the circuit court for a new trial, holding that remand was required under the circumstances.Specifically, the Supreme Court held (1) Property & Casualty Insurance Company of Hartford was not the owner of the Jeep Wrangler at issue according to Ky. Rev. Stat. 186A.530(3), and Co-part of Connecticut, Inc. was required to obtain proof of insurance pursuant to sections 186A.215 and 186A.220; (2) the court of appeals improperly engaged in fact-finding that affected its judgment on other issues; (3) the court of appeals erred in ruling that the trial court abused its discretion by allowing Co-part to withdraw an admission; (4) strict liability does not apply as a matter of law for violations of Ky. Rev. Stat. 186A.500; and (5) Aull v. Houston, 345 S.W.3d 232 (Ky. App. 2010) is hereby abrogated to the extent that it can be read to hold that Social Security Disability benefits are inadmissible in a damages calculation in a wrongful death suit. View "Savage v. Co-Part of Connecticut, Inc." on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to twenty-seven years' imprisonment for his convictions, holding that none of Defendant's claims raised in support of his request for a new trial mandated reversal of his convictions and sentence.Defendant was convicted of murder, four counts of wanton endangerment in the first degree, operating a motor vehicle while under the influence, and failure to give right-of-way to a stopped emergency vehicle. On appeal, Defendant did not challenge the sufficiency of the evidence presented by the Commonwealth but argued that the trial court made numerous errors with respect to three evidentiary rulings. The Supreme Court affirmed, holding that the trial court (1) did not err in its evidentiary rulings; (2) did not err by denying Defendant's motions to suppress; and (3) erred by forbidding Defendant from using proof of a statement of his, already admitted into evidence, to argue during closing argument that his intent was reckless at most, but the error was harmless. View "Burdette v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals denying Appellant's motion for a writ of mandamus against the circuit court, holding that there was no error in the proceedings below.In 1993, Appellant was convicted of 141 counts of first-degree sexual abuse and five counts of first-degree rape. In 2016, a panel of the court of appeals sanctioned Appellant in light of the fact that he had filed more than eighty-four appeals and original actions in an attempt to relitigate his convictions. This matter arose from Appellant's "Notice to Submit Documents to Support Motion for New Trial." After the circuit court denied the submission Appellant filed a petition for a writ of mandamus against the circuit court. The court of appeals dismissed the petition as frivolous, relying on its 2016 sanction order. The Supreme Court affirmed, holding (1) the court of appeals properly dismissed Appellant's appeal; and (2) the lower courts properly imposed sanctions on Appellant for his history of frivolous and vexatious appeals. View "Violett v. Grise" on Justia Law

The Supreme Court affirmed the decision of the court of appeals dissolving the circuit court's temporary injunction against two statutes that effectively prohibit abortions in Kentucky except in limited circumstances where it is necessary to preserve the life of the mother, holding that the circuit court abused its discretion in granting the temporary injunction.Plaintiffs, several abortion providers, filed for injunctive and declaratory relief against Ky. Rev. Stat. 311.772 and Ky. Rev. Stat. 311.7707-11, arguing that the bans contained in the statutes violated their patients' right to privacy under sections 1 and 2 of the Kentucky Constitution. The circuit court granted the temporary injunction. The court of appeals dissolved the temporary injunction against the bans. The Supreme Court affirmed, holding (1) Plaintiffs lacked third-party standing to challenge the statutes on behalf of their patients, but Plaintiffs did have first-party, constitutional standing to challenge one of the statutes on their own behalf; and (2) the court of appeals did not err in holding that the circuit court abused its discretion by granting the temporary injunction. View "Cameron v. EMW Women's Surgical Center, P.S.C." on Justia Law