Justia Constitutional Law Opinion Summaries

Articles Posted in Kentucky Supreme Court
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The Supreme Court affirmed the decision of the court of appeals upholding the 2018 amendment to Ky. Rev. Stat. 342.730(4), holding that the statutory amendment did not violate the Contracts Clause of the federal and state constitutions.The statutory amendment at issue terminates workers' compensation income benefits when the recipient of the benefits reaches the age of seventy or four years from the date of injury or last injurious exposure, whoever occurs last. Plaintiffs challenged the constitutionality of the amendment. The court of appeals held that the amendment did not violate the Contracts Clause of the state and federal constitutions and that the statute was reasonable. The Supreme Court affirmed, holding that the 2018 amendment did not violate the Contracts Clause of the Federal or Kentucky Constitutions. View "Dowell v. Matthews Contracting" on Justia Law

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The Supreme Court reversed the judgment of the circuit court granting a temporary injunction against implementation of House Bill 1, Senate Bill 1, Senate Bill 2, and House Joint Resolution 77, which the General Assembly enacted during the 2021 regular session and which amended the Governor's power to respond to emergencies, as granted in Ky. Rev. Stat. 39A, holding that the circuit court abused its discretion in issuing the injunction.The Governor and the Secretary of the Cabinet for Health and Family Services filed this declaratory action seeking a declaration that the recently-passed legislation unconstitutionally infringed on the Governor's executive powers under the Kentucky Constitution. The circuit court temporarily enjoined implementation of the challenged legislation. Thereafter, the Governor sought modification of the temporary injunction to cover HJR 77, to which the Attorney General objected. The circuit court granted the request and put on hold the implementation of HJR 77 as well. The Supreme Court reversed, holding (1) this case presented a justiciable case or controversy; and (2) the temporary injunction was not warranted. View "Cameron v. Beshear" on Justia Law

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The Supreme Court held that the amendments that the legislature made in 2017 to Ky. Rev. Stat. Chapter 109 to give home rule cities located in a county containing a consolidated local government certain rights with respect to the waste management district in the county did not comply with the requirement of Kentucky Constitution Section 156a.At issue on appeal was whether the legislature's amendment to Chapter 109 in HB 246 (the Act) complied with the requirement of Section 156a, which permits the legislature to classify cities on certain bases but requires that all legislation relating to cities with a certain classification shall apply equally to all cities within the same classification. The circuit court concluded that the balance of Act was unconstitutional. The court of appeals affirmed in part and reversed in part. The Supreme Court affirmed in part and reversed in part, holding that Sections 1, 3 and 4 of the Act violated Kentucky Constitution Section 156a. View "Louisville/Jefferson County Metro Government Waste Management District v. Jefferson County League of Cities, Inc." on Justia Law

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The Supreme Court affirmed the circuit court's judgment convicting Defendant of complicity to murder and tampering with physical evidence, holding the trial court did not err in admitting unreacted out-of-court statements in which Defendant's co-defendant incriminated herself and Defendant to a cellmate who testified at trial.Specifically, the Supreme Court held (1) the trial court did not err in ruling that the Confrontation Clause was not implicated because the co-defendant's out-of-court statements to her cellmate were not testimonial and sufficient corroboration otherwise supported the admissibility of the statements; (2) the trial court did not err in admitting a jail phone call of Defendant; and (3) the Commonwealth's Attorney improperly questioned a witness, but the error did not render Defendant's trial fundamentally unfair. View "Fisher v. Commonwealth" on Justia Law

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The Supreme Court affirmed the judgment of the trial court convicting Defendant of two counts of first-degree sexual abuse and two counts of first-degree sodomy and sentencing him to life imprisonment, holding that there was no reversible error in the proceedings below.Specifically, the Supreme Court held (1) the jury instructions did not violate the Double Jeopardy Clause of the Kentucky or the United States Constitutions; (2) the Commonwealth presented sufficient evidence to convict Defendant of two counts of first-degree sodomy; and (3) Defendant was not deprived of a fair trial by the Commonwealth's attorney vouching during closing argument for the victim's truthfulness. View "Towe v. Commonwealth" on Justia Law

