Justia Kentucky Supreme Court Opinion Summaries

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

The Supreme Court affirmed the decision of the court of appeals reversing the trial court’s grant of summary judgment against Plaintiffs in this insurance dispute, holding that summary judgment was improper.Plaintiffs sought chiropractic treatment for injuries sustained in an automobile accident. The bills were submitted to GEICO for payment under Plaintiffs’ basic reparations benefits (BRB). GEICO denied coverage and refused to pay for certain medical treatments Plaintiffs had already received. Plaintiffs then brought suit alleging that GEICO improperly denied coverage under their BRB based upon a medical records review and arguing that Ky. Rev. Stat. 304.39-270 requires an independent medical examination before GEICO can deny them BRB. In entering summary judgment against Plaintiffs, the trial court ruled that section 304.39-270 was permissive. The court of appeals reversed and remanded the case to the trial court for further proceedings. The Supreme Court affirmed, holding (1) section 304.39-270 fails to address when and how GEICO could deny BRB; and (2) because the trial court based its decision to grant summary judgment on the implications of section 304.39-270 rather than examining the remaining parts of the Motor Vehicle Reparations Act, Ky. Rev. Stat. 304.39-020(2), it was improper for the trial court to grant summary judgment without further review of the statutes. View "Government Employees Insurance Co. v. Sanders" on Justia Law

The Supreme Court reversed Defendant’s first-degree robbery conviction and sentence, vacated his persistent felony offender (PFO) conviction and sentence, which was predicated upon the underlying first-degree robbery conviction, and remanded the case to the trial court for further proceedings, holding that the trial court erred when it failed to direct a verdict on the first-degree robbery charge.After a jury convicted Defendant of first-degree robbery Defendant pleaded guilty to the PFO charge. The Supreme Court reversed in part and vacated in part, holding (1) the trial court did not err by failing to dismiss the indictment for an alleged violation of Defendant’s right to a speedy trial; (2) the trial court erred when it denied Defendant’s motion for a directed verdict on the first-degree robbery charge; and (3) the trial court should have conducted further review of Defendant’s request to make opening and closing statements himself. View "Lang v. Commonwealth" on Justia Law

At issue before the Supreme Court in this interlocutory appeal from the circuit court’s review of an agency ruling was whether Kentucky courts can undertake a statutorily created judicial review of an administrative agency’s final order when the appellant does not have a concrete injury.The Supreme Court adopted the United States Supreme Court’s test for standing as set forth in Lujan v. Defenders of Wildlife, 504 U.S. 555, 560-561 (1992), and held (1) the existence of a plaintiff’s standing is a constitutional requirement to prosecute any action in the Commonwealth courts; (2) Kentucky courts have the responsibility to ascertain, upon the court’s motion if the issue was not raised by a party opponent, whether a plaintiff has constitutional standing to pursue the case in court; and (3) in the instant case, the putative petitioner did not have the requisite constitutional standing to pursue her case in Kentucky courts. View "Commonwealth v. Sexton" on Justia Law

The Supreme Court reversed Defendant’s convictions of two counts of murder and sentence of life without the possibility of parole for twenty-five years, holding that the trial court abused its discretion by proceeding with voir dire without Defendant present.On appeal, Defendant argued that the trial court improperly conducted voir dire when Defendant was unable to be present and that the court erred when it failed to grant immunity pursuant to Ky. Rev. Stat. 503.085(1). The Supreme court reversed, holding (1) Defendant was deprived of his constitutional right to be present at jury selection pertaining to thirty-one jurors that were questioned in his absence, and the error was not harmless; and (2) the trial court did not commit reversible error when it failed to grant immunity pursuant to Ky. Rev. Stat. 503.085. View "Truss v. Commonwealth" on Justia Law