Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the decision of the Workers' Compensation Board reversing the decision of the administrative law judge (ALJ) granting permanent partial disability benefits (PPD) to Richard Russell but finding that certain medical expenses were submitted untimely and were therefore non-compensable, holding that there was no error.Russell sustained a work-related injury to his right arm and sought workers' compensation benefits. The ALJ found that Russell did not timely submit his medical bills, so they were not compensable, but otherwise granted PPD benefits. The Board reversed, concluding that the medical bills were not submitted untimely. The court of appeals affirmed. The Supreme Court affirmed, holding that Russell timely submitted his medical expenses. View "Wonderfoil, Inc. v. Russell" on Justia Law

The Supreme Court reversed Defendant's convictions on forty counts of possession or viewing of a matter depicting a sexual performance by a minor, seven counts of the use of a minor under sixteen in a sexual performance, and one count of sexual abuse of a minor under twelve, holding that the trial court erred in allowing the Commonwealth to use a great number of unindicted images as Ky. R. Evid. 404(b) evidence.At the end of an investigation, a law enforcement officer found 4,622 images and 1,005 videos of child sexual exploitation material on Defendant's home computer and 925 files of child sexual-exploitation material on Defendant's cell phone. The trial court subsequently convicted Defendant and sentenced him to a total of seventy years' imprisonment. On appeal, Defendant argued that any discussion of images not presented to the grand jury and therefore not subject to indictment should not have been allowed by the trial court. The Supreme Court reversed, holding that Defendant's trial was rendered unfair by the Commonwealth's introduction into evidence a number of inindicted images. View "Minch v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court granting Defendant's motion to suppress evidence, holding that substantial evidence supported the trial court's findings of fact and that the court's conclusions of law were legally sound.In granting Defendant's suppression motion, the trial court concluded that there was no reasonable suspicion that Defendant was involved in criminal activity prior to his stop. Because Defendant's consent to search was obtained after his illegal stop, the Supreme Court held that it was the fruit of that illegal stop. The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court did not err in concluding that Defendant was illegally detained without reasonable suspicion. View "Commonwealth v. Perry" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the circuit court concluding that Zurich American Insurance company had a reasonable basis to deny James Nichols' claim for underinsured motorist benefits under a policy issued by Zurich to Nichols' employer, holding that the trial court erred.Zurich issued a commercial fleet policy to Nichols' employer providing underinsured motorist (UIM) coverage with $1,000,000 limits. Nichols was severely injured in an automobile collision and relied on various acknowledgments that the UIM coverage had $1,000,000 limits in settling with the tortfeasor. Zurich denied coverage, and Nichols filed this action to collect under the UIM provision. The trial court denied the motion. The Supreme Court remanded. On remand, Defendant amended his complaint to assert common law bad faith. Zurich settled Nichols' UIM claim for the police limits of $1,000,000, and the trial court granted Zurich's summary judgment motion for summary judgment on the bad faith claims. The Supreme Court reversed, holding that Nichols presented sufficient evidence to survive summary judgment on the bad faith claim. View "Nichols v. Zurich American Insurance Co." on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Defendant's motion for relief under Ky. R. Crim. P. 22.42 and 10.02 and Ky. R. Civ. P. 60.02 and 60.03, holding that the circuit court did not err in finding that Defendant's claim was both substantively and procedurally improper.After a second trial in 1996, Defendant was convicted of two counts of complicity to murder, first-degree robbery and first-degree burglary. In 2018, the Supreme Court denied Defendant's collateral attacks and concluded that the United State's Supreme Court's decision in McCoy v. Louisiana, 138 S.Ct. 1500 did not govern Defendant's claim that his trial attorney conceded guilt, against Defendant's express desire to maintain actual innocence. After Defendant filed the motion at issue on appeal, the circuit court denied the motion on the grounds that Defendant had already presented this claim. The Supreme Court affirmed, holding that the circuit court did not err. View "Epperson v. Commonwealth" on Justia Law

