Justia Kentucky Supreme Court Opinion Summaries

Tyler Story was charged with first-offense DUI after being observed driving at high speed with one headlight and failing field sobriety tests. He admitted to drinking and had a breathalyzer result of 0.178. Story requested an independent blood test, which was drawn but not tested immediately. The sample was stored by the police. Story was charged and sought to preserve the sample for independent testing. The District Court suppressed the breathalyzer results due to an error in administration, leaving the Commonwealth without evidence. The Commonwealth obtained a warrant to test the independent blood sample, which Story opposed.The Campbell District Court denied Story's motion to return the blood sample for independent testing, finding he had abandoned it. The Campbell Circuit Court denied Story's petition for a writ of prohibition against the search warrant. The District Court allowed the Commonwealth to test the sample, which showed a blood alcohol level above the legal limit. Story entered a conditional guilty plea and appealed. The Circuit Court and the Court of Appeals affirmed the District Court's decisions, with the Court of Appeals disagreeing on the abandonment but upholding the testing as evidence.The Supreme Court of Kentucky reviewed the case and found that Story's statutory right to an independent blood test was infringed, but the error was harmless since the breathalyzer test was suppressed. However, the Court concluded that the Commonwealth's testing of the blood sample was conducted under an invalid warrant and without Story's consent, violating his Fourth Amendment rights. The Court reversed the District Court's denial of Story's motion to suppress the test results, vacated his conviction, and remanded for further proceedings. View "STORY V. COMMONWEALTH OF KENTUCKY" on Justia Law

Blake Jeffreys was arrested during a sting operation after unknowingly communicating with an undercover police officer and arranging to meet at a hotel for sex in exchange for $120. On May 14, 2021, Jeffreys pled guilty to promoting human trafficking. The Jefferson Circuit Court sentenced him to one year in prison, probated for five years, and ordered him to pay a $10,000 fee under KRS 529.130. Jeffreys requested the trial court waive the payment under KRS 534.030(4), but the court declined. Jeffreys appealed, arguing the fee was an unconstitutional excessive fine and should be waived.The Court of Appeals rejected Jeffreys' arguments and affirmed the trial court's decision. Jeffreys sought discretionary review from the Kentucky Supreme Court, focusing solely on the argument that the fee should be waived. The Kentucky Supreme Court granted the motion for review.The Kentucky Supreme Court affirmed the Court of Appeals' decision. The court held that KRS 529.130 imposes a human trafficking victims service fee, not a fine, and is not subject to waiver under KRS 534.030(4). The court also found that KRS 453.190, which defines a "poor person" for the purpose of waiving court costs, does not apply to the fee imposed under KRS 529.130. However, the court noted that Jeffreys could seek a show cause hearing under KRS 534.020(3)(a)1 to potentially reduce or waive the payment based on his ability to pay. The court emphasized that the trial court should consider various factors, including the defendant's financial status and dependents, when determining the ability to pay. View "JEFFREYS V. COMMONWEALTH OF KENTUCKY" on Justia Law

James Javonte Crite appealed the Daviess Circuit Court's denial of his motion to suppress evidence obtained during a search of his apartment. Crite was convicted of possession of a firearm by a convicted felon, resulting in a two-year sentence and shock probation. He argued that his landlord had no right to enter his apartment without an emergency and lacked authority to grant police entry, making the search and seizure of the firearm illegal.The Daviess Circuit Court denied Crite's motion to suppress, finding that the landlord had the right to enter the apartment under the "emergency entry" clause of the lease due to significant electrical damage that posed a danger to the tenants. The court also concluded that the police entry was reasonable to ensure the safety of the landlord and the electrician, given the information that Crite was a schizophrenic off his medication, had acted irrationally, and there was a firearm in the apartment.The Kentucky Court of Appeals affirmed the trial court's decision, agreeing that the landlord's entry was justified by the emergency and that the police entry did not violate the Fourth Amendment as they were facilitating the landlord's legitimate interest in addressing the emergency.The Supreme Court of Kentucky reviewed the case and affirmed the lower courts' decisions. The Court held that the landlord's entry was justified under the lease's emergency entry clause due to the electrical damage posing a risk to the tenants. The police entry was deemed reasonable and necessary to ensure the safety of the landlord and the electrician. The Court also held that the seizure of the AR-15 rifle was lawful under the plain view doctrine, as the officers were lawfully present and the incriminating nature of the firearm was immediately apparent. View "CRITE V. COMMONWEALTH OF KENTUCKY" on Justia Law

