Justia Kentucky Supreme Court Opinion Summaries

In this construction dispute, Plaintiff was not entitled to relief on its breach of contract claim or under a quantum meruit theory.Plaintiff and Defendant entered into a subcontract agreement that outlined services that Plaintiff was to perform as a subcontractor for the construction of the Bridge Street Bridge. Plaintiff later sued Defendant for breach of contract and quantum meruit in the alternative, asserting that the parties had entered into a separate agreement before the subcontract agreement and that, under that alleged agreement, Defendant was obligated to pay for additional work performed. The circuit court granted Defendant’s motion for judgment for the pleadings, concluding that the subcontract agreement was a complete integration of the dealings between the parties. The court of appeals determined that it was unclear whether the subcontract agreement was a full integration or a partial integration. Thus, the court declared that whether any additional work Plaintiff allegedly performed was covered by the subcontract agreement was an issue of fact for the jury. The Supreme Court reversed, holding (1) by its own terms, the subcontract agreement was a full integration of the parties’ contract for Plaintiff’s subcontracting work on the bridge; and (2) Plaintiff was not entitled to relief under a quantum meruit theory. View "Vanhook Enterprises, Inc. v. Kay & Kay Contracting, LLC" on Justia Law

Section 115 of the Kentucky Constitution bars the Commonwealth from appealing a judgment of acquittal in a criminal case.Here, the Commonwealth appealed Defendant’s judgment of acquittal on the charge of failing to register a change of address with the Sex Offender Registry. The Commonwealth argued that its appeal was not barred by section 115 because Defendant’s judgment of acquittal was based not on the jury’s verdict but on the trial court’s issuance of a judgment of acquittal. The court of appeals allowed the appeal to proceed and reversed the trial court’s judgment of acquittal. The Supreme Court reversed, holding that section 115 prevents the Commonwealth from appealing a judgment of acquittal. The Court overruled any precedent stating that section 115 derives itself from section 13 of the Kentucky Constitution and that the Commonwealth may appeal a judgment non-obstante verdicto (n.o.v.). View "Maupin v. Commonwealth" on Justia Law

In this case involving an alleged denial of Defendant’s Sixth Amendment right to conflict-free counsel, the Supreme Court held that the trial court correctly denied trial counsel’s motion to withdraw because, under the totality of the circumstances, Defendant failed to demonstrate that his lawyer was burdened by an actual conflict of interest during his representation of Defendant.Defendant was convicted of first-degree trafficking in a controlled substance and of being a first-degree persistent felony offender. Once Defendant’s attorney discovered that he had a potential conflict, he filed a motion to withdraw as Defendant’s attorney. The trial court denied the motion. The court of appeals ruled that the trial court erred by failing to grant counsel’s motion to withdraw and reversed Defendant’s conviction and sentence. The Supreme Court reversed the court of appeals and reinstated Defendant’s conviction and sentence, holding that Defendant was not denied his constitutional right to conflict-free counsel. View "Commonwealth v. Muchrison" on Justia Law

The court of appeals misapplied the ineffective-assistance-of-counsel standard by failing to consider the totality of the circumstances of Defendant’s case from the perspective of an objectively reasonable trial attorney.The court of appeals reversed the trial court’s denial of Defendant’s Ky. R. Crim. P. 11.42 post-conviction motion for a new sentencing-phase trial based upon ineffective assistance of trial counsel. The court of appeals ruled that trial counsel provided ineffective assistance by advising Defendant to enter into a sentencing agreement with the Commonwealth to waive jury sentencing and accept a plea agreement under which he was sentenced to the maximum penalty to avoid potential risks to his parole eligibility and meritorious credit against his sentence. The Supreme Court reversed, holding that the court of appeals placed too much emphasis on Defendant’s agreeing to the maximum penalty. As to Defendant’s argument that the trial court erred by denying his motion for relief for ineffective assistance of appellate counsel, the argument was without merit. View "Commonwealth v. Helm" on Justia Law

