Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court affirmed in part and vacated in part the judgment of the circuit court in this criminal case, holding that the case must be remanded for the trial court to consider whether Defendant's consent to a blood draw was voluntary under the totality of the circumstances.Defendant entered a conditional plea to one count of manslaughter in the first degree and one count of manslaughter in the second degree. The Supreme Court affirmed in part and vacated in part, holding that the trial court (1) did not err by failing to suppress Defendant's statements obtained without a Miranda warning; (2) erred in suppressing the results of Defendant's blood draw without determining whether her consent was voluntary where she received a warning that if she refused the blood test and were convicted of DUI, her mandatory minimum jail sentence would be doubled; and (3) did not err by failing to dismiss the case due to alleged abuse of the grand jury process. View "Haney v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the circuit court's entry of summary judgment in favor of Officer Ben Martin of the Georgetown Police Department on the grounds that he was entitled to qualified official immunity on Plaintiff's claims, holding that Officer Martin was not entitled to qualified immunity.Plaintiff brought this action against Officer Martin, alleging malicious prosecution, abuse of process, and defamation per se. The circuit court entered summary judgment in favor of Officer Martin, concluding that he was entitled to qualified official immunity. The court of appeals reversed, determining (1) under the circumstances, the trial court erred in granting summary judgment on the malicious prosecution claim; (2) as to the defamation claim, qualified official immunity was inapplicable; and (3) Plaintiff did not state a claim for abuse of process against Officer Martin. The Supreme Court affirmed, holding that the court of appeals properly concluded that remand for further proceedings was required. View "Martin v. Wallace" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the family court's holding that L.G. emotionally abused her son, holding that the family court was not clearly erroneous and did not abuse its discretion in finding that L.G. emotionally injured H.M., thus finding abuse and removing H.M. from L.G.'s custody.On appeal, L.G. argued that the trial court abused its discretion in finding emotional injury amounting to abuse. The court of appeals agreed and reversed. The Supreme Court reversed, holding (1) the court of appeals impermissibly substituted its own findings for the family court's and thus found an abuse of discretion; and (2) it was not unfair or unreasonable for the family court to conclude, based on substantial evidence, that H.M. was emotionally injured by L.G. View "Commonwealth v. L.G." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's motion for a writ of mandamus against the circuit court, holding that the court of appeals properly dismissed the appeal.In 1993, Defendant was convicted of 141 counts of first-degree sexual abuse and five counts of first-degree rape and sentenced to 754 years' imprisonment. The current matter arose from the trial court's denial of Defendant's pro se "Notice to Submit Documents to Support Motion for New Trial." Defendant requested a writ of mandamus challenging the denial. The court of appeals dismissed the petition as frivolous. The Supreme Court affirmed, holding that because Defendant did not timely appeal the denial of his motion for a new trial dismissal was the prescribed sanction. View "Violett v. Honorable Grise" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the trial court convicting Defendant of burglary in the first degree, rape in the first degree, kidnapping, violation of an EPO/DVO, and terroristic threatening, holding that the trial court erred in imposing Defendant's sentence.During penalty phase deliberations, Juror 8 informed the bailiff that she no longer wanted to deliberate. The judge excused the juror and told Defendant he could either waive his right to a twelve-person jury and allow an eleven-person jury to decide his sentence or allow the judge to make the sentencing decision. Defendant objected to eleven jurors, and so the judge decided the sentence. The Supreme Court affirmed Defendant's convictions but vacated his sentence, holding the trial court erred by failing to conduct a sufficiently searching inquiry to determine Juror 8's potential inability to be fair or impartial and then by excusing the juror. The Court remanded the case for a new penalty phase. View "Jerome v. Commonwealth" on Justia Law

