Justia Kentucky Supreme Court Opinion Summaries

A non-profit religious organization sought to build an outdoor grotto, including a shrine, plaza, and walking path, on land adjacent to its existing church property. The new grotto was planned for a parcel subject to a lease and eventual transfer to the organization. The property was zoned for residential use, and while the church itself predated the zoning ordinance, the construction of accessory religious structures was not directly permitted under the current ordinance unless the church was located adjacent to an arterial street. The organization’s application acknowledged this restriction but requested approval for the project and setback variances.The Park Hills Board of Adjustment held a public hearing, received input both for and against the project, and ultimately approved the conditional use permit and variances, conditioned on the property transfer. Neighbors opposed to the project, specifically the Frederics, challenged the Board’s decision in the Kenton Circuit Court, arguing that the Board exceeded its authority under local ordinances and state law. The circuit court ruled in favor of the defendants, finding that the church was “grandfathered” due to its pre-zoning existence and that the Board did not act arbitrarily. The court did not address the federal Religious Land Use and Institutionalized Persons Act (RLUIPA) claim raised during summary judgment.On appeal, the Kentucky Court of Appeals reversed, holding the Board acted arbitrarily and exceeded its authority, as the expansion constituted an impermissible enlargement of a nonconforming use under both the zoning code and state law. The court also found no RLUIPA violation, reasoning that the ordinance did not impose a substantial burden on religious exercise.The Supreme Court of Kentucky granted discretionary review. The Court held that the RLUIPA defense was properly before it, as it had been tried by implied consent of the parties. On the merits, the Court concluded that denial of the permit did not impose a substantial burden under RLUIPA, applying the Sixth Circuit’s standard. The Court also found that the zoning ordinance did not violate RLUIPA’s equal-terms provision. The Court affirmed the Court of Appeals’ ruling, vacating the Board’s grant of the permit and variances. View "MISSIONARIES OF SAINT JOHN THE BAPTIST, INC. V. FREDERIC" on Justia Law

A recently enacted statute in Kentucky, Senate Bill 1 (SB 1), altered the governance structure of only the Jefferson County public school district by granting its superintendent increased authority and reducing the powers of its school board. The law also imposed unique restrictions on the Jefferson County Board of Education, such as limiting meeting frequency and permitting unilateral actions by the superintendent not available in other districts. No other public school district in Kentucky was subject to these new terms, and the law did not provide an explanation for this differential treatment or why such governance changes would be unsuitable for other districts.The Jefferson County Board of Education challenged SB 1, alleging that it violated Section 59 of the Kentucky Constitution, which prohibits special or local legislation regarding the management of public schools unless justified by a reasonable basis. The Jefferson Circuit Court reviewed the challenge and found that SB 1 was unconstitutional because it conferred disparate treatment on Jefferson County without a rational or natural distinction justifying the law’s limitation to that district. The Kentucky Court of Appeals affirmed the trial court’s decision, agreeing that the law amounted to impermissible special legislation.The Supreme Court of Kentucky reviewed the appeal and affirmed the lower courts’ rulings. The court held that SB 1 violates Section 59 of the Kentucky Constitution because it treats Jefferson County’s school district and its superintendent differently from all others without any reasonably articulable natural and distinctive reason. The court clarified that while the legislature may address specific local needs through classification, such distinctions must be reasonable and related to legislative objectives. The court’s disposition was to affirm the judgments that found SB 1 unconstitutional. View "COLEMAN V. JEFFERSON COUNTY BOARD OF EDUCATION" on Justia Law

