Justia Kentucky Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of third-degree terroristic threatening, other firearm-related offenses, and of being a first-degree persistent felony offender. Appellant appealed, arguing, among other things, that a Batson violation occurred as a result of one of the peremptory strikes made by the Commonwealth. The Supreme Court vacated Appellant’s conviction and remanded for a new trial, holding (1) a Batson violation occurred when the prosecutor struck an African-American juror from the jury pool and failed to provide a cognizable race-neutral reason for striking the juror; and (2) therefore, the trial court’s overruling of Appellant’s Batson challenge was an abuse of discretion. View "Johnson v. Commonwealth" on Justia Law

In 2011, Appellant was convicted of first-degree wanton endangerment, first-degree fleeing or evading police, and second-degree burglary. Appellant was sentenced to concurrent sentences. The Supreme Court (1) reversed Appellant’s conviction for second-degree burglary, concluding that he was entitled to a directed verdict of acquittal on that charge; and (2) affirmed the remaining convictions and sentences. On remand, Appellant moved for a new penalty phase on the affirmed convictions, arguing that the sentencing evidence related to the now-reversed reversed burglary conviction necessarily tainted the jury’s consideration of sentencing for the other offenses. The trial court denied the motion and sentenced Appellant in conformity with the original sentence on the remaining convictions. Appellant appealed, arguing that he was entitled to a new penalty phase. The Supreme Court dismissed the appeal, holding that Appellant was barred from seeking amendment of his sentence because the trial court was bound by the Court’s mandate specifically affirming the sentences and because Appellant was not entitled to raise the issue of possible reversal of the burglary conviction because it was not raised in the initial appeal. View "Johnson v. Commonwealth" on Justia Law

Plaintiff filed suit in federal district court against her former employer, a hospital, alleging that she was terminated because she was preparing to report a medication error to an appropriate hospital regulatory authority pursuant to Ky. Rev. Stat. 216B.165. The district court certified a question of Kentucky law to the Supreme Court, asking whether a plaintiff who alleges that her employment was wrongfully terminated in violation of section 216B.165 may assert a claim for the recovery of front pay, along with other damages she may have sustained, by reason of her discharge. The Supreme Court answered in the affirmative, holding that, pursuant to the general remedial provisions of Ky. Rev. Stat. 446.070, an employee covered by section 216B.165, who suffers reprisal in violation of section 216B.165(3), may recover front pay as an element of compensable damages. View "Macglashan v. ABS Lincs Ky., Inc." on Justia Law

Plaintiffs, former members of the St. Joseph Catholic Orphan Society’s Board of Trustees, sued St. Joseph, challenging the validity of the Board’s action removing them from the Board and seeking reappointment to the Board. St. Joseph moved to dismiss, arguing that the trial court was without subject-matter jurisdiction because of the application of the ecclesiastical-abstention doctrine. The trial court denied the motion. St. Joseph then sought a writ of mandamus requiring the trial court to dismiss the underlying action. The court of appeals denied the writ. The Supreme Court (1) affirmed the denial of the writ, concluding that the ecclesiastical-abstention doctrine does not divest courts of subject-matter jurisdiction to adjudicate cases they are authorized to hear; but (2) reversed the trial court’s order denying St. Joseph’s motion. Specifically, the Court treated St. Joseph’s petition for writ of mandamus as an interlocutory appeal from the trial court’s denial of its motion to dismiss and, on the merits, agreed that the underlying action presented a question of ecclesiastical governance, which meant that the ecclesiastical-abstention doctrine prohibited the underlying action from going forward in the trial court. View "St. Joseph Catholic Orphan Soc’y v. Hon. Brian C. Edwards" on Justia Law

After Employer terminated an employment agreement with Employee, Employee sued for wrongful termination, seeking a declaration that a non-competition provision in the employment agreement was unenforceable. The trial court temporarily enjoined enforcement of the non-competition provision. Employer sought to dissolve the temporary injunction by filing a motion for temporary relief. The court of appeals granted the relief sought and dissolved the temporary injunction, finding that the trial court abused its discretion in issuing the temporarily injunction because Employee failed to make the requisite showing of irreparable injury. Employee subsequently requested that the Supreme Court granted him interlocutory relief and restore the trial court’s temporary injunction. The Supreme Court denied interlocutory relief, holding that the court of appeals did not err in finding that Employee failed to establish that he would suffer irreparable injury. View "Gharad v. St. Claire Med. Ctr., Inc." on Justia Law

