Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the determination of the circuit court that the security agreement between Harvey Haynes, the debtor, covered future advances made by Farmers Tobacco Warehouse (Farmers) so as to have priority over the security interest claimed by Versailles Farm Home and Garden, LLC (Versailles) in Haynes' 2013 tobacco crop, holding that there was no error.In 2014, Versailles brought this action against Haynes to collect on the balance due under the agreement. Versailles joined Farmers as a party to assert its claim against Farmers for conversion to the extent Farmers retained any proceeds in excess of the amount Haynes owed. Farmers admitted selling a portion of Haynes' 2013 tobacco crop and retaining the proceeds but denied doing so in violation of Versailles' security interest. The trial court granted Versailles' motion for summary judgment against Haynes and then granted Farmers' motion for summary judgment as to its cross-claim against Haynes asserting a first and superior lien in Haynes' 2013 tobacco crop. The Supreme Court affirmed, holding that the trial court did not err. View "Versailles Farm Home & Garden, LLC v. Haynes" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the order of the Workers Compensation Board reversing an Administrative Law Judge's (ALJ) application of the 2x multiplier in Ky. Rev. Stat. 342.730(1)(c)2, holding that there was no error.After suffering a work-related injury Claimant continued working his normal job for almost one year before he was laid off for unrelated reasons. The ALJ determined that, since Claimant earned no wage after the lay-off he qualified for the 2x multiplier, which doubles a claimant's benefits if the claimant returns to work after injury at the same or higher wages but subsequently experiences a cessation of that employment. The Board reversed as to the application of the 2x multiplier, determining that there was no "return" to work under section 342.730(1)(c)2. The court of appeals affirmed. The Supreme Court affirmed, holding that the ALJ misapplied the law to the facts. View "Helton v. Rockhampton Energy, LLC" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of one count of second-degree rape, one count of third-degree rape, and two counts of incest, holding that there was no reversible error.On appeal, Defendant argued that his trial court should have been severed from his wife's trial, that his wife's counsel improperly made statements against his interest in closing arguments, that the jury instructions violated his right to a unanimous jury verdict, and that certain evidence at trial was improperly admitted. The Supreme Court affirmed, holding that Defendant was not entitled to relief on any of his allegations of error. View "Sexton v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court prohibiting a vote tabulation regarding a school board tax recall based upon alleged violations of Ky. Rev. Stat. 132.017 and Ky. Rev. Stat. Chapter 369, holding that there was no error.This case involved a tax increase adopted by the Jefferson County Board of Education (JCBE) in 2020. A recall committee was formed to challenge the excess portion of the tax. A recall petition was subsequently certified. JCBE filed suit, seeking review of the county clerk's certification pursuant to section 132.017(2)(i). The recall committee intervened and counterclaimed for failure to comply with Ky. Rev. Stat. 133.185 and the notice requirements of Ky. Rev. Stat. 160.470(7)(b). The circuit court dismissed the counterclaim and ordered no further action regarding the regular ballot votes for the tax recall. The Supreme Court affirmed, holding that the public's right to vote on a tax recall is rendered null by the inadequacy of the recall petition occasioned by the alterations and lack of required information. View "Friedmann v. Honorable Bobbie Holsclaw" on Justia Law