A firefighter employed by a city filed a legal action seeking a declaration that a city ordinance requiring firefighters to live within a certain distance of a fire station was invalid. He argued that state law, specifically KRS 311A.027(1), prohibits publicly funded emergency medical service first response providers from imposing residency requirements on employees or volunteers, and that the city's firefighters, who are certified to provide emergency medical services, fall within this category.The McCracken Circuit Court granted summary judgment in favor of the city, holding that the statute in question was not intended to apply to firefighters, but rather to those whose primary duties are as emergency medical service first response providers. The trial court reasoned that firefighters are primarily governed by a different chapter of Kentucky law, which does not prohibit residency requirements. The Kentucky Court of Appeals affirmed this decision, agreeing with the trial court’s interpretation and analysis.On discretionary review, the Supreme Court of Kentucky examined whether the statute applies to the city’s fire department and its personnel. The Court held that KRS 311A.027(1) applies to institutions, not individuals, and that the term “emergency medical service first response provider” as used in the statute refers to entities that provide ambulance services and are regulated as such under Kentucky law. Because the city’s fire department does not operate ambulances or provide ambulance services, it is not an emergency medical service first response provider within the meaning of the statute. Therefore, the residency ordinance is not preempted by KRS 311A.027(1). The Supreme Court of Kentucky affirmed the decision of the Court of Appeals. View "TORIAN V. CITY OF PADUCAH, KENTUCKY" on Justia Law

A mechanical maintenance technician employed at a steel manufacturing facility contracted COVID-19 in August 2021, which ultimately led to his death following a double lung transplant and subsequent infection. The employee worked closely with a single partner during long shifts, and both were unvaccinated, sometimes failing to comply with company mask policies. The employee’s family and estate filed a workers’ compensation claim, alleging that his work conditions placed him at a greater risk of contracting COVID-19 than the general public. Evidence included testimony about his work environment, social activities, and the timeline of symptom onset.An Administrative Law Judge (ALJ) reviewed the claim and found that the estate failed to prove the employee’s exposure to COVID-19 at work was greater than that of the general public, or that his work increased his risk of contracting or exacerbating the disease. The ALJ dismissed the claim, concluding that the statutory requirements for an occupational disease under Kentucky law were not met. The Workers’ Compensation Board affirmed the ALJ’s findings, as did the Kentucky Court of Appeals, both determining that substantial evidence supported the denial of benefits and that the ALJ had not misapplied the law.The Supreme Court of Kentucky reviewed the case and affirmed the Court of Appeals’ decision. The Court held that, for a communicable disease like COVID-19 to be compensable under workers’ compensation, the claimant must prove the disease was work-related, that the nature of the employment increased the risk of contracting the disease compared to the general public, and that the injury exceeded the normal effects of such a disease. The Court found the estate did not meet its burden of proof on the threshold issue of work-related causation and affirmed the dismissal of the claim. View "ESTATE OF PERKINS V. NORTH AMERICAN STAINLESS" on Justia Law

An employee worked for over sixteen years as a shuttle car operator for a coal company, primarily in Kentucky, where he was regularly exposed to hazardous noise. After the Kentucky mine closed, he continued working for the same employer in Alabama for nine months before retiring. The employee began experiencing hearing difficulties before leaving Kentucky, and was later diagnosed with work-related hearing loss. He filed a workers’ compensation claim in Kentucky, listing his last day of work in Kentucky as the date of last exposure.The Administrative Law Judge (ALJ) dismissed the employee’s claim for coal workers’ pneumoconiosis but granted his hearing loss claim, finding that the injury occurred on his last day working in Kentucky. The ALJ relied on medical testimony indicating that the short period of exposure in Alabama was inconsequential to the hearing loss, and applied Kentucky Revised Statute (KRS) 342.7305(4), which presumes liability for the employer with whom the employee was last injuriously exposed to hazardous noise for at least one year. The Workers’ Compensation Board affirmed, concluding that Kentucky had jurisdiction and that the injury manifested while the employee was still working in Kentucky. The Kentucky Court of Appeals also affirmed, holding that extraterritorial coverage statutes did not apply because the injury occurred in Kentucky.The Supreme Court of Kentucky affirmed the Court of Appeals’ decision. The Court held that, under the amended KRS 342.7305(4), the date of injury for liability purposes is when the employee was last injuriously exposed to hazardous noise for at least one year with the employer, here in Kentucky. The Court concluded that Kentucky had jurisdiction over the claim and that the insurer covering the employer on that date was liable. View "KENTUCKY EMPLOYERS' MUTUAL INSURANCE V. CLAS COAL CO., INC." on Justia Law