After a jury trial, Appellant was convicted of second-degree manslaughter for killing her husband. Appellant was sentenced to eight years’ imprisonment. Appellant appealed, arguing that the trial court erred by admitting into evidence a recorded conversation between Appellant and a police detective in which Appellant was consistently silent in the face of accusatory questions. The court of appeals affirmed the convictions and sentence. The Supreme Court reversed, holding that the admission of the recording violated Appellant’s due process rights by using her silence against her, and the admission of the tape was not harmless error. View "Bartley v. Commonwealth" on Justia Law

After a jury trial, Appellant was found guilty of the second-degree rape of a twelve-year-old girl and sentenced to ten years’ imprisonment. The court of appeals affirmed. On appeal, Appellant argued, among other things, that a photograph of the victim lying in a hospital bed the day after she gave birth to Appellant’s child was improperly introduced at trial because the photograph was irrelevant to the case, highly prejudicial, and lacked any probative value. The Supreme Court reversed and remanded the case to the trial court, holding that the trial court abused its discretion in admitting the photograph into evidence, and the error was not harmless. View "Hughes v. Commonwealth" on Justia Law

Plaintiffs, several lot owners in Sandy Beach Subdivision, filed a petition for declaration of rights seeking a declaration that Sandy Beach Lane, a subdivision roadway, was a private roadway. Plaintiff also sought to enjoin Defendants, the developers of two separate subdivisions, or other lot owners in those subdivisions from installing driveways or culverts onto Sandy Beach Lane. The trial court concluded that Sandy Beach Lane was a private road for the sole use and benefit of the lot owners in Sandy Beach Subdivision. The court of appeals reversed, determining that Sandy Beach Lane was a public roadway dedicated by estoppel involving plat. The Supreme Court reversed, holding (1) Sandy Beach Lane is a private roadway for the use and benefit of lot owners in the Sandy Beach Subdivision; and (2) the easement for use of Sandy Beach Lane may not be extended or enlarged by allowing property owners in nearby, more recently-developed subdivisions to build driveways or culverts opening onto the road because this increased access to the road by adjacent landowners was not contemplated by the parties. View "Kircheimer v. Carrier" on Justia Law

Plaintiff filed a personal injury action against Defendants after sustaining serious injuries in an automobile collision. In the first trial, the jury was instructed on the “sudden emergency” doctrine and returned a verdict in favor of Defendants. The court of appeals reversed and remanded the case for a retrial, holding that the sudden emergency doctrine did not apply. On remand, the second jury was not instructed on the sudden emergency doctrine and, contrary to the first trial, was also not instructed Defendants had a duty to stay in the right lane. The second jury also returned a verdict in favor of Defendants. The court of appeals reversed, holding that the trial court should have granted Plaintiff’s motion for a directed verdict in the second trial and ordered the case to be retried only on the issues of damages. The Supreme Court affirmed, holding (1) the law-of-the-case doctrine did not preclude the court of appeals from determining whether a directed verdict should have been granted after the second trial; and (2) the court of appeals did not err in holding that the trial court should have directed verdict in Plaintiff’s favor, nor did the court misstate material facts in its opinion. View "Wright v. Carroll" on Justia Law

Appellant was convicted of two counts of first degree sexual abuse and three counts of first degree sodomy of two victims, Sarah and Nicholas. The Supreme Court affirmed, holding (1) any error that occurred by the admission of hearsay testimony from two of the Commonwealth’s witnesses was not palpable; (2) there was not palpable error in the introduction evidence that Appellant argued was impermissible Ky. R. Evid. 404(b) evidence; (3) Appellant was not unduly prejudiced by the testimonies of Sarah, Nicholas, and other witnesses; (4) any error in the the admission of a picture Nicholas drew in elementary school was not palpable; (5) the trial court did not violate Appellant’s right to a fair trial by failing to excuse a juror; and (6) Appellant was not denied his constitutional right to a speedy trial. View "Tackett v. Commonwealth" on Justia Law