Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the holding of the circuit court that HB 503, codified at Ky. Rev. Stat. 141.500-.528 and known as the "Education Opportunity Account Act" (EOA Act), is unconstitutional, holding that the EOA Act violates section 184.In 2021, the General Assembly passed the HB 563, which, as codified, established the Education Opportunity Account Program. Plaintiffs challenged the constitutionality of the EOA Act, arguing that it impermissibly redirects state revenues to nonpublic schools. The circuit court granted summary judgment on Plaintiffs' claims involving sections 59 and 184 of the Kentucky Constitution and granted the requested injunctive relief. The Supreme Court affirmed, holding that the EOA Act violates the plain language of section 184 and the prohibition on raising or collecting funds for nonpublic schools. View "Commonwealth ex rel. Cameron v. Johnson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court granting a directed verdict on a bad faith claim, holding that Wittmer v. Jones, 864 S.W.2d 885, 890 (Ky. 1993), established the applicable legal standard for both common law and statutory bad-faith claims.Cincinnati Insurance Company (CIC) brought a declaratory judgment action disputing coverage under a commercial general liability policy insuring K-2 Catering, LLC for claims Haley Belt made stemming from an accident that occurred during an event hosted by K-2's member-managers at their residence. Ultimately, judgment was entered declaring coverage under the policy. While the action was pending, Belt brought a separate action against K-2 and CIC, alleging bad faith and negligence in the settlement of her claims under K-2's policy. The negligence claims were settled and, after a jury trial, the jury returned a verdict against CIC. The court of appeals reversed, concluding that the trial court erred when it failed to grant CIC a directed verdict on the bad faith claims. The Supreme Court affirmed, holding that the trial court erred when it failed to apply the Wittmer standard and grant a directed verdict for CIC. View "Belt v. Cincinnati Insurance Co." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying two petitions for writs of prohibition in these cases involving allegations of the unconstitutionality of recently-enacted Ky. Rev. Stat. Chapter 202C, holding that the court of appeals did not err.KRS 202C, which went into effect April 2021, created a procedure for indefinite involuntary commitment for incompetent criminal defendants. Petitioners, who were in the midst of KRS 202C proceedings, filed petitions for writs of prohibition requesting relief from the alleged unconstitutional process set out in section 202C. The court of appeals denied relief, concluding that Petitioners had an adequate remedy by way of appeal. The Supreme Court affirmed, holding that writ relief was not appropriate. View "G.P. v. Honorable Bisig" on Justia Law

The Supreme Court vacated the judgment of the circuit court in this appeal challenging a ruling of the circuit court concerning the constitutionality of House Bill 348 (HB 348) and remanded the matter with instructions to dismiss the action in its entirety without prejudice, holding that Plaintiff's claims must be dismissed for lack of standing.HB 348 partially adopted the Supreme Court's 2016 proposed judicial redistricting plan, including the recommendation of the Supreme Court that one of the divisions of general jurisdiction in the thirty-first judicial circuit be eliminated. Plaintiff initiated this action arguing that HB 348's elimination of one division of general jurisdiction violated section 112(3) of the Kentucky Constitution. In a mixed ruling, the circuit court concluded that HB 348 was unconstitutional. The Supreme Court vacated the circuit court's judgment, holding that Plaintiff failed to allege a concrete and particularized injury-in-fact to confer constitutional standing in her individual capacity. View "Bradley v. Commonwealth" on Justia Law

The Supreme Court affirmed the judgment of the circuit court sentencing Defendant to twenty years' imprisonment for his convictions of two counts of manslaughter in the second degree, driving under the influence of controlled substances first offense, and persistent felony offender first degree, holding that Defendant's claims of error did not warrant reversal.Specifically, the Supreme Court held (1) the trial court was correct in declining to suppress Defendant's statements statements he made at the accident scene, and suppression of Defendant's blood test was not required in this case; (2) the trial court did not err in excusing a prospective juror for cause; and (3) while certain statements were not properly admissible during the Commonwealth's examination of detective Brandon McPherson, they did not rise to the level of palpable error resulting in manifest injustice. View "Simpson v. Commonwealth" on Justia Law

