Justia Kentucky Supreme Court Opinion Summaries

Keith Justin Conley (Conley) was convicted of murder his girlfriend, Jessica Newsome, whom he fatally shot in the home of his father. At the time of the shooting, Conley’s father’s home was insured through a homeowner’s insurance policy issued by Kentucky Farm Bureau (Kentucky Farm). Jessica’s parents brought a wrongful death cause of action against Conley. Kentucky Farm intervened in the action seeking a declaration that the homeowner’s policy at issue did not provide coverage to Conley for the Newsomes’ claims. The trial court ruled that the homeowner’s insurance policy provided coverage for Conley’s acts. Kentucky Farm then filed a motion under Ky. R. Civ. P. 59.05 asking the court to alter or amend its order. The trial court denied the motion. Kentucky Farm subsequently filed its notice of appeal. The Court of Appeals dismissed the appeal as untimely, concluding that the Rule 59.05 motion failed to conform with Ky. R. Civ. P. 7.02, and therefore, the Rule 59.05 motion did not toll the thirty-day period in which notice was to be filed. The Supreme Court reversed, holding that the Rule 59.05 motion, while failing to strictly comply with the requirements of Rule 7.02, was nevertheless timely, and therefore, the motion tolled the time for filing the notice of appeal. View "Ky. Farm Bureau Mut. Ins. Co. v. Conley" on Justia Law

Employer discharged Plaintiff after coworkers reported that Plaintiff made racist comments in the workplace. Plaintiff sued Employer and the coworkers for defamation. The trial court directed a verdict for Employer and one of the coworkers, citing a qualified privilege to defamation. The jury returned a verdict in the remaining coworkers’ favor, finding that either the statements made about Plaintiff were true or that they were not made with malice. The Court of Appeals affirmed the jury’s verdict but reversed the directed verdict, concluding that Employer was entitled to the protection of a qualified privilege but that a plaintiff is only required to present a prima facie defamation case to overcome the qualified privilege and survive a motion for directed verdict. The Supreme Court reversed in part and affirmed in part, holding (1) a plaintiff in a defamation action opposing a directed-verdict motion made by a defendant claiming a qualified privilege must produce some evidence of the defendant’s actual malice to survive a directed verdict; (2) the directed verdict in favor of Employer was appropriate, as Plaintiff failed to prove any degree of malice; and (3) the jury’s verdict was sound. View "Toler v. Sud-Chemie, Inc." on Justia Law

Kentucky Spirit Health Care Plan, Inc. brought a declaratory judgment action seeking a ruling that it had a right to terminate its Medicaid managed care contract with the Finance and Administration Cabinet prior to the expiration of the contract without penalty. The trial court entered partial summary judgment in favor of the Cabinet. Both parties appealed. While the appeals were pending, the circuit court stayed Kentucky Spirit’s pre-trial discovery efforts relating to its rights under the Medicaid contract until resolution of the partial summary judgment appeals. The Court of Appeals granted Kentucky Spirit’s petition for a writ of prohibition against the circuit court judge prohibiting the judge from enforcing the order imposing the stay of discovery. The Supreme Court vacated the writ and remanded for entry of an order denying Kentucky Spirit’s petition for a writ of prohibition, holding that the circuit court did not abuse its discretion by temporarily staying discovery, as a stay of discovery was appropriate pending resolution of the threshold issues currently on appeal. View "Commonwealth v. Hon. Wingate" on Justia Law

After a jury trial, Appellant was convicted of first-degree sexual abuse and first-degree sodomy. The Supreme Court vacated the judgment of the circuit court and remanded for a new trial, holding (1) flawed jury instructions denied Appellant his constitutional right to a unanimous verdict, and the error required reversal of Appellant’s conviction; (2) a certain out-of-court statement was not subject to the hearsay rule and, therefore, was not admitted improperly; and (3) the Commonwealth did not improperly elicit testimony from a police officer that bolstered the credibility of the victim. Remanded for a new trial. View "Ruiz v. Commonwealth" on Justia Law

After a jury trial, Defendant was found guilty of first-degree trafficking in a controlled substance and possession of drug paraphernalia. The trial court sentenced Appellant to twenty years’ imprisonment for the trafficking charge and assessed a $500 fine for the drug paraphernalia charge. The Supreme Court reversed, holding (1) the Commonwealth impermissibly introduced an incriminating oral statement that had not been disclosed to Appellant in violation of Ky. R. Crim. P. 7.24(1), and the error required reversal; and (2) the trial court erred when it allowed testimony commenting on Appellant’s pre-arrest silence. Remanded. View "Trigg v. Commonwealth" on Justia Law

