Justia Kentucky Supreme Court Opinion Summaries

The Supreme Court held that the denial of Defendant’s motion to suppress evidence seized from her vehicle during a traffic stop was proper.In her suppression motion, Defendant argued that the traffic stop of her vehicle was not justified because she was not required to have her license plate illuminated when Sergeant James Jenkins pulled her over. The Commonwealth acknowledged that a license plate violation may not have been a proper basis for the stop but that Detective Wade Shoemaker had reasonable suspicion of Defendant’s participation in controlled drug buys, and Det. Shoemaker’s reasonable suspicion to stop Defendant’s vehicle transferred to Sgt. Jenkins so as to justify the traffic stop. The trial court concluded that no traffic violation occurred but that law enforcement had reasonable suspicion to pull over Defendant’s vehicle. The Court of Appeals reversed, concluding that because Sgt. Jenkins did not actually rely on Det. Shoemaker’s information and instead made the stop based solely on the license plate violation, the collective knowledge doctrine was irrelevant. The Supreme Court reversed, holding that the record reflected that the real reason Sgt. Jenkins pulled over Defendant’s vehicle was upon Det. Shoemaker’s request, and because Det. Shoemaker had reasonable suspicion to make the investigatory stop, suppression of the evidence was not required. View "Commonwealth v. Blake" on Justia Law

In this appeal from a criminal conviction, the Supreme Court vacated the portion of the circuit court’s judgment imposing criminal restitution and otherwise affirmed the judgment of conviction and sentence. Defendant was convicted of second-degree manslaughter and of being a first-degree persistent felony offender (PFO). The Supreme Court affirmed in part and vacated in part the judgment, holding (1) the trial court erred when it ordered Defendant to pay criminal restitution because the court did not comply with the procedural due process requirements for imposing restitution as outlined in Jones v. Commonwealth, 382 S.W.3d 22 (Ky. 2011), and therefore, the criminal restitution award must be vacated and remanded for a new hearing; (2) the trial court did not err in allowing evidence that Defendant cut off his ankle monitor while on probation because evidence of probation violations, like evidence of parole violations, can be admissible evidence in the penalty phase of a criminal trial; and (3) the trial court did not err when it allowed the use of Defendant’s prior conviction for drug possession as a qualifier for PFO enhancement. View "Brown v. Commonwealth" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court convicting Defendant of incest, first-degree unlawful transaction with a minor, use of a minor in a sexual performance, first-degree unlawful imprisonment, and first-degree sexual abuse. The trial court sentenced Defendant to seventy years’ imprisonment. In reversing in part, the Supreme Court held that Defendant’s convictions of incest, use of a minor in a sexual performance, and unlawful imprisonment were reasonably likely a result of prosecutorial vindictiveness. The court otherwise affirmed, holding that the trial court (1) did not err in overruling Defendant’s motion to dismiss his indictment due to prosecutorial vindictiveness; (2) did not err by not granting a directed verdict on the charge of unlawful transaction with a minor; (3) did not permit double jeopardy violations; and (4) erred by permitting the victim’s mother to improperly vouch for the victim’s credibility, but the error was harmless. View "Yates v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court convicting Appellant of murder, criminal attempt to commit murder, and related crimes. The Supreme Court held that the trial court (1) did not err by denying Appellant’s request to introduce parole eligibility information during the death penalty phase of the trial; (2) did not err by permitting the Commonwealth to introduce during the guilt phase evidence of other crimes committed by Appellant against the victim’s family; and (3) did not err by allowing the testimony of a witness who was three years old at the time of the crimes and six years old at the time of the trial. View "Huddleston v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the Court of Appeals reversing the decision of the Workers’ Compensation Board (Board), which reversed the ALJ’s rejection of Plaintiff’s claim for enhanced benefits and reinstated the judgment of the ALJ.Plaintiff, an employee of VanMeter Contracting, Inc., was critically injured in a workplace accident. After an investigation, the Kentucky Occupational Safety and Health Administration (KOSHA) issued a citation against VanMeter, charging it with violating 29 CFR 1926.703(a)(1). Plaintiff filed a claim for workers’ compensation benefits and asserted a claim for a thirty percent benefit enhancement provided by Ky. Rev. Stat. 342.165(1) for the workplace injury. Plaintiff alleged the same regulatory violations asserted by KOSHA and a violation of the general workplace safety duty of Ky. Rev. Stat. 338.031(1)(a). The ALJ declined to grant the thirty percent enhancement, finding that Plaintiff had not presented sufficient evidence to prove the intentional violation of any safety statute or regulation. The Board reversed. The Court of Appeals reversed the Board. The Supreme Court affirmed, holding that the Board misconstrued or overlooked controlling law when, in contradiction of the ALJ’s findings, it accorded conclusive weight to the KOSHA settlement agreement. View "Groce v. Vanmeter Contracting, Inc." on Justia Law