Ky. Const. section 170 does not exempt a qualifying charitable institution from the use tax imposed by Ky. Rev. Stat. 139.310.The Finance and Administration Cabinet’s Department of Revenue, the Board of Tax Appeals, and the circuit court concluded that the section 170 constitutional exemption speaks only to ad valorem property taxes and does not relieve a “public charity” from the use tax imposed by section 139.310. The court of appeals disagreed, ruling that the use tax imposed under section 139.310 is similar enough to an ad valorem tax to render its enforcement on governmental entities unconstitutional under section 170. The Supreme Court reversed, holding (1) section 170 of the Kentucky Constitution provides for exemptions from property taxes only; and (2) the holding in Commonwealth ex rel. Luckett v. City of Elizabethtown, 435 S.W.2d 78 (Ky. 1968), that the section 170 exemption applies to the use tax is not sustainable. View "Commonwealth, Finance & Administration Cabinet, Department of Revenue v. Interstate Gas Supply Inc." on Justia Law

The administrative law judge’s (ALJ) findings that Appellant was exposed to MOCA, a curing agent and a known carcinogen, at a TEMA Isenmann, Inc. production facility and that this exposure resulted in an occupational disease were supported by substantial evidence.Appellant worked for TEMA Isenmann, Inc. When he was diagnosed and treated for bladder cancer, he sought permanent total disability benefits based upon his assertion that his cancer amounted to an occupational disease. On remand for the second time from the Workers’ Compensation Board, the ALJ awarded Appellant the benefits sought. The Board affirmed the ALJ. The court of appeals reversed. The Supreme Court reversed the decision of the court of appeals, holding that the ALJ’s award was based upon substantial evidence. View "Miller v. TEMA Isenmann, Inc." on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals in this appeal brought by both parties from a judgment in a paternity action. The Court held (1) a paternity action can be brought by a private attorney, and therefore, the district court properly exercised jurisdiction over this case; (2) attorneys’ fees are not recoverable in paternity actions, and therefore, the court of appeals erred in ruling that Ky. Rev. Stat. 403.220 provided a statutory avenue for attorneys’ fees in this case; and (3) the court of appeals properly concluded that a trial court has the discretionary authority to allow credits of “excess” dependent benefits toward pre-petition liabilities, but rather than simply upholding the district court’s allowance of the credit, the case must be remanded for further factual findings and a renewed determination of whether that credit is appropriate. View "Seeger v. Lanham" on Justia Law

The Supreme Court reversed in part the final judgment of the trial court convicting Defendant of three misdemeanors and four felonies and sentencing Defendant to a sentence totaling twenty years’ imprisonment and imposing $50 in fines together with court costs and court facility fees. The Court held (1) the trial court erred by imposing a $50 fine but not by imposing court costs, court facilities fee, and bond; (2) the trial court erred when it denied Defendant’s motion for directed verdict on the charge of first-degree theft by unlawful taking, over $500 but less than $10,000; (3) the jury instructions relating to Defendant’s charge of resisting arrest were erroneous, and the only remedy is to reverse the judgment on this charge and remand for further proceedings; and (4) the remainder of the judgment was not in error. View "Hall v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding the trial court’s suppression of evidence discovered as a result of a canine sniff search of Defendant’s vehicle during a traffic stop. The Court held that the court of appeals did not err by concluding (1) the stop of Defendant’s vehicle was proper, but the sniff search improperly extended the traffic stop; (2) the traffic stop was the only legal justification for stopping Defendant; and (3) the Commonwealth failed to preserve for appellate review its claim that Defendant’s parole status subjected him to a warrantless and suspicionless search and seizure. View "Commonwealth v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of criminal attempt to commit murder, possession of a handgun by a convicted felon, and tampering with physical evidence and sentencing him to twenty years’ imprisonment. The Court held (1) the trial court did not err in denying Defendant’s motion to suppress his statement to police; (2) the trial court did not err in refusing to allow certain cross-examination of the victim; (3) the trial court did not err in denying Appellant’s motion for a mistrial; and (4) the jury instructions on the possession of a handgun by a convicted felon charge did not deprive Appellant of his right to a unanimous verdict. View "Shively v. Commonwealth" on Justia Law