The Supreme Court affirmed the decision of the court of appeals that a real property contract entered into by Henry Gray and William, Mary and Frank Stewart in this case was unenforceable under the statute of frauds but held that this decision did not apply equally to William, Mary and Frank.Henry entered into a real estate contract with Frank, his brother William, and William's wife, Mary. Later, Henry filed a complaint against Frank, William and Mary alleging breach of contract and requesting specific performance and damages. The trial court entered judgment in favor of Henry and awarded $19,286 in damages. The court of appeals reversed in part. The Supreme Court affirmed, holding (1) the contract at issue did not satisfy the statute of frauds; (2) the trial court's findings of fact may not serve as a basis to reverse the court of appeals' decision as to William and Mary; and (3) the court of appeals did not err when it reversed the trial court's damage award. View "Gray v. Stewart" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the decision of the circuit court denying Defendant's motion seeking reconsideration of probation pursuant to Ky. Rev. Stat. 640.075(4), holding that the provisions of Ky. Rev. Stat. 532.045 apply to render a juvenile convicted as a youthful offender of sexual offenses ineligible for probation.When he was a juvenile, Defendant was charged with multiple sex offenses and transferred to the circuit court as a youthful offender. Defendant was convicted. Shortly before he turned twenty-one, Defendant filed his motion to reconsider probation. The circuit court denied the motion, and the court of appeals affirmed. The Supreme Court affirmed, holding that section 532.045 applies to youthful offenders such as Defendant. View "Bloyer v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court denying Defendant's motion to suppress location data obtained from the police's search of his real-time cell-site location information (CSLI) and the evidence obtained from the search, holding that suppression was required.Defendant entered a conditional guilty plea to one count of first-degree robbery, one count of possession of a handgun by a convicted felon, and one count of receiving stolen property. The court of appeals reversed, concluding that the trial court erred in denying Defendant's motion to suppress because the police's acquisition of Defendant's real-time CSLI constituted a warrantless, unreasonable search. The Supreme Court affirmed, holding that the officers illegally obtained Defendant's real-time CSLI and that the evidence obtained therefrom should be excluded from evidence. View "Commonwealth v. Reed" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's Ky. R. Crim. P. 11.42, Ky R. Crim. P. 10.02, Ky. R. Civ. P. 60.02, and Ky. R. Civ. P. 60.03 motion for relief, holding that the circuit court did not err.Appellant was convicted of two counts of complicity to murder and other crimes and sentenced to death. In the instant motion, Appellant argued that McCoy v. Louisiana, 138 S.Ct. 1500 (2018), governed his claim that his defense counsel provided ineffective assistance. The circuit court denied the motion, determining that the claim was both substantively and procedurally improper. The Supreme Court affirmed, holding that there was no error in the circuit court's denial of relief. View "Epperson v. Commonwealth" on Justia Law

The Supreme Court reversed the order of the family court denying the motion of the Commonwealth, Cabinet for Health and Family Services, ex rel. Child Support Enforcement's (Cabinet) to set aside an agreed judgment regarding the paternity of a child born out of wedlock, holding that the underlying judgment was void for lack of subject matter jurisdiction.The Cabinet brought this action to set aside the agreed judgment in this case, arguing that the judgment was void and entered due to fraud and should be side aside under Ky. R. Civ. P. (CR) 60.02. The family court denied the motion as untimely, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the family court acted outside its statutory authority in adjudicating non-paternity without a corollary determination of paternity as to an identified father; and (2) because the judgment was void, rule 60.02(e) mandated that the judgment be set aside. View "Commonwealth, Cabinet for Health & Family Services ex rel. Child Support Enforcement v. B.N.T." on Justia Law

The Supreme Court held that three dependency-neglect-abuse (DNA) petitions filed by the guardian ad litem (GAL) of three children against the Cabinet for Health and Family Services (CHFS) should have been dismissed.The GAL brought this action raising concerns regarding the conduct of the CHFS with respect to three children committed to its temporary custody. The CHFS filed a motion to dismiss the petitions, arguing that the neglect petitions did not state a viable cause of action because the CHFS was entitled to governmental immunity. The family court denied the motion. The court of appeals affirmed, holding that the General Assembly waived the CHFS's right to governmental immunity in DNA matters. The Supreme Court vacated the lower courts' decisions and remanded for dismissal of the GAL's DNA petitions, holding (1) the GAL's allegations should have been addressed by a motion in the context of the existing DNA cases rather than in separate actions; and (2) in any event, the petitions were moot on their face. View "Commonwealth v. Baker" on Justia Law