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The Supreme Court reversed Defendant's conviction of first-degree and second-degree arson and six counts of attempted murder, of which four were charged as hate crimes, holding that Defendant was denied a fair trial when the Commonwealth, aware of Defendant's intoxication during her arrest, opposed the intoxication defense instructions and implied to the jury that Defendant was not intoxicated.On appeal, Defendant argued that six trial errors required reversal, either individually or cumulatively. The Supreme Court held that the prosecutorial misconduct was flagrant enough to render the trial fundamentally unfair, simultaneously leading the jury to conclude facts contrary to the known facts and depriving Defendant of an ability to present her defense. The Court held that this one error was enough to require reversal but also addressed Defendant's remaining allegations of error, concluding that there were multiple errors in this case. View "Brafman v. Commonwealth" on Justia Law

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The Supreme Court held that Louisville Metro Government (LMG) and its employees are cloaked in sovereign immunity and qualified official immunity for an alleged violation of Ky. Rev. Stat. 71.040 and that money damages are unavailable because Ky. Rev. Stat. 446.070 does not waive immunity.James Hatcher died within twenty-four hours of entering the custody of the Louisville Metro Department of Corrections (LMDC). Plaintiffs filed suit alleging a violation of section 71.040. Plaintiffs alleged multiple torts and constitutional violations, seeking compensatory and punitive damages from LMG, the LMDC director, and six LMDC guards. The circuit court granted summary judgment for Defendants on all claims, and the court of appeals affirmed. The Supreme Court reversed in part, holding that LMG was immune from a claim for money damages, and that immunity was not waived. View "A.H. v. Louisville Metro Government" on Justia Law

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The Supreme Court affirmed Defendant's sentence of twenty years' imprisonment and convictions of not guilty by reason of insanity for first-degree murder, not guilty by reason of insanity for first-degree burglary, guilty but mentally ill of two counts of second-degree assault and guilty but mentally ill of fourth-degree assault, holding that any error was not prejudicial.Specifically, the Supreme Court held (1) the jury’s verdicts were not impermissibly inconsistent; (2) the trial court did not err by failing to grant Defendant's motions for directed verdict; (3) the trial court did not abuse its discretion by failing to provide lesser-included offense instructions to the jury; (4) the trial court's failure to provide the jury with the definition of "dangerous instrument" was harmless error; (5) the trial court did not abuse its discretion by denying Defendant's motion to strike two jurors for cause; and (6) the trial court erred by not making the requisite statutory findings under Ky. Rev. Stat. 703 before admitting prior bad act evidence, but the error was harmless. View "Exantus v. Commonwealth" on Justia Law

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The Supreme Court reversed Defendant's convictions for first-degree manslaughter, tampering with physical evidence, possession of a handgun by a convicted felon, and second-degree persistent felony offender, holding that Defendant was deprived of his right to counsel at a critical stage of the proceedings.On appeal, Defendant argued that he was denied the right to conflict-free counsel at a critical stage of the proceedings - during an in-chambers hearing the trial court conducted on the fitness and ability of Defendant's private attorney. The Supreme Court agreed, holding that the court's decision not to inform Defendant of the Commonwealth's allegations against his private attorney and not offer him the opportunity to retain independent counsel to represent his interests was of constitutional magnitude. View "Downs v. Commonwealth" on Justia Law

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The Supreme Court held that, in response to the COVID-19 global pandemic, Governor Andy Beshear properly declared a state of emergency and validly revoked the emergency powers granted to him in Ky. Rev. Stat. 93A.After the Governor declared a state of emergency pursuant to Executive Order 2020-215 on March 6, 2020 and proceeded to issue additional executive orders and emergency regulations, Plaintiffs filed suit challenging various orders affecting the reopening of their businesses. The parties obtained a restraining order prohibiting enforcement of certain of the emergency orders. On July 17, 2020, the Supreme Court stayed all injunctive orders. In this opinion, the Supreme Court lifted the stay and directed that those cases proceed consistent with this opinion and, as to circuit court litigation, reversed the July 20, 2020 order that would have granted a temporary injunction against enforcement of the Governor's orders but that was held in abeyance and remanded the case. The Court held (1) the governor properly invoked his emergency powers; (2) during the emergency, no violation of the separation of powers provisions of the Kentucky Constitution occurred; (3) Ky. Rev. Stat. 13A does not limit the governor's authority under the Constitution and Ky. Rev. Stat. 39A in the event of an emergency; and (4) the challenged orders and regulations are not arbitrary under the Constitution. View "Beshear v. Honorable Glenn E. Acree" on Justia Law