Justia Kentucky Supreme Court Opinion Summaries

A local government enacted an ordinance that completely prohibited its police officers from seeking or executing no-knock warrants within its jurisdiction. This ordinance was adopted after the state legislature passed a statute (SB 4, now codified in KRS 455.180 and related provisions) that did not ban no-knock warrants outright, but instead imposed strict conditions and procedural safeguards for their issuance and execution. The statute allowed no-knock warrants only in limited circumstances, subject to a clear and convincing evidentiary standard, approval by a superior officer, consultation with prosecutors, and time-of-day restrictions.The Fraternal Order of Police challenged the ordinance in Fayette Circuit Court, arguing that it conflicted with state law. The trial court found no express or implied conflict, reasoning that the statute did not require the use of no-knock warrants, but merely set conditions for their issuance, and thus the ordinance’s total ban did not conflict with the statute. On appeal, the Kentucky Court of Appeals reversed the trial court, but did not definitively resolve the conflict issue, instead remanding for further proceedings, particularly in light of collective bargaining questions.The Supreme Court of Kentucky granted discretionary review and held that the local ordinance directly conflicted with the state statute. The Court reasoned that the statute authorizes law enforcement officers to seek no-knock warrants under certain conditions, while the ordinance prohibits them from ever doing so, making it impossible for officers to comply with both. The Court concluded that when a local ordinance prohibits what a state statute permits, the ordinance is void. The Supreme Court of Kentucky reversed the Court of Appeals and declared the ordinance null, void, and of no effect. View "LEXINGTON-FAYETTE URBAN COUNTY GOVERNMENT V. FRATERNAL ORDER OF POLICE" on Justia Law

The case involved a violent confrontation between two former friends, Raiantez Shackles and Marvin Yarbrough, which escalated after a series of personal disputes, including threats and a romantic entanglement. On January 5, 2021, after a prior shooting incident involving their vehicles, Marvin and his wife Cassandra returned home from a funeral to find their residence under threat. Upon arrival, they were confronted by two armed men, and Shackles emerged from behind a tree, pointing a gun at them. A shootout ensued, resulting in both Marvin and Cassandra being shot, while their four children and Marvin’s brother were inside the home. The scene was chaotic, with multiple bullet holes found throughout the residence and a neighbor’s home.A jury in the Jefferson Circuit Court convicted Shackles of two counts of first-degree assault, six counts of first-degree wanton endangerment, possession of a handgun by a felon, and being a first-degree persistent felony offender. The jury recommended a sixty-year sentence, which the trial court reduced to forty-five years under Kentucky law. Shackles appealed, raising several claims of error regarding jury instructions, evidentiary rulings, and the conduct of the sentencing phase.The Supreme Court of Kentucky reviewed the case and affirmed the trial court’s judgment. The Court held that the trial court did not abuse its discretion in declining to give a self-defense instruction, as there was no evidence that Marvin used unlawful force. The Court found that while the admission of certain hearsay evidence was erroneous, it was harmless given the other evidence presented. The Court also upheld the admission of body camera footage and crime scene photographs, denied the directed verdict motions on the wanton endangerment charges, and found no manifest injustice in the jury polling or the admission of victim impact testimony. The judgment of conviction and sentence was affirmed. View "SHACKLES V. COMMONWEALTH OF KENTUCKY" on Justia Law

