Justia Kentucky Supreme Court Opinion Summaries

Defendant was charged with multiple drug-related criminal offenses. Defendant filed a motion to suppress all the evidence collected from his trailer, arguing that law enforcement officers unlawfully exceeded the scope of a warrantless knock and talk by entering the protected curtilage of his residence. The trial court denied the suppression motion. Defendant subsequently entered a conditional guilty plea to complicity to manufacture methamphetamine, complicity to possess marijuana, and complicity to possess drug paraphernalia. The court of appeals reversed, concluding that the officers did not have the right to venture away from the front of Defendant’s house pursuant to a knock and talk and to invade the curtilage of Defendant’s residence. The Supreme Court reversed, holding that, based on the totality of the factors set forth in United States v. Dunn, as well as the officers’ uncontroverted testimony, neither officer unlawfully encroached on the trailer’s curtilage. View "Commonwealth v. Dixon" on Justia Law

In 1992, Defendant was convicted of two counts of murder and sentenced to death. In 1996, Defendant was convicted of attempted murder and sentenced to twenty years’ imprisonment, with that sentence being served concurrently with 1992 sentence. The judgment in the 1996 case failed to award Defendant substantial jail-time credit to which he was entitled. Had Defendant been granted the credit, he would have served out the 1996 sentence in 2009. Nevertheless, the Department of Corrections treated that sentence as though it had been served out at that time. In 2012, Defendant filed in federal district court a petition for habeas corpus challenging his 1996 conviction. Unable to determine whether Defendant was “in custody” under the challenged conviction, the district court certified two questions to the Supreme Court to resolve the question. The Supreme Court answered (1) the Department of Corrections may award an inmate jail-time credit that was mistakenly left of the judgment of conviction and sentence; and (2) whether Corrections properly did so in this case, and thus did not have Defendant in custody on that charge at the time he filed his habeas petition, requires additional fact-finding. View "Bowling v. White" on Justia Law

Appellant suffered a work-related accident while employed by Appellee. Appellant filed for workers’ compensation, but before his claim could be resolved, he was fired for “performance-related issues.” An administrative law judge (ALJ) awarded workers’ compensation but declined to apply a multiplier to Appellant’s award, finding that there was no evidence that Appellant’s cessation of employment was the result of his injury. The Workers’ Compensation Board ultimately concluded that Appellant was not entitled to enhancement by the two multiplier at the time of the ALJ’s decision and that the evidence did not compel a finding that Appellant’s work-related injury led to his termination. The court of appeals affirmed. The Supreme Court reversed and remanded, as no finding had been made as to whether Appellant’s conduct at work satisfied the new standard set forth in Chrysalis House, Inc. v. Tackett regarding when the two multiplier may be awarded so as to justify the denial of the application of the two multiplier. View "Fuertes v. Ford Motor Co." on Justia Law

Amy and Melissa, a same-sex couple, had a child together through artificial insemination. After the couple separated, Melissa married Wesley. Wesley filed a petition for step-parent adoption of the child in the Kenton County Family Court. Amy, in turn, filed a petition for shared custody and visitation in Hamilton County, Ohio. Amy moved to intervene in the Kenton County case and moved to have the adoption action dismissed in light of her pending custody petition. The trial court granted the motion to intervene and dismissed the adoption action. The court of appeals reversed, concluding that Amy did not have standing to seek adoption. The Supreme Court reversed, holding that the trial court’s decision granting Amy’s motion to intervene in the step-parent adoption proceeding was not clearly erroneous. View "A.H. v. W.R.L." on Justia Law

Glenn Hampton suffered a work-related injury during his employment with Flav-O-Rich. An administrative law judge (ALJ) found Hampton to be permanently totally disabled and awarded him permanent total disability benefits. The Workers' Compensation Board vacated the ALJ’s opinion and remanded, finding that the ALJ’s summary of the evidence and findings of fact were not sufficient to permit meaningful appellate review. Hampton filed a petition for review with the court of appeals. The court dismissed the petition as prematurely filed from a non-final Board opinion, concluding that because the Board’s opinion did not divest Hampton of a vested right and did not direct or authorize the ALJ to enter a different award on remand, it was not final and appealable. The Supreme Court reversed, holding under the test from Davis v. Island Creek Coal Co., the Board’s opinion was final and appealable. View "Hampton v. Flav-O-Rich Dairies" on Justia Law

