Justia Kentucky Supreme Court Opinion Summaries

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

Defendant entered a conditional guilty plea to violating Lexington-Fayette Urban County Government Ordinance 14-5, which prohibits all begging and soliciting from public streets or intersections within the urban-county area. On appeal, the circuit court affirmed the judgment of conviction and sentence, determining that Lexington’s Ordinance 14-5 is a content-neutral regulation of speech, thereby requiring a less exacting standard of scrutiny to remain constitutionally viable. The Supreme Court reversed, holding that Ordinance 14-5 is a content-based regulation of expression that unconstitutionally abridges freedom of speech under the First Amendment. Remanded to the district court for dismissal of the charge against Defendant. View "Champion v. Commonwealth" on Justia Law

After a jury trial, Appellant was convicted of first-degree sodomy, first-degree sexual abuse, and use of a minor in a sexual performance. Appellant was sentenced to a total of thirty years in prison. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court erred by failing to direct a verdict of acquittal for first-degree sodomy and first-degree sexual abuse; (2) two of Appellant’s remaining arguments concerning his first-degree sodomy and first-degree sexual abuse convictions were moot; (3) the trial court did not err by denying Appellant’s request for a sexual misconduct jury instruction; (4) the prosecutor made improper remarks during closing argument, but the misstatements were not so egregious that they constitute flagrant misconduct undermining the essential fairness of Appellant’s trial; and (5) there was no cumulative effect of multiple errors that would justify reversal. View "Murphy v. Commonwealth" on Justia Law

After EQT Gathering, LLC constructed a natural gas pipeline along the boundary of Appellants’ property, Appellants filed a civil action in the circuit court alleging that EQT had trespassed upon their land. After a jury trial, the circuit court ruled in favor of Appellants and awarded compensatory and punitive damages. The court of appeals vacated the judgment, concluding that the trial court erred by directing a verdict in Appellants’ favor on the issue of liability and submitting only the issue of damages for the jury’s determination. The court of appeals further concluded, sua sponte, that, upon remand for a new trial, adjoining landowners must be included as parties to the suit before the trespass claim could be resolved. The Supreme Court affirmed in part and reversed in part, holding (1) the trial court erred in directing a verdict on the issue of EQT’s liability for the trespass; but (2) the court of appeals erred in determining that the adjoining landowners were indispensable or necessary parties to the trespass claim and in mandating their involuntary participation in the action. Remanded. View "Fleming v. EQT Gathering, LLC" on Justia Law

Carol Harrell entered into a credit card agreement with Citibank but later defaulted on her promise to repay the debt. The right to collect Harrell’s outstanding debt was later assigned to Unifund CCR Partners. Unifund filed a collection action against Harrell seeking, in addition to the outstanding balance of Harrell’s account, statutory pre-judgment interest pursuant to Ky. Rev. Stat. 360.010(1). Harrell filed a counterclaim alleging that Unifund’s request for statutory prejudgment interest was in violation of the federal Fair Debt Collection Practices Act (FDCPA). The circuit court dismissed Harrell’s counterclaim for failure to state a claim. The court of appeals reversed, concluding that the circuit court erred in concluding that Unifund’s claim for statutory interest did not violate the FDCPA and in granting Unifund’s motion to dismiss. The Supreme Court affirmed, holding that Harrell plausibly alleged that Unifund violated the FDCPA. Remanded. View "Unifund CCR Partners v. Harrell" on Justia Law