A retired teacher who continued to work as a substitute until 2014 filed a workers’ compensation claim in 2015, alleging he developed mesothelioma from asbestos exposure during his employment with a county school board. Initially, he identified his last exposure as occurring during his full-time employment, which ended in 2003, and named Kentucky Employers’ Mutual Insurance (KEMI) as the insurer. Later, the Administrative Law Judge (ALJ) determined that the last injurious exposure actually occurred in 2014, when the teacher stopped substitute teaching, which would make Encova Mutual Insurance Group the responsible carrier for the claim.After the ALJ’s finding, KEMI sought to have Encova certified as the responsible insurer, but the ALJ denied the motion as untimely and questioned his authority to resolve the issue. The Workers’ Compensation Board (WCB) affirmed the denial, but on the ground that neither KEMI nor Encova had standing, as neither had been formally joined as parties. The Kentucky Court of Appeals reversed, holding that the ALJ and WCB had the authority and obligation under the Workers’ Compensation Act to determine and certify the proper insurance carrier, even after a change in the last date of exposure.The Supreme Court of Kentucky affirmed the Court of Appeals. It held that the ALJ and WCB have statutory authority to determine which insurer is responsible for payment of benefits when the last date of injurious exposure changes, and that insurers have standing to participate in such proceedings. The Court further held that the Act binds the insurer on the risk at the time of last exposure, regardless of notice or formal joinder, and that equitable defenses such as laches or estoppel do not bar certification in these circumstances. The case was remanded for proceedings consistent with this opinion. View "ENCOVA MUTUAL INSURANCE GROUP V. HALL" on Justia Law

The appellant, a Marine Corps veteran with significant psychiatric disabilities, lived in Knox County, Kentucky, with his children and sister’s family. After separating from his wife, they began to reconcile, and he arranged to lease a second trailer, allegedly through an oral agreement with his landlord. An acquaintance, Deborah Powers, stayed in the trailer, but she claimed to have leased it with her boyfriend, Matthew Welsh. One night, after a party at the trailer, the appellant’s wife alleged she was raped by three men present. Instead of contacting police, the appellant, accompanied by two others, returned to the trailer armed, forcibly entered, and subjected the alleged assailants to threats, violence, and torture. During the confrontation, Welsh stabbed the appellant, who then fatally stabbed Welsh. The appellant was charged with murder, first-degree burglary, and four counts of unlawful imprisonment.The Knox Circuit Court conducted the trial. The appellant’s requests for self-defense and imperfect self-defense jury instructions were denied. The court admitted hearsay testimony regarding a rape kit and allowed a copy of a lease to be introduced over objections concerning the best evidence rule and authenticity. The appellant’s motion for his counsel to withdraw was also denied. The jury convicted him on all charges, and he was sentenced to thirty-five years in prison.The Supreme Court of Kentucky reviewed the case. It held that the trial court did not abuse its discretion in refusing self-defense instructions, as the appellant’s own actions created the deadly situation. The court found no palpable error in the admission of the rape kit testimony, as the error did not substantially affect the defense. However, it concluded that admitting the copy of the lease without proper foundation was an abuse of discretion, requiring reversal of the burglary conviction. The court affirmed the murder and unlawful imprisonment convictions and the overall sentence, remanding for amendment of the judgment to reflect the reversal of the burglary conviction. View "MASTERS V. COMMONWEALTH OF KENTUCKY" on Justia Law

