Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of two counts of trafficking in a controlled substance in the first degree and other drug-related offenses and his sentence of twenty years’ imprisonment, holding that there was no reversible error in this case.Specifically, the Court held (1) the Commonwealth violated the notice requirement set forth in Ky. Rev. Stat. 508 by waiting until forty hours prior to trial to disclose a confidential informant’s identity, but the late disclosure did not compel a new trial; (2) Defendant’s claims of error with respect to the complicity to trafficking in a controlled substance in the first degree conviction were unavailing; (3) the parole officer’s “good time” credit testimony presented during the penalty phase of trial did not violate Defendant’s right to due process; and (4) the prosecutor’s closing argument during the penalty phase did not amount to flagrant misconduct. View "Little v. Commonwealth" on Justia Law

The Supreme Court affirmed the holdings of the circuit court and court of appeals determining that public defenders, as employees of the Department of Public Advocacy (DPA), a statutorily-created agency of the Commonwealth, are entitled to assert the defense of qualified immunity within the proper context.After he was discharged from custody, Plaintiff filed a malpractice action against his former attorney, alleging that as a result of Defendants negligent advice regarding parole eligibility, Plaintiff had served longer in prison than he expected when entering his guilty plea. The circuit court granted Defendant’s motion to dismiss, finding that Defendant was entitled to qualified official immunity from suit as an employee of the DPA. The Supreme Court affirmed, holding (1) public defenders performing discretionary tasks in good faith and within the scope of their employment are entitled to assert qualified immunity to any negligence claim; and (2) Defendant was entitled to the defense of qualified immunity under the circumstances of this case. View "Jacobi v. Holbert" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing Defendant’s convictions for possession of a controlled substance, first degree, first offense, and for tampering with physical evidence, holding that traffic stop in this case was unreasonably prolonged, and therefore, the incriminating evidence must be suppressed.Defendant’s convictions were based on evidence discovered after a canine sniff search of Defendant’s vehicle conducted during a traffic stop. The court of appeals concluded that the sniff search prolonged the traffic stop and that the incriminating evidence should have been suppressed. The Supreme Court affirmed, holding that the free air sniff of Defendant’s vehicle impermissibly extended the duration of the stop. View "Commonwealth v. Lane" on Justia Law

The Supreme Court affirmed Appellant’s conviction of first-degree trafficking in a controlled substance, felony possession of a firearm, and being a first-degree persistent felony offender and sentence of twenty years’ imprisonment, holding that Defendant’s arguments on appeal were unavailing.Specifically, the Court held (1) any minor discrepancies in the search warrant did not require suppression of the evidence; (2) Appellant’s right to be free from double jeopardy was not violated because the trial court instructed the jury on two counts of trafficking instead of one; (3) it was not clearly unreasonable for the jury to convict Appellant of trafficking in heroin and methamphetamine; (4) the trial court did not abuse its discretion in denying Appellant’s request for expert funding; and (5) the length of Appellant’s sentence did not violate Ky. Rev. Stat. 532.110(1)(c) or 532.080(6)(b). View "Johnson v. Commonwealth" on Justia Law

The Supreme Court affirmed Defendant’s convictions of murder, driving under the influence, and first-degree assault and their corresponding sentences, holding that there was no reversible error in the proceedings below.Specifically, the Court held (1) the trial court did not err in failing to direct a verdict on Defendant’s murder charge; (2) the trial court did not abuse its discretion in allowing the Commonwealth’s expert witness to testify concerning Defendant’s potential head injury and blood glucose level; (3) the trial court erred in allowing a deputy coroner to testify regarding the results of the crash victim’s blood tests, but the error was harmless; (4) even if the Commonwealth committed prosecutorial misconduct, any such error would not be palpable; (5) Defendant’s right to be free from double jeopardy was not violated through his convictions for both wanton murder and driving under the influence; and (6) the trial court did not err in imposing a $500 fine on Defendant for driving under the influence. View "Bowling v. Commonwealth" on Justia Law

The Supreme Court affirmed the circuit court’s denial of Defendant’s motion to convert court costs to a jail term, holding that Defendant did not properly preserve the imposition for court costs for appellate review.Defendant pled guilty to several drug offenses and received ten- and twenty-year sentences, respectively, to be served consecutively, totaling thirty years’ imprisonment. The circuit court also imposed court costs totaling $302 and provided that Defendant must pay those costs within 180 days of his release from prison. Defendant filed a motion to convert court costs to a definite jail term under Ky. Rev. Stat. 534.060. The circuit court denied the motion. Defendant then filed a motion to waive or convert the court costs. The circuit court also denied this motion. The Supreme Court affirmed, holding (1) court costs are mandatory in a criminal proceeding and will be waived or modified only upon a showing of “poor person” status; (2) without a determination or request for a determination of Defendant’s financial status, the Court will not review the imposition of court costs; and (3) court costs are not a component of a plea agreement. View "Elliott v. Commonwealth" on Justia Law

