Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals concluding that the circuit court had jurisdiction in this matter and denying a writ of prohibition preventing the circuit court from adjudicating an action filed by the Lexington Herald-Leader, holding that, as a matter of law, the circuit court had subject-matter jurisdiction over the underlying action filed by the Herald-Leader.In the underlying action, the Herald-Leader sought judicial review of the determination of the Kentucky Legislative Research Commission (LRC) that certain records requested by the Herald-Leader were not subject to disclosure under Kentucky's Open Records Act. Appellants, acting co-directors of the LRC, sought a writ of prohibition preventing the circuit court from adjudicating the action, asserting that the General Assembly had not granted the circuit court subject-matter jurisdiction to hear the merits of Herald-Leader's claims. The court of appeals denied the writ. The Supreme Court affirmed, holding (1) the circuit court had subject-matter jurisdiction to adjudicate the underlying case arising from the Herald-Leader's legislative records request; and (2) the trial court did not lack jurisdiction based on the separation of powers doctrine. View "Harrison v. Hon. Phillip J. Shepherd" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the decision of the Workers' Compensation Board affirming the decision of the administrative law judge (ALJ) denying benefits to Appellant for a knee injury and two back surgeries, finding they were not causally related to his employment and therefore not compensable, holding that the ALJ's conclusions were supported by substantial evidence.The ALJ awarded Appellant temporary total disability, permanent partial disability, and medical benefits for a back strain he sustained while employed but denied benefits for his knee injury and back surgeries. The board and court of appeals affirmed. The Supreme Court affirmed, holding (1) the ALJ's finding that Appellant's knee injury was not work-related and therefore not compensable was supported by substantial evidence; and (2) the ALJ's conclusions regarding Appellant's back surgeries were supported by substantial evidence. View "Wilkerson v. Kimball International, Inc." on Justia Law

The Supreme Court affirmed the opinion of the court of appeals affirming an order of the circuit court dismissing Plaintiff's claims for personal injuries in a civil action against her landlords, holding that summary judgment was proper.Plaintiff's complaint alleged that she sustained injuries as a result of a porch railing giving way, causing her to fall and suffer an ankle injury. The Supreme Court affirmed the lower courts' denial of relief, holding (1) Defendants were not liable to Plaintiff under Kan. Rev. Stat. 446.070 or the Uniform Residential Landlord and Tenant Act; and (2) Defendants were not liable to Plaintiff under common-law safety rules. View "Waugh v. Parker" on Justia Law

The Supreme Court affirmed Defendant's conviction and sentence for first-degree sexual abuse and of being a first-degree persistent felony offender (PFO1), holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) Defendant's argument that he was denied a unanimous verdict because the jury was only instructed on one count of sexual abuse when two separate allegations were introduced at trial was not subject to appellate review; and (2) Defendant was not entitled to a new trial because the jury pool was not tainted due to a social media post. View "Rudd v. Commonwealth" on Justia Law

The Supreme Court reversed the judgment of the court of appeals ruling that the family court erred in declining to conduct a special immigrant juvenile (SIJ) hearing at the disposition phase of a dependency, neglect and abuse case regarding an unaccompanied Guatemalan child, holding that Kentucky courts are not required to engage in SIJ status factfinding.The family court determined that it was without the jurisdictional authority to undertake SIJ findings because such findings were not relevant to the core dependency, neglect, and abuse issues before the court. The mother appealed, arguing that the circuit court erred by not making the findings required for SIJ status. The court of appeals agreed. The Supreme Court reversed, holding (1) the General Assembly has not specifically directed Kentucky's courts to make SIJ findings, and therefore, the family could need not make additional findings relevant to the child's SIJ classification, upon request, in every case; and (2) under the circumstances of this case, the proper place for SIJ status factfinding was in federal immigration court. View "Commonwealth v. N.B.D." on Justia Law