In this appeal concerning the statutory ownership of a vehicle involved in a crash, the Supreme Court affirmed the court of appeals' decision affirming the order of the trial court granting summary judgment in favor of Central Motors, Inc., holding that the circuit court correctly held that Juan Garcia was the statutory owner of the vehicle at the time of the accident.Dolores Zepeda was the passenger in a 2002 BMW being driven by Darley Morales, the son of Juan Garcia, when Morales caused the car to crash in a single vehicle accident. As a result of the accident, Morales died and Zepeda was left paralyzed. Zepeda sued, among other defendants, Garcia for negligent entrustment and Central Motors as the purported statutory owner of the BMW. The trial court granted summary judgment for Central Motors, determining that Garcia, and not Central Motors, was the statutory owner of the vehicle at the time of the accident. The Supreme Court affirmed, holding that Central Motors substantially complied with Ky. Rev. Stat. 186A.220 and delivered possession of the vehicle pursuant to a bona fide sale, thus making Garcia the BMW's statutory owner. View "Zepeda v. Central Motors, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court dismissing Constance Mouanda's complaint against Jani-King International (Jani-King) and Cardinal Franchising, Inc. (Cardinal) alleging fraud, breach of contract, and unconscionability, holding that the trial court erred in granting Cardinal's and Jani-King's motion to dismiss.Mouanda formed The Matsoumou's LLC, for which Cardinal provided the necessary legal documents. The LLC entered into a franchise agreement with Cardinal and began operating as a unit franchisee. Mouanda later brought suit alleging fraud, breach of contract, and unconscionability and seeking damages for Cardinal and Jani-King's failure to comply with Kentucky's wage and hour laws. Cardinal and Jani-King moved to dismiss based on Mouanda's failure to bring the lawsuit on behalf of the LLC. The court of appeals affirmed. The Supreme Court reversed, holding that the franchise agreement contained nothing that would preclude a wage and hour claim by Mouanda individually and that the fraud claim was not dependent on the LLC being a party to the action. The Court remanded the case to allow the parties to develop the record so the trial court can determine whether Mouanda has a valid wage and hour claim and/or fraud claim. View "Mouanda v. Jani-King International" on Justia Law

The Supreme Court affirmed in part and reversed in part the opinion of the court of appeals affirming the judgment of the trial court finding Primal Vantage Company, Inc. liable for failure to warn and to instruct of the dangers associated with certain polypropylene straps and awarding substantial damages to Kevin and Sante O'Bryan, holding that the trial court abused its discretion.While Kevin was using a ladder stand manufactured by Primal Vantage that must be affixed to a tree to be used for hunting, the polypropylene straps securing the stand to the tree broke. The stand fell, resulting in Kevin sustaining serious injuries. A jury found Primal Vantage liable and awarded both Kevin and his wife damages. The Supreme Court reversed in part, holding that the trial court erred by abandoning its role as evidentiary gatekeeper and allowing the jury to hear substantial evidence regarding other injuries and accidents involving ladderstands, then declaring the evidence inadmissible, and failing to admonish the jury not to consider the inadmissible other-incidents evidence. View "Primal Vantage Co. v. O'Bryan" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree sodomy and sentencing him to twenty years in prison, holding that there was no error in the proceedings below.On appeal, Defendant argued that the trial court erred in failing to remove two jurors for cause during voir dire and committed a reversible error by allowing the Commonwealth to make an improper assertion about him during closing arguments. The Supreme Court affirmed, holding (1) the trial court's denial of Defendant's motion to strike the jurors was not an abuse of discretion; and (2) the prosecutor's statements during closing arguments were not reversible error. View "Robinson v. Commonwealth" on Justia Law

The Supreme Court vacated the decision of the court of appeals affirming the summary judgment and fees ordered by the trial court in favor of Defendants' right to direct payment of basic reparation benefits within an element of loss under Kentucky's Motor Vehicle Reparations Act, holding that this Court lacked subject matter jurisdiction over this appeal.Defendants were involved in a collision while in a vehicle insured by Erie Insurance Exchange. Erie filed a declaratory judgment action to determine whether it was required to pay bills within an element of loss in an order directed by secured persons. Defendants filed a counterclaim seeking attorney's fees and excess interest for the unreasonable delay of the payment of their bills caused by Erie. The trial court granted Defendants' motion for an attorney's fee and denied Erie's second summary judgment motion, but did not indicate in its order that it granted Defendants' motion for summary judgment. The court of appeals affirmed. The Supreme Court vacated the order below, holding that no final and appealable orders were before the Court, and therefore, this Court lacked jurisdiction over the appeal. View "Erie Insurance Exchange v. Johnson" on Justia Law