The Supreme Court reversed the judgment of the trial court denying Defendant's motion to suppress, holding that the traffic stop in this case was extended, and the extension was not justified by reasonable, articulable suspicion.Defendant was charged with first-degree possession of cocaine. Defendant pled not guilty and filed a motion to suppress the evidence of cocaine, claiming that he was illegally detained and the the police did not have a reasonable, articulable suspicion to call for a K-9 unit to come and search the scene. The trial court denied the motion to suppress, concluding that the initial stop was valid. The Supreme Court reversed, holding that no reasonable articulable suspicion existed to permit the K-9 unit search and that the search unconstitutionally extended the traffic stop, in violation of Defendant's Fourth Amendment rights. View "Commonwealth v. Clayborne" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court's grant of summary judgment in favor of Defendants in this action alleging negligent operation of a resident swimming pool, negligent supervision, and gross negligence, holding that a property owner owes a reasonable duty of care to a guest whom the owner invites onto the owner's property to participate in an activity.Defendants hosted a pool party and cookout at their home for a baseball team made up of seven and eight-year-old boys. Plaintiff's son drowned in the pool during the party. Plaintiffs brought this action alleging negligence resulting in the wrongful death of their son. The circuit court granted summary judgment for Defendants, and the court of appeals affirmed. At issue before the Supreme Court was the applicability of the common law distinctions of licensee and invitee in identifying the scope of duty owed by Defendants owed to the child. The Supreme Court reversed and remanded the case, holding that Defendants owed a duty of reasonable care to the child, and the determination of breach of such duty should be left to a jury's discretion. View "Bramlett v. Ryan" on Justia Law

The Supreme Court reversed the decision of the court of appeals vacating Defendant's conviction for robbery in the first-degree and complicity to murder and affirmed the trial court, holding that the trial court did not err in denying Defendant's Ky. R. Crim. P. (RCr) 11.42 and Ky. R. Civ. P. (CR) 60.02 motions for a new trial.The evidence against Defendant included his codefendant's testimony that Defendant committed the crimes for which he was convicted, as well as expert testimony explaining historical cell site information placing Defendant in the area around the time of the crimes. Defendant's codefendant subsequently recanted his testimony, and Defendant sought a new trial under CR 60.02 and RCA 11.42. The trial court determined that Defendant was not entitled to a new trial under either rule. The court of appeals vacated Defendant's conviction based on the codefendant's recantation of his testimony. The Supreme Court reversed, holding that the recanted testimony did not warrant a new trial. View "Commonwealth v. Crumes" on Justia Law

The Supreme Court reversed the decision of the circuit court denying a writ of prohibition seeking to prohibit enforcement of the district court's suppression order in this case, holding that the Commonwealth failed to show a great injustice and irreparable harm if its requested writ of prohibition was not granted.At issue was whether the district court erred in suppressing a blood alcohol concentration (BAC) result collected from Defendant, a Spanish-speaking person suspected of driving under the influence of alcohol. Defendant filed a motion to suppress the BAC evidence, arguing that the arresting officer violated the implied consent statute. The Commonwealth subsequently petitioned for a writ of prohibition to prevent enforcement of the suppression order. The court of appeals granted the writ, determining that the statute did not require a suspect to understand the implied consent warning, but only that it must be read to the suspect. The Supreme Court reversed, holding that the Commonwealth did not meet the threshold requirements for the writ. View "Ortiz v. Commonwealth" on Justia Law

The Supreme Court reversed the decisions of the court of appeals denying Plaintiffs' petitions seeking writs of prohibition in these medical malpractice actions, holding that Plaintiffs established that they were entitled to the writs.Plaintiffs brought this action against Defendants, medical providers and their employers asserting medical malpractice. Plaintiffs moved to disqualify Defendants' counsel, asserting the existence of an actual conflict of interest. The trial court found the existence of actual conflicts of interest and granted the motions. The court of appeals subsequently denied Defendants' separate petitions seeking writs of prohibition. The Supreme Court reversed, holding that Plaintiffs satisfied the burdens of showing entitlement to seek issuance of a writ. View "Harkins v. Honorable House" on Justia Law