A group of inmates sentenced to death filed a declaratory judgment action in the Franklin Circuit Court, challenging the validity of the Kentucky Department of Corrections' (DOC) execution regulations. In 2010, the court issued a temporary injunction preventing the execution of an inmate under the then-current lethal injection protocols. The Commonwealth's attempt to dissolve this injunction was denied, and the court's decision effectively halted all executions until a final judgment was rendered.The DOC revised its lethal injection regulations in March 2024, prompting the Commonwealth to request the lifting of the 2010 injunction. The Franklin Circuit Court reserved ruling on this motion, noting that the original protocols were no longer in effect and questioning whether the injunction still applied. The court highlighted that no current death warrants were active and declined to issue an advisory opinion on the amended regulations' constitutionality.The Commonwealth sought interlocutory relief from the Court of Appeals under RAP 20(B), arguing that the circuit court's reservation of ruling effectively modified the injunction. The Court of Appeals recommended transferring the matter to the Kentucky Supreme Court. Both parties supported this transfer, and the Supreme Court accepted the case.The Kentucky Supreme Court dismissed the action without prejudice, ruling that RAP 20(B) does not allow for interlocutory relief from an order that maintains an injunction. The court noted that the circuit court's decision to reserve ruling did not constitute a new or modified injunction and maintained the status quo. The Commonwealth had other potential remedies, such as requesting a definitive ruling or filing a petition for a writ of mandamus, but did not pursue these options. View "DEPARTMENT OF CORRECTIONS V. BAZE" on Justia Law

Kimminee Costello, an event manager for Thompson Catering & Special Events, traveled to Las Vegas for a work conference. After the conference ended, she had some free time before her flight and decided to shop for souvenirs. While descending stairs at her hotel, she tripped and injured her right ankle, requiring multiple surgeries. Costello filed for workers' compensation benefits, but the Administrative Law Judge (ALJ) dismissed her claim, finding that her injury occurred during a personal errand, not within the scope of her employment.The ALJ's decision was appealed to the Workers’ Compensation Board, which reversed the ALJ's ruling and remanded the case for further findings on medical benefits and indemnity. The Kentucky Court of Appeals affirmed the Board's decision, leading Thompson Catering to appeal to the Supreme Court of Kentucky.The Supreme Court of Kentucky affirmed the Court of Appeals' decision. The Court held that the ALJ misapplied the traveling employee exception to the going and coming rule. The Court determined that Costello's brief shopping trip did not constitute a substantial deviation from her employment. The injury occurred during a period of enforced hiatus while she awaited her return flight, and the deviation was minor and insubstantial. Therefore, the injury was deemed work-related and compensable under Kentucky law. View "THOMPSON CATERING & SPECIAL EVENTS V. COSTELLO" on Justia Law

The case involves disputes over horse consignment contracts between Ramsey and Hickstead Farms and Dapple Stud, LLC. Ramsey and Hickstead entered into agreements with Dapple Stud to sell their horses at auction, with Dapple Stud acting as the consigning agent. The sales proceeds were deposited into Dapple Sales' checking account, managed by Mike Akers, who allegedly misappropriated the funds, resulting in Ramsey and Hickstead not receiving their due proceeds.The Fayette Circuit Court granted summary judgment in favor of Dapple Stud and Dapple Sales, dismissing Ramsey and Hickstead's breach of contract claims. The court also required Ramsey and Hickstead to pay restitution to Dapple Stud for amounts previously paid. Additionally, the court denied Ramsey and Hickstead's motions to file third-party complaints against Akers and Dapple Sales, citing the statute of limitations.The Supreme Court of Kentucky reviewed the case and found that Ramsey and Hickstead had valid consignment contracts with Dapple Stud, which were breached when the sales proceeds were not remitted. The court held that Akers, as the manager of Dapple Stud, had the authority to bind the company in these transactions. The court reversed the summary judgment in favor of Dapple Stud and Dapple Sales and the restitution orders, remanding the case for further proceedings to determine the amounts owed to Ramsey and Hickstead, including interest.However, the court affirmed the lower court's decision to bar the third-party complaints against Akers and Dapple Sales due to the statute of limitations. The court also upheld the dismissal of the conversion and theft claims against Dapple Sales. The case was remanded to the Fayette Circuit Court for further proceedings consistent with the Supreme Court's opinion. View "RAMSEY V. DAPPLE STUD, LLC" on Justia Law

Thomas Dunbar, also known as "Sam," passed away without any direct descendants. Connie Corner, who was not related to Dunbar by blood, probated a will that purportedly left his entire estate to her. Tyler Popplewell, Dunbar's grandnephew, filed a motion in Russell Circuit Court alleging that the will was a product of fraud and undue influence, and requested the court to declare it null and void. Corner later moved to dismiss the case, arguing that Tyler lacked standing to bring the claim. The trial court sustained Corner's motion, leading Tyler to appeal.The Russell Circuit Court initially dismissed Tyler's case on the grounds of lack of standing, as Corner had argued. Tyler then filed a motion to set aside the judgment, claiming he did not receive notice of the hearing. Additionally, Imogene Popplewell, Dunbar's sister and Tyler's grandmother, attempted to intervene as a successor plaintiff, but her motion was denied as untimely. The trial court reaffirmed its dismissal, citing the mailbox rule in denying Tyler's motion to set aside the judgment.The Kentucky Court of Appeals reversed the trial court's decision, holding that Corner had waived the issue of standing by not raising it in her initial response to Tyler's complaint. The Court of Appeals based its decision on the precedent set in Harrison v. Leach, which emphasized that standing issues must be raised at the outset of litigation. Corner then sought discretionary review from the Supreme Court of Kentucky.The Supreme Court of Kentucky affirmed the Court of Appeals' decision, agreeing that Corner had waived the standing issue by failing to raise it promptly. The Court emphasized that defendants must address standing issues early in the litigation process to avoid inefficiencies and potential gamesmanship. The case was remanded to the trial court for a trial on its merits. View "CORNER V. POPPLEWELL" on Justia Law