The Supreme Court affirmed in part and vacated in part the judgment of the circuit court in this criminal case, holding that the case must be remanded for the trial court to consider whether Defendant's consent to a blood draw was voluntary under the totality of the circumstances.Defendant entered a conditional plea to one count of manslaughter in the first degree and one count of manslaughter in the second degree. The Supreme Court affirmed in part and vacated in part, holding that the trial court (1) did not err by failing to suppress Defendant's statements obtained without a Miranda warning; (2) erred in suppressing the results of Defendant's blood draw without determining whether her consent was voluntary where she received a warning that if she refused the blood test and were convicted of DUI, her mandatory minimum jail sentence would be doubled; and (3) did not err by failing to dismiss the case due to alleged abuse of the grand jury process. View "Haney v. Commonwealth" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court denying Defendant's motion to suppress location data obtained from the police's search of his real-time cell-site location information (CSLI) and the evidence obtained from the search, holding that suppression was required.Defendant entered a conditional guilty plea to one count of first-degree robbery, one count of possession of a handgun by a convicted felon, and one count of receiving stolen property. The court of appeals reversed, concluding that the trial court erred in denying Defendant's motion to suppress because the police's acquisition of Defendant's real-time CSLI constituted a warrantless, unreasonable search. The Supreme Court affirmed, holding that the officers illegally obtained Defendant's real-time CSLI and that the evidence obtained therefrom should be excluded from evidence. View "Commonwealth v. Reed" on Justia Law

The Supreme Court affirmed the judgment of the circuit court denying Appellant's Ky. R. Crim. P. 11.42, Ky R. Crim. P. 10.02, Ky. R. Civ. P. 60.02, and Ky. R. Civ. P. 60.03 motion for relief, holding that the circuit court did not err.Appellant was convicted of two counts of complicity to murder and other crimes and sentenced to death. In the instant motion, Appellant argued that McCoy v. Louisiana, 138 S.Ct. 1500 (2018), governed his claim that his defense counsel provided ineffective assistance. The circuit court denied the motion, determining that the claim was both substantively and procedurally improper. The Supreme Court affirmed, holding that there was no error in the circuit court's denial of relief. View "Epperson v. Commonwealth" on Justia Law

The Supreme Court dismissed Appellants' claims in this case raising questions regarding a challenge to a constitutional ballot initiative, holding that Appellants lacked standing to bring their claims.In 2018, Kentucky voters ratified the constitutional amendment known as Marsy's Law, but the Supreme Court invalidated the amendment on procedural grounds. In 2020, after the General Assembly again proposed the Marsy's Law constitutional amendment, Appellants brought a complaint seeing declaratory and injunctive relief either prohibiting Marsy's Law from appearing on the ballot or preventing tabulation of votes on ratification of the amendment. The trial court ruled against Plaintiffs on their procedural claims but concluded that Appellants' facial challenges to Marsy's Law were not ripe. After the parties appealed, Kentucky voters ratified that Marsy's Law constitutional amendment. The Supreme Court dismissed this appeal, holding that Appellants lacked constitutional standing to bring their claims because they failed to allege a concrete and particularized injury in fact on the record. View "Ward v. Westerfield" on Justia Law

The Supreme Court affirmed the judgment of the circuit court finding Defendant guilty of two counts of murder and four counts of wanton endangerment in the first degree and sentencing him to life in prison without the possibility of parole, holding that there was no error or abuse of discretion.In 2012, a jury found Defendant guilty but mentally ill of murder and wanton endangerment. The Supreme Court reversed the conviction and remanded the case for a new trial. On remand, the main issue at trial was Defendant's affirmative defense of insanity or, in the alternative, extreme emotional disturbance. A jury found Defendant guilty of the crimes and sentenced to life in prison without the possibility of parole. The Supreme Court affirmed, holding Defendant's claims on appeal were without merit. View "Hall v. Commonwealth" on Justia Law