Justia Kentucky Supreme Court Opinion Summaries

Dillian Ford was sentenced to fifteen years in prison and ordered to pay $10,972 in jail fees for the 422 days he was held in custody. The jail fees were imposed based on a stipulation that Carlisle County would pay McCracken County twenty-six dollars a day for housing inmates. Ford challenged the imposition of these fees, arguing that there was no evidence of a jail reimbursement policy adopted by the county jailer with the approval of the county's governing body, as required by KRS 441.265(2)(a).The Carlisle Circuit Court imposed the jail fees based on the stipulation. Ford appealed, and the Kentucky Court of Appeals affirmed the imposition of the fees. Ford then sought discretionary review from the Supreme Court of Kentucky, arguing both the lack of evidence for the jail fees and a new argument regarding an amendment to KRS 441.265(1)(a) that he claimed removed the trial court's authority to impose jail fees.The Supreme Court of Kentucky reviewed the case and found that the stipulation regarding the agreement between Carlisle and McCracken counties did not meet the evidentiary burden required by Capstraw v. Commonwealth. The Court held that there was no evidence in the record of a jail reimbursement policy adopted by the county jailer with the approval of the county's governing body. Therefore, the imposition of jail fees was not justified. The Court vacated the portion of Ford's sentence imposing the jail fees but did not address the validity of the fifteen-year sentence for the underlying convictions. The Court of Appeals' decision was reversed. View "Ford v. Commonwealth" on Justia Law

Louisville/Jefferson County Metro Government (LJCMG) entered into a contract with Omni Louisville, LLC (Omni) in 2014, which included the demolition of Liberty Hall. In 2019, the Metro Council directed the Historic Landmarks and Preservation Districts Commission to review Liberty Hall for landmark status. Despite the Commission's vote to designate Liberty Hall as a landmark, the Metro Council overturned this decision in 2021, citing various reasons including the building's association with racism and lack of architectural significance.The Louisville Historical League, Inc. (LHL) sought review in the Jefferson Circuit Court, which found that the Metro Council had violated procedural due process, concluding that the decision was predetermined due to the 2014 contract with Omni. The court held that the hearing was a pretext and that the decision was tainted by blatant favoritism and conflict of interest.The Kentucky Court of Appeals addressed the issue of jurisdiction, concluding that LHL failed to allege particularized injury or aggrievement, thus depriving the circuit court of subject matter jurisdiction. The Court of Appeals held that strict compliance with statutory requirements was necessary for jurisdiction.The Supreme Court of Kentucky reversed the Court of Appeals, clarifying that the requirement to plead particularized injury or aggrievement pertains to particular-case jurisdiction, not subject matter jurisdiction. The Court held that the judiciary has inherent constitutional authority to review administrative decisions for arbitrariness, and compliance with statutory requirements affects particular-case jurisdiction. The Court also reversed the Jefferson Circuit Court's conclusion of procedural due process violations, affirming the Metro Council's decision to overturn the landmark designation of Liberty Hall. View "Louisville Historical League, Inc. v. Louisville/Jefferson County Metro Government" on Justia Law

Melzena Moore pled guilty to first-degree manslaughter of Raymond Jackson under extreme emotional disturbance (EED) as part of a plea agreement. The issue on appeal is whether the Laurel Circuit Court erred in denying Moore the domestic violence exemption to the mandatory minimum sentence for parole eligibility. This exemption would allow Moore to be considered for parole after serving 20% of her eighteen-year sentence and qualify her for counseling and rehabilitation programs.The Laurel Circuit Court found that Moore was a victim of domestic violence based on a single corroborated incident but concluded that her shooting of Jackson did not occur "with regard to" the domestic violence. The court denied Moore the exemption, citing a lack of corroborating evidence for her account of the events leading up to the shooting and questioning her credibility. The Court of Appeals reversed this decision, instructing the trial court to grant the exemption, arguing that the trial court failed to properly apply the "some connection" standard and did not adequately consider the expert testimony provided by Moore.The Supreme Court of Kentucky reviewed the case and determined that the trial court erred in its analysis by not making sufficient factual findings regarding the totality of the evidence of domestic violence. The court emphasized that the "some connection" standard does not require a direct causal link or contemporaneous act of domestic violence. The Supreme Court vacated the trial court's order and remanded the case for further factual findings and proper application of the legal standard to determine if Moore qualifies for the domestic violence exemption. View "Commonwealth v. Moore" on Justia Law