Jaime Morales, a Sheriff’s Deputy with the Scott County Sheriff’s Office, was shot and paralyzed during a law enforcement operation to apprehend a bank robbery suspect in September 2018. Morales filed a negligence suit against several employees of the City of Georgetown and the Georgetown Police Department, alleging that their actions led to his injuries. The case centers on whether the government defendants are immune from suit.The Scott Circuit Court granted summary judgment to the defendants, ruling that they were immune from Morales’s claims. The court found that Officer Joseph Enricco and Lieutenant James Wagoner were entitled to qualified official immunity for their discretionary actions, and that the City and the Georgetown Police Department were immune from vicarious liability and negligence claims.The Kentucky Court of Appeals affirmed in part and reversed in part, holding that some of Lt. Wagoner’s actions were ministerial and not protected by qualified official immunity. The court also found that the City and the Georgetown Police Department could be held vicariously liable for Lt. Wagoner’s ministerial actions and directly liable for their own negligence.The Supreme Court of Kentucky affirmed in part, reversed in part, and remanded the case. The court held that Officer Enricco’s decision to fire his weapon was discretionary and protected by qualified official immunity. However, it found that Lt. Wagoner had a ministerial duty to formulate a plan to apprehend the suspect and to enforce certain training requirements, making him potentially liable for negligence. The court also ruled that the City and the Georgetown Police Department could be held liable for Lt. Wagoner’s ministerial actions but were immune from direct negligence claims related to training and personnel selection. View "MORALES V. CITY OF GEORGETOWN, KENTUCKY" on Justia Law

In the early morning of October 13, 2020, Calvin Taylor was found dead in his home in Hopkinsville, Kentucky, with duct tape on his mouth and arm, and three gunshot wounds. A neighbor, Treesha Shelton, heard gunshots and saw a light-colored vehicle outside Taylor’s home. Surveillance footage showed a silver minivan and a silver Saturn near Taylor’s home around the time of the murder. Larayna Manning and her son, Anthony, were known to frequent Taylor’s home, where Taylor sold crack cocaine. Manning was interviewed by police but provided limited information. A search of a minivan at Manning’s home revealed a large amount of crack cocaine. DNA evidence linked Manning to duct tape found at the crime scene.The Christian Circuit Court convicted Manning of complicity to murder and complicity to first-degree robbery, sentencing her to life imprisonment. Manning appealed, arguing that her right to a speedy trial was violated, that evidence of a prior home invasion was improperly admitted, that the Commonwealth improperly used her son’s Alford plea as substantive evidence of her guilt, and that her right to remain silent was infringed upon.The Supreme Court of Kentucky reviewed the case. It found that the delay in Manning’s trial was largely due to valid reasons, such as the need for DNA evidence, and that her right to a speedy trial was not violated. The court also held that the Commonwealth provided reasonable notice of its intent to introduce prior bad acts evidence and that any error in admitting this evidence was not palpable. The court acknowledged that the Commonwealth improperly used Anthony’s Alford plea as substantive evidence of Manning’s guilt but concluded that this did not result in a substantial possibility of a different outcome. Finally, the court found no improper comment on Manning’s right to remain silent.The Supreme Court of Kentucky affirmed Manning’s convictions and sentence. View "MANNING V. COMMONWEALTH" on Justia Law

On April 25, 2018, John Crawford stopped his tanker truck on the shoulder of Interstate 71 to remove loose dogs from the roadway. Kentucky State Trooper Michael Gonterman arrived to assist, parking his cruiser with flashing lights. Shortly after, three vehicles approached: a Nissan Altima, a box truck driven by James Baumhower, and a tractor trailer driven by Teddy Seery. Traffic slowed, and Baumhower swerved into the right lane to avoid the Altima, followed by Seery, who collided with Baumhower’s truck. The collision caused the box truck to flip and slide, pinning Crawford and knocking Gonterman off the bridge, resulting in severe injuries to Gonterman and Crawford’s death.The Henry Circuit Court granted summary judgment for the defendants, applying the Firefighter’s Rule, which bars claims by public employees injured while responding to specific risks inherent in their duties. The court found all three prongs of the rule met: the defendants were similarly situated to other drivers, Gonterman was responding to a specific risk, and the accident arose from that risk. The Court of Appeals reversed, holding the defendants did not meet the first and third prongs, as they had no connection to the loose dogs and the accident was independent of the specific risk.The Supreme Court of Kentucky affirmed the Court of Appeals. It clarified that the Firefighter’s Rule does not extend to independent and intervening negligence unrelated to the specific risk that necessitated the public employee’s presence. The court held that the negligence of Seery and Baumhower was independent of the hazard posed by the loose dogs, thus the rule did not bar Gonterman’s claims. The case was remanded to the Henry Circuit Court for further proceedings. View "WOOSTER MOTOR WAYS, INC. V. GONTERMAN" on Justia Law