Several individuals who allegedly owed debts to Kentucky public institutions—either for medical services at the University of Kentucky or for educational services at the University of Kentucky, Morehead State University, or the Kentucky Community & Technical College System—challenged the referral of their debts to the Kentucky Department of Revenue for collection. The plaintiffs argued that the statutes used to justify these referrals did not apply to their debts and that the Department unlawfully collected the debts, sometimes without prior court judgments or adequate notice. The Department used its tax collection powers, including garnishments and liens, to recover these debts, and in some cases, added interest and collection fees.In the Franklin Circuit Court, the plaintiffs sought declaratory and monetary relief, including refunds of funds collected. The Circuit Court ruled that the Department was not authorized by statute to collect these debts and held that sovereign immunity did not protect the defendants from the plaintiffs’ claims. The court also certified the medical debt case as a class action. The Court of Appeals reviewed these interlocutory appeals and held that while sovereign immunity did not bar claims for purely declaratory relief, it did bar all claims for monetary relief, including those disguised as declaratory relief.The Supreme Court of Kentucky reviewed the consolidated appeals. It held that sovereign immunity does not bar claims for purely declaratory relief or for a refund of funds that were never due to the state, nor does it bar constitutional takings claims. However, the court held that sovereign immunity does bar claims for a refund of funds that were actually due to the state, even if those funds were unlawfully or improperly collected. The court affirmed in part, reversed in part, and remanded for further proceedings to determine which funds, if any, were never due to the state and thus subject to refund. The court also found that statutory changes rendered prospective declaratory relief in the medical debt case moot, but not retrospective relief. View "LONG V. COMMONWEALTH OF KENTUCKY" on Justia Law

The case concerns Isaiah Brown, who, along with Rayshawn Tucker and Fatima Alabusalim, was implicated in the murder and first-degree robbery of DaMani Dulaney in Louisville, Kentucky. Alabusalim, who had relationships with both Tucker and Dulaney, testified that Tucker was upset about her relationship with Dulaney and devised a plan to rob him, enlisting her and Brown’s help. On the night of the incident, Alabusalim lured Dulaney to a park, where Tucker and Brown confronted him. Brown broke the driver’s side window with a gun, and after Alabusalim was pulled from the car, a single gunshot was fired, resulting in Dulaney’s death. The trio fled to Florida after the crime. Evidence included text messages, cell site data, and testimony from Alabusalim, who initially gave false statements to police but later admitted her involvement.The Jefferson Circuit Court tried Brown alone after his co-defendants entered plea agreements. The jury found Brown guilty of murder (complicity) and first-degree robbery (complicity), recommending concurrent sentences of twenty-two years for murder and ten years for robbery. The court sentenced Brown accordingly. Brown appealed, raising issues about the admission of certain evidence, including hearsay regarding phone number attribution, the foundation for text messages, improper opinion testimony by a detective, the admission of co-conspirator statements, and cumulative error.The Supreme Court of Kentucky reviewed the case and affirmed the convictions. The court held that while the trial court erred in admitting hearsay evidence identifying Brown’s phone number and in allowing improper opinion testimony about a witness’s credibility, these errors were harmless or did not result in manifest injustice. The court found that the text messages were properly authenticated and that the co-conspirator exception to the hearsay rule was satisfied. The cumulative effect of the errors did not render the trial fundamentally unfair. View "BROWN V. COMMONWEALTH OF KENTUCKY" on Justia Law

A police officer observed an individual walking in the middle of a street at night near a location known for drug activity. The officer, believing this to be a violation of Kentucky’s jaywalking statute, attempted to stop the individual by asking him to approach the patrol car. The individual ignored the officer’s verbal commands, turned away, and increased his pace. The officer then physically seized the individual by grabbing his arms and escorted him back to the patrol car. During this process, the officer observed the individual discard drugs, which led to his arrest. Additional drugs were found in the individual’s possession after the arrest.The Nelson Circuit Court held a suppression hearing, during which the officer and the defendant’s mother testified. The court found that the officer had probable cause to believe a jaywalking violation had occurred and concluded that the officer’s actions were justified. The court denied the motion to suppress the drug evidence. The defendant subsequently entered a conditional guilty plea to amended charges, reserving the right to appeal the suppression ruling. The Kentucky Court of Appeals affirmed the circuit court’s decision, reasoning that an officer may detain a pedestrian for a traffic law violation to issue a citation, and distinguished the case from prior precedent involving different circumstances.The Supreme Court of Kentucky reviewed the case and affirmed the lower courts’ decisions. The court held that the Fourth Amendment is not violated when police physically seize a person for an observed violation, such as jaywalking, for the purpose of issuing a citation if the person fails to comply with verbal commands. The court found the officer’s use of minimal force to be objectively reasonable under the circumstances and concluded that the subsequent discovery of contraband was not the result of an unreasonable search or seizure. The denial of the motion to suppress and the convictions were affirmed. View "BUECHELE V. COMMONWEALTH OF KENTUCKY" on Justia Law

