Justia Kentucky Supreme Court Opinion Summaries

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

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