Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of murder and sentencing him to thirty years in prison, holding that there was no error in the proceedings below.Specifically, the Court held (1) the trial court did not err by denying Defendant's motion to suppress a videotaped conversation between Defendant and family members that took place in an interrogation room shortly after Defendant was arrested; (2) the trial court did not err by denying Defendant's motions for a mistrial and a new trial; and (3) the trial court did not err by denying Defendant's motion to prohibit the introduction of crime scene and autopsy photographs. View "Easterling v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of murder and being a convicted felon in possession of a handgun and sentencing him to life imprisonment, holding that there was no error in the proceedings below.Specifically, the Court held, contrary to Defendant's arguments on appeal, that (1) the trial court did not err in denying Defendant's request for a first-degree manslaughter instruction under extreme emotional disturbance; (2) the trial court did not err in denying Defendant's motion to admonish the jury as to the use of threats; and (3) no discovery violation occurred regarding Defendant's prior convictions prior to the penalty phase. View "Posey v. Commonwealth" on Justia Law

The Supreme Court accepted certificate of a question of law from a federal district court and answered that Seven Counties Services, Inc.'s participation in and its contributions to the Kentucky Employees Retirement System (KERS) are based on a statutory obligation, rather than a contractual obligation.In 1979, the then-Governor designated Seven Counties, a non-profit provider of mental health services, a "department" for purposes of participating in KERS, a public pension system. Thereafter, Seven Counties paid into KERS to secure retirement benefits for its employees. In 2013, Seven Counties initiated bankruptcy proceedings primarily to reject its relationship with KERS as an executory contract. KERS countered that Seven Counties should be required to comply with its statutory obligations to contribute to KERS. The bankruptcy court determined that Seven Counties' relationship with KERS was contractual and, therefore, that Seven Counties could reject the contract in bankruptcy and leave the retirement system. The Supreme Court disagreed, holding that the relationship between KERS and Seven Counties was statutory. View "Kentucky Employees Retirement System v. Seven Counties Services, Inc." on Justia Law

In this lawsuit between AllyAlign Health, Inc. and Signature Advantage, LLC the Supreme Court granted AllyAlign's motion for an order to compel arbitration of all claims, holding that a carve-out provision in the parties' contract for certain claims to be decided by a court did not negate the mandate of the Commercial Arbitration Rules and Arbitration Procedures of the American Arbitration Association (AAA's Rules) that the initial arbitrability of claims is to be determined by the arbitrator, not the courts.AllyAlign contracted with Signature Advantage for AllyAlign's services. The contract contained an arbitration provision incorporating the AAA's Rules. Signature Advantage later sued AllyAlign for breach of contract and other claims. AllyAlign moved to compel arbitration on all the claims based on the AAA's Rules that delegate to the arbitrator the initial decision about the arbitrability of claims arising between the parties. In response, Signature Advantage argued that the language of the carve-out provision exempted equitable claims from arbitration. The trial court granted in part the motion to compel arbitration but denied the motion for the claims it found to demand equitable relief. The Supreme Court compelled arbitration of all claims, holding that the trial court's order declining to refer all the claims of the complaint was erroneous. View "AllyAlign Health, Inc. v. Signature Advantage, LLC" on Justia Law

The Supreme Court affirmed in part and dismissed in part the appeal brought by Judge Beth Lewis Maze from the denial of the Judicial Conduct Commission (JCC) denying Judge Maze's motions in JCC proceedings stemming from the JCC's five-count misconduct charge against Judge Maze, holding that the JCC did not err in denying Judge Maze's motion for a stay and that Judge Maze's other challenges were either moot or procedurally infirm.While the misconduct charges against Judge Maze were pending before the JCC, a grand jury charged Judge Maze with two counts of second-degree forgery and one count of tampering with public records. Thereafter, Judge Maze filed three motions in her JCC proceedings. The JCC denied relief on all of the motions. The Supreme Court affirmed the JCC's denial of Judge Maze's motion to stay, dismissed as moot Judge Maze's challenge to the JCC's denial of her motion for a continuance, and dismissed Judge Maze's challenge to the JCC's denial of Judge Maze's motion for an informal hearing, holding that the balance of the equities favored allowing the JCC to move ahead with its disciplinary proceedings. View "Maze v. Kentucky Judicial Conduct Commission" on Justia Law