Class action is available to plaintiffs seeking recovery under the State’s prevailing-wage law, Ky. Rev. Stat. 337.505-550, and the circuit court did not abuse its discretion in certifying the underlying action for backpay and statutory damages under the prevailing-wage law as a class action.A group of plaintiffs, claiming for themselves and for other similarly situated, brought the underlying action to recover backpay and statutory damages as authorized by section 337.505-550, asserting that they were not paid prevailing wages, benefits, or overtime in connection with their employment as truck drivers. The trial court granted Plaintiffs’ motion to certify this action as a class action under Ky. R. Civ. P. 23. The court of appeals vacated the class-action certification order, concluding that Plaintiffs had failed to establish commonality, one of the prerequisites to support a class action. In a separate concurring opinion, the judge argued that section 337.550(2) does not permit class action suits at all. The Supreme Court reversed, holding (1) class-action lawsuits are allowed under section 337.550(2); and (2) the trial court did not abuse its discretion when certifying the class in this case. View "Hensley v. Haynes Trucking, LLC" on Justia Law

The Supreme Court reversed the decision of the trial court declining to award post-judgment interest pursuant to Ky. Rev. Stat. 360.040 in this action concerning a divorce judgment.Karen and James Samuel Doyle (Sam) were divorced in 1995. In 1998, the circuit court issued a judgment pertaining to reserved issues of child custody, support, and division of property. The judgment was silent as to interest. When Sam did make an equalization payment to Karen as ordered by circuit court, Karen filed a judgment lien against property owned by Sam, plus interest at the legal rate from 1998. In 2012, Sam moved to prohibit the collection of interest. The court granted the motion on the grounds that the 1998 judgment was unliquidated and the judgment was silent as to interest. Karen appealed, and the court of appeals reversed. On remand, the circuit court again denied an award of interest. The court of appeals affirmed. The Supreme Court reversed, holding that the balance of equities favored the statutory award of interest under the circumstances of this case. View "Doyle v. Doyle" on Justia Law

Stigma damages are a measure of damages stemming from actual injury to property, but if remediation damages are settled and a claim on the stigma damages resulting from the actual damages is reserved, the injured party may be awarded stigma damages regardless of the partial settlement on remediation.Plaintiffs’ property was damaged from oil contamination. In a federal action, the parties entered into a partial settlement that allocated $60,000 to Plaintiffs for repair costs, intended to remedy actual damages to their property. Plaintiffs agreed to dismiss all claims against Defendants except for a reserved claims asserting the diminution of the value of their real estate due to the stigma resulting from the contamination. Plaintiffs then filed this state claim alleging negligence, trespass, and permanent nuisance. Defendants moved for summary judgment, arguing that the partial settlement barred the state action because Plaintiffs were fully compensated for the actual damages the contamination caused to their property. The circuit court dismissed the stigma damages claim, holding that Plaintiffs could not seek both the costs of remediation and the diminution in value due to stigma damages. The court of appeals affirmed. The Supreme Court reversed, holding that Plaintiffs’ claim for damages resulting from the stigma of the contamination may be recovered in addition to the settled repair costs. View "Muncie v. Wiesemann" on Justia Law

The Supreme Court held that Ky. Rev. Stat. 532.130(2), which contains what the Court determined was an “outdated test” for ascertaining intellectual disability, is unconstitutional under the Eighth Amendment to the United States Constitution.Nearly twenty years ago, Defendant was convicted for the kidnapping, rape, and murder of a teenage girl. Defendant was sentenced to death. Here, Defendant filed a postconviction motion under section 532.130(2) requesting that the trial court declare him to be intellectually disabled, which would preclude the imposition of the death penalty. The trial court denied the motion. The Supreme Court reversed, holding that any rule of law that states that a criminal defendant automatically cannot be ruled intellectually disabled and precluded from execution simply because he or she has an IQ of 71 or above is unconstitutional. The Court remanded the case to the trial court to conduct a hearing, make findings, and issue a ruling on the issue of Defendant’s potential intellectual disability following this Court’s and the United States Supreme Court’s guidelines on such a determination, especially as set forth in Moore v. Texas, 137 S.Ct. 1039 (2017). View "Woodall v. Commonwealth" on Justia Law