Justia Kentucky Supreme Court Opinion Summaries

At issue was the role of the courts on judicial review of a final decision of the Kentucky Retirement Systems (KERS) as to a KERS member’s entitlement to disability retirement.A hearing officer recommended granting Plaintiff’s disability benefits application. The Board of Trustees of KERS (Board) denied Plaintiff’s application for disability benefits. The trial court affirmed the Board’s final order. The court of appeals reversed, concluding that substantial evidence compelled a finding in favor of Plaintiff. The Supreme Court reversed, holding (1) the KERS Board’s final decision must be supported by substantial evidence; (2) the standard set forth in McManus v. Ky. Retirement Systems, 124 S.W.3d 454, 458 (Ky. App. 2003), in conjunction with Ky. Rev. Stat. 13B.150, provides the proper standard for judicial review of KERS disability retirement decisions; (3) the hearing officer’s credibility determinations are not binding on the Board; and (4) substantial evidence supported the Board’s decision in this case, and the evidence in favor of Plaintiff was not so compelling that no reasonable person could have failed to be persuaded by it. View "Kentucky Retirement Systems v. Ashcraft" on Justia Law

At issue was various statutory amendments to the Kentucky Affordable Prepaid Tuition Fund (KAPT) contracts previously purchased by Appellants.The Court of Appeals reversed the judgment of the trial court concluding that the 2014 statutory changes affecting the 2003 contracts for prepaid college tuition entered into by Maze and the Board did not alter Appellants’ contracts, concluding that Appellants had expressly agreed to be bound by amendments to the contracts imposed by future statutory and regulatory changes. The Supreme Court reversed, holding (1) the KAPT contracts entered into by Appellants, and the underlying enabling statutes, did not authorize the contractual changes imposed by the retroactive application of the statutory amendments at issue in this case; and (2) the retroactive imposition of those amendments upon Appellants unlawfully impaired their contracts in violation of U.S. Const. art. I, 10 and Ky. Const. 19. View "Maze v. Board of Directors for the Commonwealth Postsecondary Education Prepaid Tuition Trust Fund" on Justia Law

The Supreme Court reversed Defendant’s conviction of first-degree murder but affirmed his remaining convictions and sentences, holding that several errors on the trial court in this case affected the propriety of Defendant’s murder conviction and demanded reversal of this conviction.Specifically, the Supreme Court held that the trial court erred in excluding certain evidence and in admitting other evidence and inappropriately handled the characterization of missing evidence. The Court then found that these errors constituted harmless error as to all of Defendant’s convictions, with the exception of the first-degree murder conviction, but that the errors did affect the propriety of Defendant’s murder conviction. View "Tigue v. Commonwealth" on Justia Law

At issue was whether the former Mayor of the City of Audubon Park and individual members of the City Council were personally liable for excess sanitation funds generated by a monthly assessment for the stated purpose of paying for sanitation services that was not devoted to trash collection and recycling but had been spent for other municipal purposes.The circuit court dismissed this action, brought by a taxpayer pursuant to section 180 of the Kentucky Constitution and Ky. Rev. Stat. 92.330 and 92.340, for failure to state a cause of action due to lack of injury to the City. The court of appeals reversed, concluding that Defendants were liable for the excess sanitation funds. The Supreme Court affirmed in part, reversed in part and remanded, holding (1) the complaint stated a cause of action because the statutes prohibit the use of the sanitation tax revenue for other non-sanitation purposes; but (2) liability was not absolute if the individuals who acted on behalf of the City could establish that the tax revenue was spent for valid City obligations. View "Scalise v. Sewell-Scheuermann" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the trial court’s denial of Defendants’ motion for summary judgment based on their claims of qualified immunity, holding that Defendants, officials in the Breathitt County school system, were entitled to qualified official immunity on the claims brought by Jane Doe and her mother based on sexual abuse Doe experienced as a middle-school student.Doe alleged that Defendants breached their ministerial duties to properly supervise students and to report abuse and acted in bad faith in handling misconduct claims involving a former teacher. The court of appeals concluded that qualified immunity applied because Defendants’ acts - or inactions - were discretionary, were within the scope of their authority, and were undertaken in good faith. The Supreme Court affirmed, holding (1) Defendants’ duty to supervise was a discretionary act, and the duty to report can have both discretionary and ministerial elements, depending on the facts; (2) Defendants’ response to a texting incident did not constitute a violation of a ministerial duty that destroyed qualified official immunity; and (3) Doe failed to show Defendants acted in bad faith so as to deprive them of qualified official immunity View "Ritchie v. Turner" on Justia Law