Linda Davis and Matthew Davis executed a property settlement agreement prior to their divorce providing that Matthew maintain his life insurance policy and keep Linda as the beneficiary. The decree of dissolution entered by the circuit court failed to incorporate the agreement. The omission went unnoticed until after Matthew died. Prior to his death, Matthew changed the beneficiary on his life insurance policy to Karen Davis, his then-wife. Linda, upon learning of Matthew’s death, filed a proof of claim against his estate, alleging breach of the agreement. Karen, as executrix of Matthew’s estate, denied the claim. Karen then filed this action seeking the policy proceeds. Linda intervened as a third party plaintiff. The circuit court ruled against Linda. The court of appeals affirmed, holding that Ky. Rev. Stat. 403.180(4) essentially voided the agreement. The Supreme Court reversed, holding that a settlement agreement involving property division that was not incorporated or referenced in the final decree of dissolution may be enforced through an independent contract action. View "Davis v. Davis" on Justia Law

Sarah Jackson and David Thomas retained Persels & Associates, LLC (Persels) to defend them in debt collection cases. Persels retained Kentucky attorneys K. David Bradley and Robert Gillispie to provide limited representation. The limited representation agreements provided that neither lawyer was required to sign pleadings, enter an appearance, or attend court proceedings. The circuit court subsequently ordered the attorneys to show cause why they should not be held in contempt for their failure to enter their appearances and sign documents filed with the court. Persels intervened as a third party. The trial court determined that Parsels and the two attorneys had violated Ky. R. Civ. P. 11 and fined each $1. The court of appeals affirmed. The Supreme Court reversed, holding that limited-representation counsel is not required to sign the documents prepared as part of the limited representation, and therefore Rule 11 does not apply. Remanded to the trial court to determine whether the limited-representation agreements at issue were reasonable. View "Persels & Assocs., LLC v. Capital One Bank" on Justia Law

Delena Tipton was injured during the course of her employment with Trane Commercial Systems. Trane initially paid Tipton temporary total disability (TTD) income benefits but stopped paying TTD benefits when Tipton returned to work. An administrative law judge (ALJ) found that Tipton’s release and return to work justified termination of TTD benefits when Tipton returned to work. The Workers’ Compensation Board affirmed. The court of appeals reversed, concluding that Tipton’s return to work did not terminate her entitlement to TTD benefits because Tipton did not returned to the type of work she had performed when she was injured. The Supreme Court reversed and reinstated the ALJ’s opinion and award, holding that there was ample substantial evidence to support the ALJ’s denial of Tipton’s request for additional TTD benefits. View "Trane Commercial Sys. v. Tipton" on Justia Law

Laul Deng (“Aker”) sued his former employer, Norton Healthcare, Inc., for racial discrimination in terminating his employment. Specifically, Aker alleged that Norton’s failure to reinstate him after termination of his employment was retaliation for filing a pro se discrimination complaint. The trial court granted Norton summary judgment on all of Aker’s claims. Despite acknowledging that Aker never applied for any position with Norton, the court of appeals reversed, concluding that the futile-gesture doctrine excused the requirement that Aker show that he applied for a position in order to establish a prima facie claim for employment discrimination. The Supreme Court reversed, holding (1) the court of appeals erred in invoking the futile-doctrine theory sua sponte; and (2) the trial court did not err in granting summary judgment to Norton as a matter of law. View "Norton Healthcare, Inc. v. Deng" on Justia Law

After a jury trial, Defendant was convicted of two counts of murder for intentionally killing his parents and one count of tampering with physical evidence. Defendant was sentenced to a total of forty-five years’ imprisonment. At issue on appeal was whether the trial court erred in failing to suppress Defendant’s confession made during protracted interrogation by sheriff’s detectives. The Supreme Court reversed Defendant’s convictions, holding (1) Defendant’s confession was involuntarily extracted through interrogation techniques employed by law enforcement that were constitutionally unjustifiable; and (2) the trial court improperly excluded Defendant’s alternate perpetrator evidence at trial. View "Gray v. Commonwealth" on Justia Law