Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals remanding this case to the trial court and reinstated the circuit court's domestic violence protective order in this case, holding that the trial court's factual findings were readily apparent upon review of the record and, therefore, remand was not required.The circuit court issued a domestic protective order against Jason McCoy restraining him from having contact with E.S., the daughter of McCoy's girlfriend. The trial court made oral findings of fact and conclusions of law and filled out Administrative Office of the Courts (AOC) Form 275.3, order of protection. The court of appeals vacated the trial court's order and remanded the case, concluding that the trial court failed to make written factual findings as required by Ky. R. Civ. P. 52.01. The Supreme Court reversed, holding that family courts are not required to transcribe their clear oral findings in protective order cases when they also completely and accurately fill out AOC Form 275.3 and issue a written order explicitly incorporating their clear oral factual findings. View "Smith v. McCoy" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the circuit court finding that the natural, minor children of Father were abused or were at risk of being abuse while in his care pursuant to Ky. Rev. Stat. 600.020(1)(a)(5), holding that there was no abuse of discretion in the issues raised by Father.On appeal, Father argued that the trial court erred in (1) admitting a portion of the testimony of his youngest child's therapist describing the alleged abuse and naming Father as the perpetrator, and (2) not giving greater weight to the grand jury findings of "no true bill" when they were submitted as evidence at the adjudication hearing. The court of appeals affirmed, finding no abuse of discretion. The Supreme Court affirmed, holding that the trial court did not abuse its discretion on either of the evidentiary matters brought forward on appeal. View "B.B. v. Commonwealth, Cabinet for Health & Family Services" on Justia Law

The Supreme Court affirmed the order of the court of appeals granting Defendant's petition for a writ of prohibition of the first class, thereby vacating the circuit court's denial of Defendant's motion to dismiss Plaintiffs' claim for breach of contract, holding that the court of appeals did not err.Plaintiffs were Kentucky landowners who leased their land to Defendant, an oil and gas producer. Plaintiffs filed a breach of contract class action suit alleging that Defendant impermissibly deducted severance taxes as a post-production cost before paying them royalties. Defendant filed a motion to dismiss on grounds that the circuit court lacked subject matter jurisdiction because Plaintiffs did not meet the required amount in controversy. The circuit court denied the motion. Defendant then sought a writ of prohibition. The court of appeals granted the writ. The Supreme Court affirmed, holding that Plaintiffs did not meet the required amount in controversy, and therefore, the circuit court lacked subject matter jurisdiction. View "Imhoff v. Honorable House" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for two counts of trafficking in a controlled substance in the first degree and being a persistent felony offender in the second degree, holding that the trial court did not err in its assessment of court costs.On appeal, Defendant challenged the portion of the judgment ordering him to pay court costs within six months of being released from custody. Specifically, Defendant argued that the trial court exceeded its authority under Ky. Rev. Stat. 23A.205(3) and 534.020 because the statutes require all imposed court costs to be paid at the time of sentencing or within one year thereafter. The Supreme Court affirmed, holding that there was no error requiring correction. View "Chadwell v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the opinion and order of the circuit court which upheld the district court's entry of an interpersonal protection order (IPO) between an eleven-year-old petitioner and a thirteen-year-old respondent, holding that any IPO hearing involving either a minor petitioner or respondent must be made confidential by the presiding court.Jane Smith filed a petition for an IPO on behalf of her eleven-year-old son, Brian. The respondent was John Doe, age thirteen. The district court entered an IPO against Doe, and the circuit court affirmed. The court of appeals reversed on several grounds. The Supreme Court affirmed, holding (1) the court of appeals erred in holding that the general division of the district court lacked subject matter jurisdiction to preside over this case; (2) a guardian ad litem must be appointed to unrepresented minor petitioners and respondents in IPO cases; and (3) it was reversible error for the district court to permit Doe's mother to represent Doe in lieu of appointing a guardian ad litem to represent him. View "Smith v. Doe" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals upholding the constitutionality of the 2018 amendment to Ky. Rev. Stat. 342.730(4), which terminates workers' compensation income benefits when the recipient reaches the age of seventy or four years from the date of injury or last injurious exposure, holding that the statute is constitutional.Plaintiffs brought separate appeals arguing that the amendment (1) was unconstitutional under the state and federal Equal Protection Clauses because it discriminates based on the income-benefit recipient's age, and (2) was unconstitutional special legislation because it applied only to older income-benefits recipients. The court of appeals upheld the constitutionality of the statute's age classification. The Supreme Court affirmed, holding that the court of appeals correctly rejected the constitutional challenges to the statute. View "Cates v. Kroger" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the trial court's grant of summary judgment in favor of Defendants in this personal injury action, holding that the trial court properly granted summary judgment.Roy Prather was crossing a path between barns at a horse sale at Keeneland Association when a horse broke loose from his handler. While attempting to flee, Prather fell and fractured his shoulder. Prather and his wife (together, Plaintiffs) filed suit against Keeneland and Sallee Horse Vans, Inc., the transportation company that agreed to transport the horse to its destination (together, Defendants), alleging negligence. The trial court granted summary judgment for Defendants, finding that the claims were barred by Ky. Rev. Stat. 247.402, a provision of the Farm Animals Activity Act (FAAA). The court of appeals reversed, raising a new legal theory sua sponte. The Supreme Court reversed, holding that the FAAA applied and that summary judgment was properly granted. View "Keeneland Ass'n v. Prather" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding the 2018 amendment to Ky. Rev. Stat. 342.730(4), holding that the statutory amendment did not violate the Contracts Clause of the federal and state constitutions.The statutory amendment at issue terminates workers' compensation income benefits when the recipient of the benefits reaches the age of seventy or four years from the date of injury or last injurious exposure, whoever occurs last. Plaintiffs challenged the constitutionality of the amendment. The court of appeals held that the amendment did not violate the Contracts Clause of the state and federal constitutions and that the statute was reasonable. The Supreme Court affirmed, holding that the 2018 amendment did not violate the Contracts Clause of the Federal or Kentucky Constitutions. View "Dowell v. Matthews Contracting" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court granting summary judgment to Defendants and dismissing Plaintiff's action alleging that her consent to certain medical treatment was invalid, holding that summary judgment was proper.Plaintiff consented to participate in a clinical trial following her kidney transplant. Shortly after participating in the trial, Plaintiff developed a rare form of blood cancer. Plaintiff and her husband brought this action against the clinical trial's medical providers, alleging that her consent to the medical treatment involved in the trial was invalid pursuant to Ky. Rev. Stat. 304.40-320. The trial court granted summary judgment to Defendants, finding that Plaintiff's informed consent complied with Kentucky statutory authority and federal regulations. The court of appeals reversed. The Supreme Court reversed, holding that Plaintiffs did not have a viable informed consent claim under Kentucky law. View "University Medical Center, Inc. v. James Graham Brown Cancer Center" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of first-degree assault, attempted murder, and other offenses and sentencing him to a total of thirty-five years' imprisonment, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) Defendant was not entitled to a directed verdict on the charge of first-degree burglary; (2) the trial court did not err in finding that a specific mistake of fact instruction would be duplicative of the trial court's proposed instruction; (3) the trial court did not abuse its discretion in denying Defendant's request for a self-protection instruction; (4) the trial court did not abuse its discretion in permitting the jury to view the body camera video from the first officer to arrive on the scene; (5) the trial court did not err in permitting the jury to correct a mistake in form on Verdict Form 8; and (6) the trial court did not err in imposing a thirty-five-year sentence. View "Sutton v. Commonwealth" on Justia Law