Darrell Strunk participated in two robberies on the same day in December 2011: first, a home invasion, and then a business robbery. He was indicted for the business robbery, and later, with his consent, additional charges from the home robbery were added. Strunk entered a plea agreement, pleading guilty to two counts of second-degree robbery, each enhanced by his status as a second-degree persistent felony offender. The agreement called for consecutive sentences of 20 years and 10 years, totaling 30 years’ imprisonment.The Fayette Circuit Court accepted the plea and imposed the 30-year sentence, despite Strunk’s counsel raising concerns that this exceeded the statutory maximum under KRS 532.110(1)(c), which limits the aggregate sentence for Class C felonies to 20 years. Strunk later filed a motion under CR 60.02 to correct his sentence, arguing it was illegal. The trial court denied the motion, reasoning that the plea agreement treated the two robberies as separate cases and that Strunk had knowingly accepted the deal. On appeal, the Kentucky Court of Appeals reversed, holding that the 30-year sentence violated the statutory cap and that the statutory limit could not be waived, remanding for resentencing within the legal maximum.The Supreme Court of Kentucky reviewed the case and affirmed the Court of Appeals. The Court held that Strunk’s aggregate sentence of 30 years was illegal under KRS 532.110(1)(c), as the statutory maximum for his offenses was 20 years. The Court further held that, because Strunk sought only correction of his sentence and not withdrawal of his guilty plea, the proper remedy was to remand for resentencing with instructions to impose the highest legal sentence—20 years’ imprisonment. View "COMMONWEALTH OF KENTUCKY V. STRUNK" on Justia Law

An individual diagnosed with Alzheimer’s disease was admitted to a personal care facility in Kentucky after his spouse, who had been appointed his conservator by a Tennessee court, signed a mandatory arbitration agreement required for admission. The spouse did not specify her capacity when signing. The patient later suffered injuries and died, leading his spouse, as administratrix of his estate, to file suit alleging negligence, wrongful death, and other claims against the facility and its operators.The defendants moved to compel arbitration, arguing that the spouse had authority to sign the agreement under the Tennessee conservatorship order or, alternatively, under Kentucky’s Living Will Directive Act, which allows a spouse to make “health care decisions” for an incapacitated person. The Fayette Circuit Court denied the motion, finding that signing an arbitration agreement was not a health care decision under the Act and that the spouse lacked authority to bind the patient. The court did not rule on unconscionability. The Kentucky Court of Appeals affirmed, distinguishing prior cases involving powers of attorney and holding that the Act’s definition of “health care decision” did not include entering arbitration agreements.The Supreme Court of Kentucky reviewed whether a spouse may bind an incapacitated person to arbitration for facility admission under the Living Will Directive Act. The Court held that signing an arbitration agreement is not a “health care decision” as defined by Kentucky law, which limits such decisions to consenting to or withdrawing consent for medical procedures, treatments, or interventions. The Court affirmed the Court of Appeals’ decision, upholding the denial of the motion to compel arbitration, and remanded the case for further proceedings. View "LEXINGTON ALZHEIMER'S INVESTORS, LLC V. NORRIS" on Justia Law