The Supreme Court vacated Defendant's conviction and sentence for the murder of her mother and remanded this case for a new trial, holding that the trial court's application of the principles in Ake v. Oklahoma, 470 U.S. 68 (1985), led to errors that required that the circuit court's judgment be vacated and a new trial held.Specifically, the Supreme Court held (1) under the circumstances of this case, the trial court should have summarily granted funds for a defense examination pursuant to Ake; (2) the trial court by permitting the Commonwealth to have access to a Kentucky Correctional Psychiatric Center (KCPC) criminal responsibility report written by Dr. Amy Trivette, a KCPC staff member; and (3) testimony elicited by the Commonwealth that overemphasized the insanity defense terminology was improper. The Court then remanded the case for a new trial. View "Conley v. Commonwealth" on Justia Law

The Supreme Court vacated the trial court's grant of summary judgment in favor of the Bingham Greenbaum Doll law firm (Bingham) in this ongoing dispute between Bingham and Meredith Lawrence, holding that the trial court erroneously granted summary judgment in favor of Bingham.The litigation in this case resulted in the foreclosure and judicial sale of some of Lawrence's property. The Supreme Court vacated the summary judgment and remanded the case to the trial court for further proceedings, holding (1) Lawrence's arguments challenging the Gallatin Circuit Court's jurisdiction over his case were without merit; and (2) the trial court erred in granting Bingham summary judgment because genuine issues of material fact remained unresolved. View "Lawrence v. Bingham Greenebaum Doll, LLP" on Justia Law

The Supreme Court vacated the decision of the court of appeals concluding that the searches and seizures leading to Defendant's conviction were illegal under the Fourth Amendment to the United States Constitution and section 10 of the Kentucky Constitution, holding that the circuit court's suppression order was insufficient for appellate review.Defendant entered a conditional Alford plea to one count of possession of a controlled substance, third degree, and a conditional Alford plea to one count of possession of marijuana. On appeal, Defendant challenged the denial of his motions to suppress evidence obtained as a result of a traffic stop. The court of appeals upheld the denial of his motions to suppress. The Supreme Court remanded the case for entry of sufficient findings of fact, holding (1) the court of appeals erred in analyzing Defendant's claim that the searches and seizures were illegal under the state and federal constitutions; but (2) the circuit court's order of suppression was factually insufficient for appellate review of Defendant's claim that his detention was unlawful and that the evidence must be excluded as fruit of the poisonous tree. View "Warick v. Commonwealth" on Justia Law

In this dependency, neglect, and abuse proceeding the Supreme Court vacated the order of the court of appeals reversing the family court's decision denying an indigent mother's request for expert funding and finding the child to be a neglected child, holding that the court of appeals lacked jurisdiction.After the family court made a finding of neglect, the mother failed timely to file her notice of appeal. The family court, however, permitted a belated appeal, citing excusable neglect. In reversing the family court's expert funding decision, the court of appeals found that the mother's due process rights were impacted by her inability to hire an expert. The Supreme Court vacated the court of appeals' order, holding that the court lacked jurisdiction to consider the mother's appeal because the mother failed timely to file her appeal, and there was no excusable neglect in this case. View "Commonwealth v. H.C." on Justia Law

In this medical malpractice action, the Supreme Court reversed the opinion of the court of appeals reversing the judgment of the trial court granting summary judgment in favor of Dr. Paul Wesley Lewis and Ashland Hospital Corporation (KDMC) after finding that David Shackelford could not establish a prima facie case of negligence, holding that, contrary to the decision of the court of appeals, expert opinion evidence was required to establish causation.The circuit court granted summary judgment for Dr. Lewis and KDMC after determining that Shackelford could not establish a prima facie case of negligence. The court of appeals reversed, finding that the issue of causation in this case did not require expert medical testimony. The Supreme Court reversed, holding (1) the res ipsa loquitor exception did not apply to this case, and expert testimony was necessary; and (2) the proffered expert opinion evidence failed to raise a genuine issue of material fact on the issue of causation. View "Ashland Hospital Corp. v. Lewis" on Justia Law