The Supreme Court vacated the decision of the court of appeals in this interlocutory appeal from the denial of a judicial statements privilege in litigation between two physicians, holding that the matter at issue was beyond the parameters of appellate interlocutory jurisdiction.Plaintiff alleged that Defendant engaged in a pattern of conduct intended to damage Plaintiff's reputation and lure her patients to Defendant's medical practice. Defendant filed a motion to dismiss asserting the protections of the judicial statements privilege for absolute immunity based on a previous medical malpractice action that both physicians were involved in. The trial court denied the motion to dismiss. The court of appeals concluded that Defendant was immune from some, but not all, of Plaintiff's claims. The Supreme Court vacated the court of appeals' decision, holding (1) the collateral order doctrine is a narrowly circumscribed exception to the final judgment rule; and (2) the judicial statements privilege is not a form of immunity, the denial of which allows for an interlocutory appeal under the collateral order doctrine. View "Maggard v. Kinney" on Justia Law

The Supreme Court vacated Defendant's conviction and twenty-seven-year sentence for the murder of her mother and remanded this case for a new trial, holding that the trial court's application of principles in Ake v. Oklahoma, 470 U.S. 68 (1985), in this case led to errors that entitled Defendant to a new trial.Specifically, the Court held (1) the trial court erred by failing to grant Defendant's request for funds to hire a mental health professional for a defense examination pursuant to Ake and instead ordering that a criminal responsibility examination be conducted by the Kentucky Correctional Psychiatric Center (KCPC); (2) the fruits of the erroneous trial court that resulted in a criminal responsibility report prepared by the KCPC should be excluded upon retrial; and (3) testimony elicited by the Commonwealth KCPC staff member regarding Defendant's appreciation of the consequences of her acts was improper. View "Conley v. Commonwealth" on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that the trial court lacked jurisdiction over Defendant's motion for shock probation, holding that the Commonwealth waived its ability to raise that issue on appeal by failing to object during the trial court proceedings.Defendant pled guilty to two counts of distribution of matter portraying a sexual performance by a minor and twenty counts of possession of matter portraying a sexual performance by a minor. While serving his sentence, Defendant filed a motion for shock probation. The Commonwealth did not object to the trial court's exercise of jurisdiction over that motion, and the trial court granted the motion. For the first time on appeal, the Commonwealth argued that the trial court was without jurisdiction to entertain Defendant's motion. The court of appeals agreed and reversed. The Supreme Court reversed and remanded the case, holding that the Commonwealth's issue was not reviewable by the Supreme Court because the Commonwealth never objected to the trial court's exercise of jurisdiction over Defendant's motion. View "Martin v. Commonwealth" on Justia Law

In this wrongful death suit, the Supreme Court overruled Chambers v. Ideal Pure Milk Co., 245 S.W.2d 589 (Ky. 1952), insofar as it holds a police officer cannot be the proximate or legal cause of damage inflicted on a third party by a fleeing suspect and adopted the majority rule that will allow juries to determine whether a pursuing officer's actions were a substantial factor in causing injury to a third party and apportion fault accordingly.Luiz Gonzales was killed when a criminal suspect crashed into Gonzales' vehicle during a high-speed chase initiated by a Scott County deputy sheriff. Gonzales' estate filed a wrongful death suit against the deputy sheriff and the county sheriff. The circuit court granted summary judgment for Defendants based on Chambers and its per se no proximate cause rule. The court of appeals affirmed. The Supreme Court reversed and remanded, holding that, applying the new standard announced today, the factual allegations in this case were sufficient to create a disputed issue of material fact as to whether the deputy sheriff negligently conducted his pursuit of the criminal suspect. View "Gonzalez v. Johnson" on Justia Law

The Supreme Court reversed the court of appeals' decision holding 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 (Child), holding that the Kentucky General Assembly has not specifically directed Kentucky's courts to make SIJ findings.Child was detained by United States immigration authorities in Arizona and temporarily placed with a cousin pending immigration proceedings. An adult resident of Newport, Kentucky filed a dependency petition in the Campbell County Family Court regarding Child. The court concluded that it was without the jurisdictional authority to undertake SIJ findings because such findings were not relevant to the core dependency, neglect, and abuse matters before the court. The court of appeals reversed. The Supreme Court reversed, holding that Kentucky courts are not required to make additional findings related to SIJ classification unless the court first determines that the evidence to be gathered from such a hearing is relevant to the child's best interests. View "Commonwealth, Cabinet for Health & Family Services v. N.B.D." on Justia Law