At issue in this visitation dispute was whether the trial judge’s questioning of a teenage boy exceeded the bounds of Ky. Rev. Stat. 403.290(1).Father had physical custody of the parties’ two sons when Mother pursued timesharing. Father moved to suspend Mother’s visitation/timesharing rights based upon the boys’ sexual abuse allegations. The trial court suspended Mother’s visitation rights to her two sons after conducting an in camera interview in chambers with one of the boys. The court of appeals affirmed, holding that the judge’s questioning exceeded the bounds of section 403.290(1) but that the error was harmless. The Supreme Court affirmed, holding that the trial court’s in camera questioning did not exceed the bounds of section 403.290(1) because it is appropriate for the court to make detailed inquiries especially when allegations of sexual abuse are at issue and that Mother received the process she was due. View "May v. Harrison" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of two counts of murder, possession of a handgun by a convicted felon, tampering with physical evidence, and being a first-degree persistent felony offender, holding that the trial court did not commit reversible error.After a jury convicted Defendant, the trial court accepted a total effective sentence of life imprisonment. The Supreme Court affirmed, holding that there was no reversible error in the trial court’s admission of certain evidence at trial and that the errors that did occur in this case did not rise to the level of reversible cumulative error. View "Mason v. Commonwealth" on Justia Law

The Supreme Court held that Plaintiff failed to meet the standard for judicial reversal of the Kentucky Retirement System (KERS) Board’s administrative decision to deny Plaintiff disability retirement benefits and thus affirmed the denial of benefits.The Board denied Plaintiff, a member of KERS, disability retirement benefits. The circuit court reversed on judicial review. The Court of Appeals reversed and remanded for reinstatement of the Board’s final decision denying Plaintiff’s claim, holding that the standard for judicial reversal of the Board’s decision was not met. On discretionary review, Plaintiff challenged the standard of judicial review set forth in McManus v. Kentucky Retirement Systems, 124 S.W. 3d 454 (Ky. App. 2003), and expressly adopted by the Supreme Court in Kentucky Retirement Systems v. Brown, 336 S.W.3d 8 (Ky. 2011). The Supreme Court held (1) the McManus standard remains proper; and (2) Plaintiff did not meet the standard for judicial reversal of the Board’s administrative decision. View "Bradley v. Kentucky Retirement Systems" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the trial court’s order granting summary judgment in favor of Defendants, jail personnel, on this wrongful death suit alleging that an inmate died of a hydrocodone overdose while in jail due to the negligence of the jail personnel.Specifically, the Court held (1) even if a jury could reasonably determine that Defendants’ ministerial duties were violated, Plaintiffs could not prove causation; and (2) because there was no guide issue of material fact concerning causation, summary judgment for Defendants was proper. View "Peterson v. Foley" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the trial court’s denial of Appellant’s motion to withdraw his guilty plea, holding that a conflict of interest did not exist when Appellant’s counsel represented him on the motion to withdraw the plea and that Appellant was not coerced into entering a guilty plea.Appellant entered a guilty plea to four counts of first-degree robbery and related crimes. Before he was sentenced, Appellant filed a motion to withdraw his plea based on his alleged misunderstanding regarding his sentence. The trial court denied the motion, and the court of appeals affirmed. The Supreme Court affirmed, holding that the record did not support either Appellant’s argument that his counsel had a conflict of interest at the hearing on the motion to withdraw the plea or that Appellant was coerced to enter the plea. View "Dorsey v. Commonwealth" on Justia Law