Justia Kentucky Supreme Court Opinion Summaries

Appellant entered a conditional guilty plea to charges of first-degree trafficking in a controlled substance, first-degree possession of drug paraphernalia, and being a first-degree persistent felony offender. Appellant was sentenced to twenty years’ imprisonment. Appellant appealed the denial of his motion to suppress evidence that was found on his person and in his car following a sniff search by a narcotics-detection dog that was conducted after a routine traffic stop. The Supreme Court reversed, holding (1) the arresting officer prolonged the seizure and conducted the search in violation of Rodrigues and Appellant’s Fourth Amendment rights; and (2) therefore, the fruits of that search must be suppressed. View "Davis v. Commonwealth" on Justia Law

Appellant was indicted for being a convicted felon in possession of a handgun, carrying a concealed deadly weapon, and alcohol intoxication in a public place. Appellant filed a motion to suppress the weapon seized at his arrest, arguing that the arresting officer lacked sufficient cause to arrest Appellant for alcohol intoxication and that the ensuing search of his person incident to the improper arrest violated his Fourth Amendment rights. The trial court denied the motion. The court of appeals upheld the validity of the arrest. The Supreme Court reversed, holding (1) Appellant’s arrest for alcohol intoxication in a public place was unlawful because the offense was not committed in the presence of the arresting officer; and (2) therefore, the search conducted incident to that arrest was not valid, and the evidence obtained during the search should have been suppressed. View "Maloney v. Commonwealth" on Justia Law

Plaintiff was injured in an automobile accident. Plaintiff filed a negligence suit against the adverse driver. Plaintiff settled the claim for the adverse driver’s automobile-liability-insurance policy limits. Before dismissing the suit, however, Plaintiff asserted a claim against his own automobile liability insurer, State Farm, for underinsured motorist benefits (UIM). Plaintiff’s insurance policy contained a limitation provision that gave Plaintiff two years from the date of the accident or date of the last basic reparation benefit payment within which to make a UIM claim. Plaintiff filed his UIM three years after the date of the accident. The trial court granted summary judgment in favor of State Farm, concluding that the explicit terms of Plaintiff’s policy rendered his UIM claim untimely. The court of appeals reversed, holding that State Farm’s time limitation on UIM claims was unreasonable and therefore void. The Supreme Court reversed, holding that the State Farm policy provision was not unreasonable. View "State Farm Mut. Auto. Ins. Co. v. Riggs" on Justia Law

After she was denied tenure, Plaintiff, a former faculty member of Northern Kentucky University, filed suit, alleging violations of the Kentucky Civil Rights Act for discriminatory employment practices on the basis of her gender. The trial court granted summary judgment for the University, concluding that Plaintiff failed to raise a prima facie claim for gender discrimination because she could not prove she was qualified for tenure and she failed to present evidence that she was treated differently from similarly situated male comparators. The court of appeals reversed. The Supreme Court reversed the court of appeals and reinstated the trial court’s grant of summary judgment, holding that the court of appeals employed an erroneous standard for reviewing Plaintiff’s claim. View "Bd. of Regents of N. Ky. Univ. v. Weickgenannt" on Justia Law

Defendant entered a conditional guilty plea to three counts of incest, one count of first-degree sexual abuse, and to being a first-degree persistent felony offender. Defendant was sentenced to twenty years’ imprisonment. Defendant appealed, arguing that Ky. Rev. Stat. 530.020, the incest statute, does not criminalize sexual intercourse between a stepfather and his adult stepdaughter. The Supreme Court affirmed the trial court’s denial of Defendant’s motion to dismiss and judgment, holding that, in accordance with Raines v. Commonwealth, a plain reading of section 530.020 did not include the victim’s age as an element of the crime and that the legislative intent was to prohibit sexual intercourse between persons with certain relationships, including stepparents and stepchildren. View "Howard v. Commonwealth" on Justia Law

Appellant was charged with first-degree rape, first-degree sodomy, and first-degree incest of his granddaughter, referred to as Sarah. During her opening statement, Appellant’s attorney commented on Sarah’s alleged untruthfulness. The Commonwealth moved for a mistrial on the basis that defense counsel had characterized Sarah as a liar. The trial court granted the mistrial motion and scheduled the case for retrial. Appellant filed a motion to prohibit retrial and dismiss the indictment, which the trial court denied. Appellant then filed a writ of prohibition with the court of appeals requesting an order prohibiting the trial court from retrying him. The court of appeals denied the writ. The Supreme Court affirmed, holding that defense counsel’s statements constituted improper evidence that prejudiced the Commonwealth’s right to a fair trial, and therefore, a mistrial was an appropriate remedy. View "Sneed v. Hon. Rodney Burress" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree sodomy and two counts of first-degree sexual abuse. The trial court sentenced Defendant to twenty-five years’ imprisonment. The Supreme Court affirmed, holding that the trial court (1) did not err when it denied Defendant’s motion to dismiss the indictment; (2) did not err when it granted the Commonwealth’s intra-trial motion to amend the indictment; (3) did not err when it denied Defendant’s motion for a mistrial; (4) did not err when it denied Defendant’s motions for a directed verdict; and (5) did not commit palpable error when it admitted testimony about prior and uncharged crimes and other bad acts. View "Bartley v. Commonwealth" on Justia Law

After a jury trial, Appellant was found guilty of wanton murder. The trial court adopted the jury’s recommended penalty of twenty years’ imprisonment. The Supreme Court affirmed the conviction and sentence, holding (1) the trial court properly instructed the jury on self-protection; (2) the combination murder instruction permitting Appellant to be convicted of either intentional or wanton murder did not violate Appellant’s right to a unanimous verdict; and (3) the trial court did not err in denying Appellant’s motion for a directed verdict, as there was sufficient evidence to support a guilty verdict for intentional or wanton murder. View "Gribbins v. Commonwealth" on Justia Law

After a jury trial, Appellant was convicted of murder and four counts of first-degree criminal abuse. Appellant was sentenced to life imprisonment. The Supreme Court affirmed, holding (1) the trial court’s admission of evidence of Appellant’s prior bad acts - namely, his history of domestic violence against his spouse - was not in error; (2) the admission of hearsay statements made to an examining pediatrician was not in error, and the admission of a detective’s hearsay testimony in violation of Appellant’s confrontation rights was harmless beyond a reasonable doubt; and (3) improper closing statements made during the Commonwealth’s closing argument did not rise to the level of misconduct requiring reversal. View "Dickerson v. Commonwealth" on Justia Law

After a jury trial, Defendant was convicted of one count of intentional murder and one count of being a first-degree persistent felony offender. Defendant was sentenced to twenty years’ imprisonment. Defendant appealed, arguing (1) the trial court’s power to establish the number of peremptory challenges awarded to the Commonwealth is an impermissible delegation of legislative authority under Kentucky’s separation of governmental powers principle, and (2) he was entitled to a directed verdict on the intentional-homicide charge. The Supreme Court affirmed, holding (1) because Defendant did not notify the Attorney General of his intent to challenge the constitutionality of Ky. Rev. Stat. 29A.290(2)(b), Defendant failed to comply with Ky. Rev. Stat. 418.075, and therefore, the Court must decline to address the merits of his argument; and (2) Defendant was not entitled to a directed verdict. View "Craft v. Commonwealth" on Justia Law