Justia Kentucky Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of second-degree assault, fourth-degree assault, first-degree wanton endangerment, and third-degree arson. Appellant appealed, arguing, primarily, that the trial court erred in refusing to instruct the jury on voluntarily intoxication under Ky. Rev. Stat. 501.080(1). The Supreme Court reversed the second-degree assault conviction and otherwise affirmed, holding (1) the evidence was sufficient to entitle Defendant to a voluntary intoxication instruction, and the failure to include the instruction was reversible error as to the second-degree assault conviction; and (2) the remaining convictions’ required mental states cannot be negated by voluntary intoxication, and therefore, those convictions and sentences were not in error. View "King v. Commonwealth" on Justia Law

This personal injury suit arose from a 2007 trip-and-fall at the Speedway SuperAmerica filling-station in Manchester. After a bench trial, the circuit court found for Teresa and Randy Grubb (together, Plaintiffs) and against Speedway SuperAmerica LLC, the store’s owner, and Roxanne Smith, the store’s manager at the time of the accident (collectively, Defendants). The court of appeals reversed and remanded for entry of a defense judgment, concluding that the trial court erred by failing to apply the “open and obvious” doctrine under the circumstances of this case. On discretionary review, the Supreme Court remanded to the court of appeals for reconsideration in light of the Court’s recent attempts to modernize the open and obvious doctrine and to harmonize it with tort law’s shift to a regime of comparative negligence. On remand, the court of appeals stood by its prior ruling. The Supreme Court reversed, holding (1) the court of appeals read recent precedent too narrowly; (2) the trial court erred by failing to consider whether Teresa shared responsibility for the accident and by failing to find that she did; and (3) the trial court erred in finding Smith jointly and severally liable with Speedway on Plaintiffs’ claims. View "Grubb v. Smith" on Justia Law

Appellant was convicted of incest, first-degree rape, first-degree sodomy, and other crimes. Appellant was sentenced to a total of sixty-five years in prison, the maximum sentence allowable in this case. On appeal, Appellant argued, inter alia, that he was entitled to relief because during voir dire the juror who ultimately became foreperson lied on her juror qualification form and also during voir dire proceedings concerning whether a member of her family had ever been prosecuted in a criminal matter. The Supreme Court reversed and remanded for a new trial, holding (1) the jury foreperson wrongfully failed to disclose the criminal prosecutions of her family, and the concealment of that information denied Appellant the opportunity to challenge the juror for cause or alternatively, use a peremptory strike to remove the juror; and (2) Appellant was deprived of a substantial right not subject to harmless error analysis. View "Gullett v. Commonwealth" on Justia Law

Appellants were charged with one count each of cultivation of marijuana five or more plants and other drug-related offenses. Appellants filed separate motions to suppress, arguing (1) police officers violated the curtilage of their apartment when they entered the back patio enclosure, thereby having no legal authority to view marijuana baggies, and (2) the officers lacked any exigencies to enter the apartment and conduct the search. The trial court denied Appellants’ motions to suppress. The court of appeals affirmed. The Supreme Court reversed, holding (1) officers breached the curtilage of Appellants’ apartment when viewing the marijuana baggies, in addition to conducting an illegal search of Appellants’ apartment; and (2) the evidence seized should be excluded as fruit of the poisonous tree. View "Pace v. Commonwealth" on Justia Law

Defendant entered a conditional guilty plea to one count of first-degree rape, one count of second-degree rape, and one count of second-degree sodomy. Defendant appealed, arguing that the trial court erred in denying his motion to suppress the evidence of his confession, arguing that the police obtained his confession in violation of Miranda v. Arizona because he did not knowingly and voluntarily waive his rights guaranteed under the Fifth Amendment. The Supreme Court affirmed, holding that Miranda did not apply because Defendant was not in custody at the time he made incriminating statements to the police. View "Wells v. Commonwealth" on Justia Law

Defendant was convicted of second-degree assault. A public defender from the local Department of Public advocacy (DPA) office was appointed to represent Defendant. Prior to trial, counsel advised the trial court that another attorney in the local DPA was representing the alleged victim in an unrelated matter. Defendant requested the appointment of new counsel. The trial court denied the request, concluding that there was not conflict of interest, and ordered the trial to proceed. Defendant appealed, arguing that the trial court’s refusal to appoint new counsel violated his right to conflict-free counsel under the Sixth Amendment. The court of appeals ultimately concluded that Defendant had not shown that his lawyer had an unconstitutional conflict of interest during her representation of him. The Supreme Court affirmed, holding (1) a public defender’s conflict of interest is not necessarily imputed to all other public defenders in the same Public Defender office; and (2) Defendant was not denied his Sixth Amendment right to conflict-free counsel in this case. View "Samuels v. Commonwealth" on Justia Law