Coppage Construction Company, Inc. filed a third-party complaint raising a number of contract, tort, and statutory claims against Sanitation District No. 1 (SD1), a public sewer utility serving three Northern Kentucky counties. SD1 moved to dismiss the third-party complaint on the grounds that it was entitled to sovereign immunity. The circuit court converted the motion to dismiss into a motion for summary judgment and granted the motion, concluding that SD1 was entitled to sovereign immunity because SD1’s “parent” entities - the three counties - were immune entities, and SD1 performed a function integral to state government. The Court of Appeals affirmed, describing SD1 as an “arm” of the three counties. The Supreme Court reversed the Court of Appeals and vacated the summary judgment order of the circuit court, holding that SD1 was not entitled to sovereign immunity because it was not created by the state or a county and does not carry out a function integral to state government. View "Coppage Constr. Co., Inc. v. Sanitation Dist. No. 1" on Justia Law

Appellant, who was fifteen years old at the time, was charged with third-degree sexual abuse. Appellant was released from detention on a conditional order of release. The district court ordered that Appellant’s case be “informally adjusted” on the condition that Appellant move out of state to Oklahoma to live with his father. The existing order of release with its conditions was then terminated. Appellant and his mother were forced to comply with the order to avoid formal juvenile prosecution. When Appellant returned to Kentucky with his mother, the district court re-docketed the charges. The trial court eventually removed Appellant from his home and committed him to the Department of Juvenile Justice as a juvenile sexual offender for placement in an “appropriate facility.” The Supreme Court vacated the district court’s adjudication and disposition in this case, holding that the trial court erred when it changed the case from an informal adjustment to formal proceedings because once a case has been determined to be appropriate for an informal adjustment, the case cannot be returned to formal proceedings. View "Q.M. v. Commonwealth" on Justia Law

Appellant, a member of a fraternity at the University of Kentucky, leased a room at the fraternity house. When a police detective learned that Appellant was selling marijuana at the fraternity house, he and two other detectives entered the fraternity house without a warrant. Upon knocking on the door to Appellant’s room, the officers were greeted by the strong smell of marijuana. Appellant was charged with one count of trafficking in a controlled substance within 1,000 yards of a school and other drug-related charges. Appellant moved to suppress the evidence discovered in his bedroom, arguing that the detectives unlawfully entered and searched the house in violation of the Fourth Amendment. The trial court denied the motion to suppress. Appellant subsequently pled guilty to the trafficking charge. The Court of Appeals affirmed the trial court’s denial of Appellant’s motion to suppress. The Supreme Court reversed the Court of Appeals and vacated Appellant’s guilty plea, holding that the detective were not welcome to enter the fraternity house at their own discretion, and therefore, the officers’ entry was unlawful. View "Milam v. Commonwealth" on Justia Law

Randy Ellington owned and operated R&J Cabinets as a sole proprietorship. When Ellington received a work-related injury, R&J had no employees. Kentucky Employers’ Mutual Insurance (KEMI) had previously issued a workers’ compensation policy to Ellington and R&J as “insureds.” At the same time, the policy included a specific exclusion from coverage of Ellington as the sole proprietor. KEMI denied Ellington’s claim for benefits, arguing that it was not covered because of the sole-proprietor exclusion endorsement. An administrative law judge concluded that Ellington was not covered by the policy. The Court of Appeals reversed, finding the policy was ambiguous and construing it in Ellington’s favor to provide coverage for his injuries. The Supreme Court reversed, holding that the policy, as issued, is not a personal policy but rather a business policy purchased by a sole proprietor, and Ellington, as the sole proprietor, was not entitled to benefits under the policy. View "Ky. Employers Mut. Ins. v. Ellington" on Justia Law

Defendant was charged with driving under the influence (DUI) of alcohol, third offense. Defendant moved to dismiss the DUI charge, claiming that the arresting officer violated Kentucky’s implied consent law by denying him a breathalyzer test and instead ordering a blood test. The district court denied the motion to dismiss, concluding that the officer had the option as to which test may be given in a DUI case. The circuit court affirmed and Court of Appeals affirmed. Defendant petitioned for reconsideration in light of the U.S. Supreme Court’s recent decision in Missouri v. McNeely. The Court of Appeals granted the petition, withdrew its earlier opinion, and reversed the circuit court’s holding. The Supreme Court reversed, holding that when a law enforcement officer has reasonable grounds to believe that a driver is operating a motor vehicle under the influence of alcohol, that officer may request that the driver submit to a blood test in order to determine the driver’s blood alcohol concentration level, and the officer is not required to administer a breathalyzer test prior to the administration of the blood test. View "Commonwealth v. Duncan" on Justia Law