A Kentucky resident purchased a firearm from a local pawn shop and, shortly after, suffered severe injuries when the gun allegedly discharged unexpectedly while the safety was engaged. The gun had been manufactured by a Utah-based company, which sold it to a Texas distributor. The distributor then sold the firearm to a Kentucky merchant, and it eventually reached the plaintiff through a Kentucky pawn shop. The injured party filed a products liability lawsuit in Fayette Circuit Court against both the manufacturer and the pawn shop, alleging the manufacturer’s product caused his injuries.The Fayette Circuit Court initially held the manufacturer’s motion to dismiss for lack of personal jurisdiction in abeyance to allow for limited discovery. However, the manufacturer failed to timely respond to discovery requests, only providing responses after being compelled by court order and after significant delay. Despite this, the trial court granted the manufacturer’s motion to dismiss, finding that the manufacturer had not purposefully availed itself of doing business in Kentucky and that exercising personal jurisdiction would not comport with due process. The Kentucky Court of Appeals affirmed the dismissal, agreeing that due process would be offended, though it found the manufacturer fell within the state’s long-arm statute due to deriving substantial revenue from Kentucky sales.The Supreme Court of Kentucky reviewed the case and held that the evidence was sufficient to show the manufacturer derived substantial revenue from sales in Kentucky and that the plaintiff’s claims arose from those sales, thus satisfying the long-arm statute. However, the Court determined that the manufacturer’s failure to comply with discovery obligations deprived the plaintiff of an adequate opportunity to conduct jurisdictional discovery. The Court reversed the dismissal in part and remanded the case to the Fayette Circuit Court, instructing it to allow the plaintiff ample opportunity to complete jurisdictional discovery before ruling on personal jurisdiction. View "BRAUN V. BEARMAN INDUSTRIES, LLC" on Justia Law

After the owners of a parcel of real property in Manchester, Kentucky, died, no one paid the property taxes, resulting in the issuance of multiple certificates of delinquency for unpaid taxes. Clay County sold the 2011 and 2012 tax liens to third parties: the 2011 lien was eventually assigned to Keith and Jessica Smith, and the 2012 lien was purchased by Apex Fund Services. The Smiths recorded their lien before Apex recorded its own. Both the Smiths and Apex sought to enforce their liens, and Apex initiated a foreclosure action in Clay Circuit Court, naming all lienholders and heirs as defendants. The property was ultimately sold at a master commissioner’s auction, with the Smiths purchasing it for $2,500.The Clay Circuit Court initially ruled that the Smiths’ lien had priority because it was recorded first, applying the “first in time, first in right” doctrine. The court allowed the Smiths to receive a credit against the purchase price for the amount owed to them under their lien, plus costs and attorney fees. Apex appealed, and the Kentucky Court of Appeals reversed, holding that all tax liens were of equal rank and that the proceeds from the sale should be distributed pro rata among all tax lienholders, including the county.The Supreme Court of Kentucky affirmed the Court of Appeals’ decision. The Court held that, under Kentucky statutes, tax liens held by the state, county, city, or third-party purchasers are of equal rank and are not subject to the common law “first in time, first in right” rule. Instead, when the proceeds from a foreclosure sale are insufficient to pay all tax liens and associated costs, the proceeds must be distributed pro rata among all tax lienholders. The case was remanded for the circuit court to determine the amounts owed and to distribute the proceeds accordingly. View "SMITH V. APEX FUND SERVICES AS CUSTODIAN FOR CERES TAX RECEIVABLES, LLC" on Justia Law

Two individuals, Brandon Waddles and his three-year-old daughter, were killed in their home. The prosecution alleged that the defendant orchestrated the crime by having his girlfriend lure Waddles to the door, after which the defendant, driven to the scene by another accomplice, shot both victims. The defendant was indicted on two counts of murder, first-degree burglary, and being a felon in possession of a handgun. The prosecution’s case relied heavily on the testimony of the accomplices, both of whom had entered plea agreements in exchange for their cooperation.The case was tried in the Jefferson Circuit Court. During the trial, after one accomplice testified, the trial judge, outside the jury’s presence but in front of the media, ordered the witness taken into custody for perjury, stating that the witness had lied under oath. This event was reported by the media, and a juror saw the report, subsequently informing the rest of the jury. During deliberations, a juror reported being unable to decide the case truthfully after learning of the arrest. The defense moved for a mistrial, but the trial court denied the motion, instead excusing one juror and instructing the remaining jurors to disregard the information. The jury ultimately convicted the defendant of both murders and burglary, and he was sentenced to life without parole.On appeal, the Supreme Court of Kentucky held that the trial court erred by not granting a mistrial after the jury became aware that a key prosecution witness had been arrested for perjury at the judge’s direction. The court found that this extrajudicial information tainted the jury and constituted a structural error, depriving the defendant of a fair and impartial trial. The court vacated the convictions and remanded the case for further proceedings. View "LAWLESS V. COMMONWEALTH OF KENTUCKY" on Justia Law