Ray Ballou worked as an underground coal miner from 1982 until 2012 and was sixty-nine years old when last exposed to coal dust. An administrative law judge (ALJ) awarded Ballou retraining incentive benefits (RIB), finding that Ballou had category 1/1 coal workers’ pneumoconiosis. Due to Ballou’s advanced age, however, the ALJ determined that Ballou could only receive those benefits if he participated in an approved retraining or educational program. Ballou challenged the constitutionality of the RIB statute’s age classifications. The court of appeals concluded that those age classifications are constitutional. The Supreme Court affirmed, holding that the age classifications at issue did not violate Balou’s right to equal protection. View "Ballou v. Enterprise Mining Co., LLC" on Justia Law

Margie Mullins sustained a workplace injury during the course of her employment with Leggett and Platt. Mullins settled her workers’ compensation claim after negotiating with Leggett & Platt’s insurance carrier, CCMSI. The Chief Administrative Law Judge (CALJ) approved the award, which included weekly permanent-partial disability benefits, and Mullins’s election to accelerate the payment of her attorney’s fee to a lump-sum amount. This payment reduced Mullins’s weekly benefit amount pro-rata. But, in calculating Mullins’s weekly benefits remaining after deduction of the attorney’s fee, CCMSI applied a multiplier reflecting the future periodic payment of the attorney’s fee commuted to a present value. Mullins filed a motion for determination, disputing CCMSI’s calculation. The CALJ denied the motion, concluding that the statutory text and accompanying administrative regulations supported CCMSI’s calculation. The Workers’ Compensation Board and the Court of Appeals upheld the CALJ’s ruling. The Supreme Court affirmed, holding that Mullins failed to establish that CCMSI acted contrary to law or failed to correctly reduce her weekly benefits. View "Mullins v. Leggett & Platt" on Justia Law

In 1993, Appellant was convicted in a state court of multiple crimes and sentenced to a total of forty-two years’ imprisonment. In 1994, a federal district court sentenced Appellant to 152 months’ incarceration for separate crimes. At the time of Appellant’s federal sentencing, he was in the custody of the Kentucky Department of Corrections (DOC). The Federal Bureau of Prisons issued a detainer in order to obtain custody upon Appellant’s release from state custody. In 2001, the Kentucky Parole Board (KPB) paroled Appellant to his federal detainer, after which Appellant was transferred from state custody to federal custody. In 2012, Appellant was released from federal supervision. In 2013, after obtaining new criminal charges, the KPB revoked Appellant’s parole. In 2015, Appellant, then a prisoner at the Northpoint Training Center, filed a petition for writ of habeas corpus, arguing that the DOC permanently surrendered jurisdiction over his sentence when it transferred custody to federal authorities. The circuit court denied Appellant’s petition. The court of appeals affirmed. The Supreme Court affirmed, holding that, in accordance with Commonwealth v. Hale, the DOC did not forfeit its right to require Appellant to satisfy the remainder of his sentence upon his return to the Commonwealth. View "Murrell v. Bottom" on Justia Law

In 2011, Husband filed a petition for dissolution of his marriage to Wife. The family court entered a decree of dissolution in 2013 that divided the parties’ marital assets, awarded the parties joint custody of their two children, and ordered Husband to pay maintenance to Wife in the amount of $7,300 per month for a period of nine years. The court of appeals reversed in part, finding that the family court erred by including a portion of the children’s living expenses in its calculation of Wife’s maintenance award and by failing to make findings that justified its award of maintenance for a period of nine years. The Supreme Court affirmed in part and reversed in part, holding (1) the family court’s decision to include the children’s living expenses in its calculation of Wife’s reasonable living expenses was neither clearly erroneous nor an abuse of discretion; (2) the family court acted within its discretion in awarding Wife maintenance for nine years; (3) the court of appeals did not err in affirming the family court’s calculation of Husband’s income; and (4) the court of appeals properly found the family court did not abuse its discretion in denying Wife’s request that Husband pay the entirety of her attorney’s fees. View "Weber v. Lambe" on Justia Law