In this case arising from the 1996 murder of LeBron Gaither, the Supreme Court affirmed the judgment of the Court of Appeals that, in the circumstances of this case, the Estate of LeBron Gaither was entitled to post-judgment interest on damages awarded by the Board of Claims from the date of the initial circuit court judgment. This was the third appeal in this matter. In this appeal, the Kentucky State Police, a department within the Commonwealth’s Justice and Public Safety Cabinet, argued that the Court of Appeals misconstrued Civil Rule 54.01 and Ky. Rev. Stat. 360.040, 44.130 and 44.140, which govern post-judgment interest on Board of Claims’ awards. The Supreme Court disagreed, holding (1) the Court of Appeals correctly read the Board of Claims Act as according circuit court judgments entered pursuant to the Act the same treatment under the post-judgment interest statute as ordinary civil judgments; and (2) the Court of Appeals properly held that post-judgment interest began to accrue from the circuit court’s initial judgment. View "Commonwealth, Justice & Public Safety Cabinet v. Gaither" on Justia Law

The Supreme Court affirmed the district court’s denial of Defendant’s motion to suppress the evidence obtained during a traffic stop, holding that the law enforcement officer did not violate Defendant’s right to privacy when he reviewed Defendant’s license and registration information.The officer’s police car in this case was equipped with a camera that could read license plates in order to provide information about the vehicle’s registered owner. The record check performed by the camera indicated that Defendant had an active warrant for failing to appear in court. The officer pulled Defendant’s vehicle over and, after noticing several signs that Defendant was intoxicated, arrested Defendant for, inter alia, driving under the influence. The district court denied Defendant’s motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant’s rights under the Fourth Amendment were not violated by the officer obtaining information linked to Defendant’s license plate, which was displayed in a place where Defendant had no reasonable expectation of privacy; and (2) the officer had the articulable and reasonable suspicion required to stop the vehicle. View "Traft v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to life imprisonment for murder, first-degree assault, and other crimes and sentencing Defendant to life imprisonment for murder. The court held (1) the trial court did not abuse its discretion in denying Defendant’s motion for change of venue; (2) the trial court did not abuse its discretion in denying Defendant’s motion to exclude an incriminating statement Defendant made to a witness; (3) the trial court did not abuse its discretion in denying Defendant’s motions for a continuance; (4) the trial court did not abuse its discretion by refusing Defendant’s motion to excuse jurors for cause; (5) the trial court did not abuse its discretion in denying Defendant’s request for a mistrial; and (6) the trial court erred in permitting testimony about what would constitute an appropriate sentence for Defendant, but the error was harmless. View "Hilton v. Commonwealth" on Justia Law

A plaintiff may bring a private right of action under Ky. Rev. Stat. 446.070 against an employer for an alleged violation of Ky. Rev. Stat. 341.990(6)(a), Kentucky’s criminal prohibition against making false statements during unemployment proceedings.Plaintiff brought suit against Employer, alleging that he suffered damages due to being temporarily deprived of his unemployment benefits. Employer’s successor-in-interest, the real party-in-interest, removed the case to federal court and moved to dismiss Plaintiff’s section 446.070 claim for failure to state a cognizable legal claim. The federal court denied the motion to dismiss and requested certification of law from the Supreme Court. The Supreme Court answered the question as set forth above and held that Plaintiff’s section 446.070 claim for an alleged violation of section 341.990(6)(a) was cognizable under Kentucky law. View "Hickey v. General Electric Co." on Justia Law

In Kentucky, an attorney’s contingent-fee contracts should be considered marital property to be divided as part of the equitable division of the marital estate, and trial courts must apply the delayed-distribution method to determine the actual distribution of funds.Husband had an active law practice in which he had executed contingent-fee contracts with some clients. When Husband and Wife divorced, the trial court treated the contingent-fee contracts as a component of Husband’s income when received and not as property of the marital estate subject to division. The court of appeals affirmed. The Supreme Court reversed and remanded the case to the trial court for further proceedings, holding (1) a contingent-fee contract in existence during the marriage does constitute marital property to be divided in a dissolution proceeding; and (2) trial court shall apply the delayed-division method to determine the distribution to the attorney and non-attorney ex-spouses. View "Grasch v. Grasch" on Justia Law