Kimberly Deramos lived in an apartment complex owned by Anderson Communities. While returning from a walk with her Shih Tzu, Princess, they were attacked by a pit bull allegedly owned by a neighboring tenant. Princess died, and Deramos sustained injuries requiring surgery and counseling. Deramos sued Anderson Communities, claiming they negligently failed to maintain a safe environment for tenants.The Jefferson Circuit Court granted Anderson Communities' motion to dismiss for failure to state a claim, relying on the strict liability dog-bite rule in Kentucky Revised Statute (KRS) 258.235(4). The court concluded that Anderson Communities was not an "owner" under KRS 258.095(5) and thus could not be held strictly liable. Deramos did not cite this statute in her complaint but instead alleged general negligence. The Court of Appeals affirmed the dismissal, agreeing that Anderson Communities was not an "owner" under the statute and did not address Deramos's negligence claim.The Supreme Court of Kentucky reviewed the case and reversed the lower courts' decisions. The court held that the strict liability dog-bite statute was inapplicable to Deramos's negligence claim. The court emphasized that negligence and strict liability are distinct legal concepts, and Deramos's complaint sufficiently alleged negligence. The court concluded that the circuit court erred in dismissing the negligence claim based on strict liability principles. The case was remanded to the Jefferson Circuit Court for further proceedings consistent with the opinion. View "Deramos v. Anderson Communities, Inc." on Justia Law

Ryan Roberts and Briana Gebell are the biological parents of a child born in January 2016. In August 2016, the Cabinet for Health and Family Services filed a dependency, neglect, and abuse (DNA) petition against both parents due to Mother’s mental health issues and criminal charges, and Father’s substance abuse. The Bracken District Court placed the child in the temporary custody of Debbie and Nick Appleman, Father’s paternal cousins. After several incidents involving Father’s substance abuse and criminal behavior, the district court granted full custody of the child to the Applemans in July 2019.Mother filed a motion in June 2021 in the Bracken Circuit Court to regain custody or obtain visitation. The circuit court granted her supervised visitation, which was later changed to unsupervised visitation. In December 2022, Mother sought sole custody, but the circuit court denied her request, finding that she had waived her superior right to custody by being absent for most of the child’s life and that continued custody with the Applemans was in the child’s best interest.The Kentucky Court of Appeals reversed the circuit court’s decision, concluding that the record did not support a finding of waiver. The Applemans did not participate in the appeal. The Supreme Court of Kentucky reviewed the case and affirmed the Court of Appeals in part, agreeing that the Applemans needed to demonstrate Mother’s unfitness or waiver of her superior rights. However, the Supreme Court reversed the part of the decision that granted immediate custody to Mother, remanding the case for further proceedings to apply the correct legal standard in determining custody. View "APPLEMAN V. GEBELL" on Justia Law

Buford and Sharon Combs executed a joint will in 2013, intending to distribute their estate equally among their five children from previous marriages. Buford died in October 2020, and Sharon died in January 2021. Most of their assets were held jointly with right of survivorship, and Buford's estate was small enough to dispense with administration. Sharon's sons were initially appointed as co-administrators, but Greg Combs later filed a motion to probate the joint will as a lost will, which was granted by the Jackson District Court.The Napier brothers filed a declaratory judgment action, arguing that the joint will's provisions only took effect if Buford and Sharon died in a common disaster or close in time, which did not occur. They claimed Sharon died intestate, entitling them to inherit all property. The Combs siblings argued the couple intended to divide the estate equally among all five children and sought to reform the will to remove the qualifying clause.The Jackson Circuit Court granted summary judgment in favor of the Combs siblings, interpreting the will to distribute the estate equally among the children. The Court of Appeals reversed, holding that the will was unambiguous and extrinsic evidence was inadmissible. They concluded Sharon died intestate as the conditions in the will were not met.The Supreme Court of Kentucky reviewed the case and reversed the Court of Appeals. The court held that the presumption against intestacy and the impracticality of administering separate estates supported the interpretation that the estate should be divided equally among the five children. The court reinstated the Jackson Circuit Court's summary judgment. View "COMBS V. NAPIER" on Justia Law

Joseph Lee, a Louisiana resident, sought workers’ compensation benefits for injuries sustained in a motorcycle accident during nonworking hours while employed at a construction project in Maysville, Kentucky. Lee was hired by W.G. Yates & Sons Construction Co. (Yates) and temporarily moved to a campground in Ohio near the job site. He was paid a daily per diem but not reimbursed for travel or housing expenses. The accident occurred when Lee was riding his motorcycle to meet a friend for dinner before his night shift.The Administrative Law Judge (ALJ) determined that Lee’s injuries did not occur within the course and scope of his employment, applying the “coming-and-going” rule. The Workers’ Compensation Board (Board) affirmed the ALJ’s decision. Lee appealed, and the Court of Appeals reversed the Board’s decision by a 2-1 vote, finding that Lee’s injuries fell under the “traveling-employee” exception to the “coming-and-going” rule, as his presence in Kentucky was for the benefit of Yates.The Supreme Court of Kentucky reviewed the case and reversed the Court of Appeals’ decision, affirming the Board’s determination. The Court held that Lee was not a “traveling employee” at the time of the accident, as his job did not require travel once he relocated to the job site. The Court also found that Lee’s motorcycle ride to a restaurant was not in furtherance of his employer’s business interests and did not fall under the “service to the employer” exception. Therefore, Lee’s injuries were not compensable under workers’ compensation. View "W.G. YATES & SONS CONSTRUCTION CO. V. HARVEY" on Justia Law

