Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals declining to issue a writ sought by Miki Thompson prohibiting the trial court from enforcing discovery orders entered for inspection and discovery in a wrongful death and negligence action pending in the circuit court. The court of appeals found that Thompson failed to show irreparable injury without the writ or the existence of facts sufficient to justify issuance of the writ under the special-case exception. In affirming, the Supreme Court held that the court of appeals did not err in concluding that complying with the trial court’s orders will not lead to an irreparable injury for Thompson or that the writ must issue under the special-case exception. View "Thompson v. Honorable Eddy Coleman" on Justia Law

The Supreme Court affirmed the opinion of the court of appeals affirming the decision of the Workers’ Compensation Board upholding the decision of the administrative law judge (ALJ), which awarded Michael R. Plumley permanent partial disability benefits.On appeal, the Court held that the ALJ did not err (1) by relying upon the medical report of Dr. Greg Snider, who evaluated Plumley under the range-of-motion method and used terminology different from that which Plumley would use to describe essentially the same condition; (2) by finding that Plumley had three distinct work-related injuries, for each of which the ALJ made three tandem benefit awards rather than a single-injury with a single-benefit award; and (3) in his use of modifier multipliers. View "Plumley v. Kroger, Inc." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the decision of the Workers’ Compensation Board (Board) affirming the decision of the administrative law judge (ALJ) awarding Donald Jobe benefits regarding his back.Jobe, an employee of Ford Motor Company, suffered a right hip injury stemming from a work-related accident. Jobe applied for workers’ compensation benefits, asserting that he sustained a low back impairment due to the hip injury. The ALJ found that Jobe’s work-related hip injury was a proximate cause of his low back impairment and awarded Jobe benefits for a fourteen percent permanent partial disability, temporary total disability benefits for the periods he was off work due to his back impairment, and medical benefits. The Board affirmed, concluding that the ALJ had substantial evidence to support his finding that Jobe’s low back impairment had a causal connection to the work-related injury. The court of appeals affirmed. The Supreme Court affirmed, holding that the ALJ based his decision that Jobe’s back impairment was work-related on substantial evidence. View "Ford Motor Co. v. Jobe" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Appellant to thirty years’ imprisonment for murder and for being a first-degree persistent felony offender. The Court held that the trial court (1) did not err by permitting the Commonwealth to elicit testimony from the coroner about the victim’s estimated time of death; (2) did not err by denying Appellant’s motion to continue the trial; (3) did not err by disqualifying one of Appellant’s attorneys; (4) erred by admitting evidence about the victim’s state of mind prior to his murder, but the error was harmless; and (5) did not err by instructing the jury as to self-defense and extreme emotional disturbance. View "Turner v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Defendant of raping and murdering Pamela Armstrong and sentencing Defendant to death. The Court held (1) the trial court did not commit reversible error when it allowed the Commonwealth to admit other bad acts evidence of Appellant as addressed by Ky. R. Evid. 404(b); (2) the trial court’s failure to define the terms “modus operandi” and “identity evidence” in the jury instructions did not violate Appellant’s due process rights; (3) there was no reversible error in the trial court’s refusal to suppress Defendant’s DNA sample; (4) there was no error in the trial judge’s refusal to disqualify himself from presiding over Appellant’s trial; (5) Appellant was not entitled to a new trial on the grounds that the trial court improperly admitted unreliable evidence; (6) any alleged prosecutorial misconduct did not require reversal; and (7) Appellant was not entitled to relief on his remaining claims of error. View "White v. Commonwealth" on Justia Law

The scope of appellate review of an interlocutory appeal of the trial court’s determination of qualified official immunity is limited to the specific issue of whether immunity was properly denied.In this interlocutory appeal, the court of appeals not only agreed with the trial court that Defendants were not entitled to qualified immunity but also conclusively determined that Defendants were not negligent as a matter of law. The Supreme Court reversed and remanded the case to the trial court, holding that the court of appeals exceeded its scope of appellate review when it addressed the substantive claim of negligence on an interlocutory appeal of a decision about qualified official immunity. View "Baker v. Fields" on Justia Law

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