Justia Kentucky Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to life imprisonment without the possibility of parole in connection with his conviction for murder, robbery in the first degree, and tampering with physical evidence, holding that there was no error in the sentence.Defendant entered an open guilty plea to the charges against him and then appealed his sentence. At issue was whether Defendant could subsequently appeal on the grounds that his statutorily-authorized sentence should be reversed because there was inadequate consideration given to mitigation evidence. The Supreme Court affirmed, holding (1) Defendant waived his right to appeal his sentence; and (2) even if the trial court's sentencing decision were subject to review, the trial court did not err when sentencing Defendant. View "Hayes v. Commonwealth" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the decision of the trial court denying Defendant's motion to vacate the judgment convicting her for the murder of her husband, holding that the court of appeals correctly denied Defendant's ineffective assistance of counsel claim but that, as to all other issues, the court of appeals' decision must be reversed.Specifically, the Supreme Court held (1) the court of appeals did not err in denying Defendant's ineffective assistance of counsel claim relating to her trial counsel's failure to object to certain erroneous jury instructions; and (2) the court of appeals' use of the manifest injustice standard of review was improper, and the case must be remanded to undertake a review of Defendant's remaining claims utilizing the proper standard of review. View "Ford v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the circuit court holding that substantial evidence supported the $200,000 assessment of Kentucky Retirement Systems in actuarial costs against the City of Villa Hills following the retirement of one of its employees, holding that the court of appeals properly resolved all of the City's issues in favor of the Retirement Systems.The Retirement Systems found that increases in the employee's compensation over the five years preceding his retirement was not the direct result of a bona fide promotion or career advancement and so shifted the added actual cost of the retired employee's pension benefits to the City. The circuit court and court of appeals affirmed. The Supreme Court affirmed, holding that none of the City's arguments on appeal warranted reversal. View "City of Villa Hills v. Kentucky Retirement Systems" on Justia Law

The Supreme Court vacated the decision of the court of appeals reversing the circuit court's order on revocation of probation which ran Defendant's sentence in her Kenton County case sentence consecutive to, rather than concurrent with, her sentence in her Campbell County cases, holding that this case was moot.In 2016, Defendant pled guilty to Kenton Circuit Court to criminal possession of a forged instrument. While still on probation, Defendant committed two additional felonies in Campbell County. The Kenton Circuit Court ultimately revoked Defendant's probation and ordered her incarcerated for three years. The court of appeals reversed, ordering on remand that Defendant's sentences be ordered to run concurrently. The Supreme Court vacated the decision below, holding that the case was moot because Defendant has completed all of her obligations to both Kenton and Campbell Counties. View "Commonwealth v. Collinsworth" on Justia Law