In 2016, Thomas Raider was arrested and charged with multiple drug offenses. He was granted monitored conditional release but failed to comply with its terms, leading to his re-arrest. In 2017, Raider entered a plea agreement that included participation in Drug Court as a condition of his pretrial diversion. Despite multiple sanctions for noncompliance, Raider ultimately absconded from the program and was terminated from Drug Court in 2018. In 2022, after being taken into custody on new charges, the trial court initiated revocation proceedings for Raider's pretrial diversion without a motion from the Commonwealth.The Estill Circuit Court revoked Raider's pretrial diversion and sentenced him to five years in prison, as per his plea agreement. Raider appealed, and the Kentucky Court of Appeals reversed the trial court's decision, holding that the Commonwealth must file a motion to revoke pretrial diversion before the trial court can act.The Supreme Court of Kentucky reviewed the case to determine whether a trial court can revoke pretrial diversion on its own initiative. The Court held that Kentucky Revised Statutes (KRS) 533.256 does not require the Commonwealth to file a motion before a trial court can revoke pretrial diversion. The Court emphasized that the trial court has the authority to notice, schedule, and conduct hearings to revoke diversion if a defendant fails to comply with the conditions of the diversion agreement. The Supreme Court of Kentucky reversed the Court of Appeals' decision and affirmed the Estill Circuit Court's revocation of Raider's pretrial diversion and subsequent sentencing. View "COMMONWEALTH OF KENTUCKY V. RAIDER" on Justia Law

In November 2020, John Ray Williams was convicted in Graves Circuit Court for first-degree sexual abuse of his granddaughter, L.W. Shortly after his conviction, Williams sent a postcard to Leslie, his former daughter-in-law and a key witness in his trial, which contained her birth date and social security number, and included a message that Leslie found threatening. Williams was subsequently charged with retaliating against a participant in the legal process and being a first-degree persistent felony offender.The Graves Circuit Court jury found Williams guilty on both charges and recommended the maximum sentence of twenty years, which the trial court imposed. Williams appealed, arguing that the trial court erred in allowing the jury to be informed of his prior sexual abuse conviction and that he was entitled to a directed verdict on the retaliation charge.The Supreme Court of Kentucky reviewed the case and affirmed the lower court's decision. The court held that the evidence of Williams' prior conviction was admissible under Kentucky Rules of Evidence (KRE) 404(b) because it was relevant to proving his retaliatory intent and was more probative than prejudicial. The court also found that the jury instructions were sufficient and that Williams' conduct threatened damage to Leslie's tangible property, satisfying the statutory requirements for a retaliation conviction. The court concluded that Williams was not entitled to a directed verdict and upheld his conviction and sentence. View "WILLIAMS V. COMMONWEALTH OF KENTUCKY" on Justia Law

In 2022, the Kentucky General Assembly enacted Senate Bill 1 (S.B. 1), which restructured the relationship between the Jefferson County Board of Education and its superintendent. The bill required the Board to delegate day-to-day operations to the superintendent, limited the Board's meeting frequency, and granted the superintendent additional administrative powers. The Jefferson County Board of Education filed a declaratory judgment action, claiming S.B. 1 violated Sections 59 and 60 of the Kentucky Constitution, which prohibit local or special legislation.The Jefferson Circuit Court ruled in favor of the Board, declaring S.B. 1 unconstitutional. The court found that the bill effectively applied only to Jefferson County, thus constituting impermissible local legislation. The court also ruled, sua sponte, that S.B. 1 violated the equal protection rights of Jefferson County residents. The Kentucky Court of Appeals affirmed the trial court's decision on the grounds of Section 59 but did not address the equal protection ruling.The Supreme Court of Kentucky reviewed the case and reversed the Court of Appeals' decision. The Supreme Court held that S.B. 1 did not violate Sections 59 and 60 of the Kentucky Constitution. The Court reasoned that the bill's language created an open classification applicable to any county with a consolidated local government, not just Jefferson County. The Court also found that the Board had standing to challenge the bill and that the superintendent was not a necessary party to the action. The Court declined to address the equal protection issue, as it was not properly raised or developed in the lower courts. View "COLEMAN V. JEFFERSON COUNTY BOARD OF EDUCATION" on Justia Law