A child was born in 2012 to Kendra and Christopher, but due to concerns about Kendra’s fitness as a parent, the child was placed with her paternal grandmother, Denise, and Denise’s long-term partner, David Lemaster, under a Cabinet safety plan. Denise was later granted permanent custody of the child, and the child lived with Denise and Lemaster for her entire life. Kendra, the child’s mother, was initially denied visitation but later received supervised and then unsupervised visitation. Denise and Lemaster jointly raised and financially supported the child, functioning as a family unit. In 2022, Denise died, and Lemaster sought to intervene in the ongoing custody case, claiming de facto custodian status and seeking custody or visitation.The Greenup Family Court granted emergency custody to Kendra and, without holding an evidentiary hearing, later awarded her full custody, denying Lemaster’s motion to intervene as untimely and finding he could not qualify as a de facto custodian. Lemaster’s motion to alter or amend was denied. On appeal, the Kentucky Court of Appeals affirmed, holding that Lemaster’s intervention was untimely and that he could not be a de facto custodian since he co-parented with Denise, the legal custodian.The Supreme Court of Kentucky reversed and remanded. It held that Lemaster had standing to intervene as a “person acting as a parent” under the Uniform Child Custody Jurisdiction and Enforcement Act and had sufficiently alleged a basis for de facto custodian status, even though he was not married to Denise. The Court found that Lemaster’s motion to intervene, filed two days after Denise’s death, was timely, as his interest was previously protected by Denise. The Court ordered the family court to allow Lemaster to intervene and to hold an evidentiary hearing to determine his status as a de facto custodian. View "LEMASTER V. STILTNER" on Justia Law

A man named Donald Prater, Jr. was found partially nude and behaving erratically after leaving a hospital, having previously told a deputy he had used methamphetamine and was hallucinating. Law enforcement officers from the City of Paintsville and Johnson County, along with emergency medical personnel, responded to reports of his behavior. When officers attempted to arrest Prater on a public street, he resisted and force was used, including a taser, pepper spray, and baton strikes. After being handcuffed, Prater stopped breathing and, despite immediate lifesaving efforts, died. The medical examiner found no lethal trauma and attributed the death to excited delirium syndrome, with other health factors possibly contributing.The personal representative of Prater’s estate filed a wrongful death suit in Johnson Circuit Court against various city and county entities and their employees, alleging excessive force, negligence, and wrongful death. The circuit court granted summary judgment to all defendants, finding the officers and emergency personnel were entitled to qualified official immunity, that the force used was reasonable, and that there was no evidence their actions caused Prater’s death. The court also dismissed claims against the city and county entities, including those for negligent hiring and supervision, on the basis that no underlying tort had been established.On appeal, the Kentucky Court of Appeals affirmed in part and reversed in part, holding that some claims against the city and police department for negligent hiring and supervision could proceed, and that the officers’ entitlement to qualified immunity required further factual findings. The Supreme Court of Kentucky reviewed the case and held that all defendants were properly dismissed. The Court concluded that the officers’ actions were discretionary, performed in good faith, and within the scope of their authority, entitling them to qualified official immunity. The Court reversed the Court of Appeals in part, affirmed in part, and remanded for any necessary proceedings. View "CITY OF PAINTSVILLE V. HANEY" on Justia Law

A healthcare provider participated in Kentucky’s Medicaid program, offering in-home services to recipients in rural areas under the Home and Community Based (HCB) Waiver program. The Department for Medicaid Services had, for several years, reimbursed the provider at enhanced rates for “case management” services, even though the relevant administrative regulation did not list “case management” as a reimbursable “revenue code service.” In 2016, the Department determined that these payments were made in error and sought to recoup over $1 million from the provider for services rendered between 2011 and 2013.After the Department initiated recoupment, the provider contested the action through the Cabinet’s administrative process, arguing that the omission of “case management” from the regulation was a drafting error and that the Department should be estopped from recouping the funds due to its prior representations and delay. The administrative hearing officer rejected these arguments, finding the regulation’s text unambiguous and concluding that neither equitable estoppel nor laches applied. The Secretary of the Cabinet adopted this decision. The provider then sought judicial review in the Franklin Circuit Court, which affirmed the agency’s decision. The Kentucky Court of Appeals also affirmed.The Supreme Court of Kentucky reviewed the case and affirmed the Court of Appeals. The Court held that the Department’s regulation unambiguously excluded “case management” from the list of services eligible for enhanced reimbursement, and the Department was within its authority to recoup the overpaid funds. The Court declined to read omitted language into the regulation, found no basis for equitable estoppel or laches against the Department, and rejected the provider’s arguments regarding the sufficiency of the Department’s audit. View "PROFESSIONAL HOME HEALTH CARE V. COMMONWEALTH OF KENTUCKY CABINET FOR HEALTH AND FAMILY SERVICES" on Justia Law