Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals reversing Defendant's convictions for theft of identity and being a persistent felony offender in the first degree, holding that the court of appeals erred in holding that giving a peace officer false information is not a lesser-included offense of theft of identity.On appeal, the court of appeals concluded that the trial court erred by failing to instruct the jury on the misdemeanor offense of giving a peace officer false identifying information as a lesser-included offense to the theft of identity charge and reversed as to that conviction. The Supreme Court reversed, holding that the trial court acted properly and did not abuse its discretion when it chose not to give jury instructions on a lesser, not-included offense. View "Commonwealth v. Boone" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus directing the circuit court to dismiss the underlying circuit court action filed by three sisters (Sisters), holding that the circuit court correctly denied the writ.The Sisters, daughters of Elbert Goff Sr., brought the underlying complaint against, among others, Appellant, individually and in her capacity as the personal representative of Elbert's Estate, alleging that Appellant breached her fiduciary duties to Elbert before he died through self-dealing. The circuit court denied Appellant's ensuing motion to dismiss. Appellant petitioned the court of appeals for a writ of mandamus directing the circuit court to dismiss the Sisters' complaint, but the court of appeals denied the request. The Supreme Court affirmed, holding (1) the circuit court had subject-matter jurisdiction in this case; and (2) an appellate remedy was available, and great injustice and irreparable injury will not be suffered by Appellant. View "Goff v. Honorable Edwards" on Justia Law

The Supreme Court affirmed the order of the court of appeals denying a motion for writs of prohibition and mandamus, holding that there was no error.In the underlying medical negligence action, Petitioners filed a petition seeking a writ of prohibition in the court of appeals to prohibit the enforcement of a circuit court order directing them to provide Norton Healthcare with nine years of Facebook data. Alternatively, Petitioners sought a writ of mandamus directing the circuit court to enter a more constrained discovery order. The court of appeals denied the motion for writs of prohibition and mandamus. The Supreme Court affirmed, holding that Petitioners' series of general objections were without merit, and therefore, the court of appeals did not err in denying the writ. View "Leslie-Johnson v. Hon. Audra Eckerle" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that Claimant's claim for disability benefits was not barred by res judicata and that the Workers' Compensation Board misconstrued the reopening statute, Ky. Rev. Stat. 342.125(1)(d) and (2), holding that the court of appeals did not err.In 2017, Claimant received a work-related injury, and an administrative law judge (ALJ) awarded her temporary total disability benefits. In 2019, Claimant alleged a worsening of her condition, and her claim was reopened pursuant to section 342.125(1)(d). An ALJ awarded Claimant permanent partial disability benefits and future medical benefits. The Board reversed, holding that the ALJ's original decision was supported by substantial evidence and therefore was res judicata. The court of appeals reversed, concluding that the Board misconstrued section 342.125 and erred in its res judicata analysis. The Supreme Court affirmed, holding that nothing in the plain language of section 342.125 precludes reopening of a temporary disability award. View "Lakshmi Narayan Hospitality Group Louisville v. Jimenez" on Justia Law

The Supreme Court reversed the decision of the court of appeals for failing as a reviewing court to give proper deference to the trial court's decision to deny Appellees leave to amend a pleading and held that the court erred when it found that the district court lacked jurisdiction to probate the will at issue in this action.Plaintiff filed this action challenging the validity of the decedent's will and asserting claims of undue influence and breach of fiduciary duty by Defendants and requesting a declaration that the will was invalid. After Plaintiff settled his claims with some of the defendants, defendant Suzanne McGaha filed a motion for leave to amend her answer and to assert cross-claims and certain objections. The district court overruled the motion. The court of appeals reversed. The Supreme Court reversed, holding (1) the court of appeals erred in concluding that the district court lacked jurisdiction over the probate matter because of an alleged defect with verification of the probate petition; and (2) the circuit court did not abuse its discretion by denying Suzanne's motion for leave to amend her answer to assert cross-claims. View "McGaha v. McGaha" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to twenty years' imprisonment for his convictions of two counts of manslaughter in the second degree, driving under the influence of controlled substances first offense, and persistent felony offender first degree, holding that Defendant's claims of error did not warrant reversal.Specifically, the Supreme Court held (1) the trial court was correct in declining to suppress Defendant's statements statements he made at the accident scene, and suppression of Defendant's blood test was not required in this case; (2) the trial court did not err in excusing a prospective juror for cause; and (3) while certain statements were not properly admissible during the Commonwealth's examination of detective Brandon McPherson, they did not rise to the level of palpable error resulting in manifest injustice. View "Simpson v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the circuit court denying Defendant a directed verdict on the charge against her of unlawful access to a computer in the first-degree, holding that Ky. Rev. Stat. 434.840(9)(d) refers to a computer-related purpose.At issue was whether Defendant's act of exchanging the barcodes on two items she purchased with barcodes on two less expensive items and then using the self-scanner at Walmart to purchase the two more expensive items for less than what she should have paid based on the prices at which the items were offered for sale justified conviction for unlawful access to a computer in the first degree. The Supreme Court affirmed the circuit court's denial of a directed verdict on the unlawful access to a computer charge, holding that the term "purpose" in section 434.840(9)(d) refers to an unauthorized computer-related purpose, rather than a broader fraudulent purpose. View "Commonwealth v. Shirley" on Justia Law

The Supreme Court reversed the decisions of the circuit court and court of appeals affirming the judgment of the Kentucky Labor Cabinet finding that because no union business privilege exists in the Commonwealth, the Louisville Metro Police Department (LMPD) did not engage in an unfair labor practice under the circumstances of this case, holding that the lower courts erred.The River City Fraternal Order of Police Lodge No. 614, Inc. (FOP) brought an unfair labor practice claim against the Louisville-Jefferson County Metro Government (Louisville Metro) alleging that the LMPD engaged in an unfair labor practice by coercing the FOP President to reveal communications he had with a sergeant that the FOP asserted were protected by a "union business privilege." The Labor Cabinet concluded that Kentucky does not recognize a union business privilege and therefore entered judgment for the LMPD. The circuit court and court of appeals affirmed. The Supreme Court reversed, holding that Louisville committed an unfair labor practice when it compelled the FOP President to disclose the substance of his conversation with the sergeant. View "River City Fraternal Order of Police Lodge No. 614, Inc. v. Louisville/Jefferson County Metro Government" on Justia Law

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