Justia Government & Administrative Law Opinion Summaries

The Supreme Court affirmed the court of appeals' opinion affirming the decision of the Workers' Compensation Board, holding that Karen Woodall, the surviving spouse of an employee who died as a result of a workplace accident, was entitled to a statutory income benefit and that the time limitation as to the lump-sum benefit does not violate the United States and Kentucky constitutional guarantees of equal protection or Kentucky's prohibition against special legislation.Ten years after a workplace injury, Steven Spillman died as a result of a surgery required by that injury. Woodall, Spillman's surviving spouse, sought income benefits under Ky. Rev. Stat. 342.750(1)(a), and Spillman's estate sought a lump-sum benefit under Ky. Rev. Stat. 342.750(6). The Board found that Woodall was eligible for the surviving spouse income benefits but that the Estate was not entitled to the lump-sum death benefit. The court of appeals affirmed. The Supreme Court affirmed, holding (1) section 342.750(1)(a) contains no temporal limitation on Woodall's receipt of income benefits; and (2) the time limitation as to the lump-sum benefit is constitutional. View "Calloway County Sheriff's Department v. Woodall" on Justia Law

The Supreme Court reversed the court of appeals' decision reversing the circuit court's order dismissing Property Owners' appeal from the decision of the Kenton County Board of Adjustment granting approval of a conditional use application to allow the operation of a nursery school in a residential zone, holding that Kentucky law requires that a party must claim to be "injured or aggrieved" to perfect an appeal to circuit court under Ky. Rev. Stat. 100.347(1).After the Board unanimously granted the conditional use application Property Owners filed an appeal, alleging that the Board's action was improper because it did not meet certain statutory requirements and the requirements of the Kenton County Zoning Ordinance. The circuit court dismissed the appeal, concluding that Property Owners failed to allege that they were injured or aggrieved by the final action of the Board, and therefore, the court lacked subject matter jurisdiction. The court of appeals reversed, interpreting the "injured or aggrieved" language to be a standing requirement rather than a jurisdiction requirement. The Supreme Court reversed, holding that Property Owners failed to follow the appeal procedures in section 100.347(1) by not claiming in the complaint to be injured or aggrieved, and therefore, the circuit court appeals properly dismissed the action for lack of jurisdiction. View "Kenton County Board of Adjustment v. Meitzen" on Justia Law

In this case considering the Kentucky Horse Racing Commission's regulations as applied to historical horse racing the Supreme Court reversed the order of the circuit court determining that the Encore system constitutes a "pari-mutuel system of wagering," holding that the trial court misapplied the applicable regulation as a matter of law.The Commission, the Department of Revenue and several horse racing associations sought judicial approval for wagering on historical horse racing. The Family Foundation of Kentucky, Inc. was permitted to intervene and challenged both the validity of regulations and the premise that wagering on historical horse races was truly pari-mutuel wagering. The trial court concluded that the Encore system constituted a pari-mutuel system of wagering approved by the Commission. The Supreme Court reversed, holding that the Encore system does not create a wagering pool among patrons such that they are wagering among themselves, as required for pari-mutuel wagering. View "Family Trust Foundation of Kentucky, Inc. v. Kentucky Horse Racing Commission" on Justia Law

The Supreme Court reversed the opinion of the court of appeals affirming the decision of the Board of Trustees of the Kentucky Retirement Systems denying Edward Elder's application for disability retirement benefits, holding that the circuit court and the court of appeals misinterpreted this Court's holding in Kentucky Retirement Systems v. West, 413 S.W.3d 578 (Ky. 2013).Elder applied for disability retirement benefits due to a genetic disorder. Systems denied benefits because Elder submitted no pre-employment medical records. In affirming Systems' denial of benefits, the circuit court read West to require submission of pre-employment medical records to prove a disabling condition was asymptomatic and reasonably undiscoverable prior to hiring. The court of appeals affirmed the circuit court's reading of West and its denial of Elder's claim for disability retirement benefits. The Supreme Court reversed and remanded the case, holding that West imposed no requirement that a claimant submit pre-employment records to disprove the pre-existence of his genetic disorder. View "Elder v. Kentucky Retirement Systems" on Justia Law

The Supreme Court affirmed the opinion of the court of appeals affirming a workers' compensation board opinion that affirmed in part, vacated in part, and remanded the order and opinion of the administrative law judge (ALJ) for further findings of fact concerning whether Appellant was, pursuant to Ky. Rev. Stat. 342.610(w), an up-the-ladder employer of Randy Medlin, holding that there was a factual error present in the original ALJ analysis.On appeal, Appellant argued that the portion of the ALJ's opinion and order finding that Appellant was not an up-the-ladder employer pursuant to Ky. Rev. Stat. 342.610(2) was based on substantial evidence and, accordingly, the Board erred in not affirming the ALJ's decision. The Supreme Court affirmed, holding that the ALJ's determination was based upon a misconstruction of Uninsured Employers' Fund v. Ritchie, No. 2012-SC-00746-WC, 2014 WL 1118201 (Ky. Mar. 20, 2014). View "Tryon Trucking, Inc. v. Medlin" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that the circuit court had jurisdiction in this matter and denying a writ of prohibition preventing the circuit court from adjudicating an action filed by the Lexington Herald-Leader, holding that, as a matter of law, the circuit court had subject-matter jurisdiction over the underlying action filed by the Herald-Leader.In the underlying action, the Herald-Leader sought judicial review of the determination of the Kentucky Legislative Research Commission (LRC) that certain records requested by the Herald-Leader were not subject to disclosure under Kentucky's Open Records Act. Appellants, acting co-directors of the LRC, sought a writ of prohibition preventing the circuit court from adjudicating the action, asserting that the General Assembly had not granted the circuit court subject-matter jurisdiction to hear the merits of Herald-Leader's claims. The court of appeals denied the writ. The Supreme Court affirmed, holding (1) the circuit court had subject-matter jurisdiction to adjudicate the underlying case arising from the Herald-Leader's legislative records request; and (2) the trial court did not lack jurisdiction based on the separation of powers doctrine. View "Harrison v. Hon. Phillip J. Shepherd" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the decision of the Workers' Compensation Board affirming the decision of the administrative law judge (ALJ) denying benefits to Appellant for a knee injury and two back surgeries, finding they were not causally related to his employment and therefore not compensable, holding that the ALJ's conclusions were supported by substantial evidence.The ALJ awarded Appellant temporary total disability, permanent partial disability, and medical benefits for a back strain he sustained while employed but denied benefits for his knee injury and back surgeries. The board and court of appeals affirmed. The Supreme Court affirmed, holding (1) the ALJ's finding that Appellant's knee injury was not work-related and therefore not compensable was supported by substantial evidence; and (2) the ALJ's conclusions regarding Appellant's back surgeries were supported by substantial evidence. View "Wilkerson v. Kimball International, Inc." on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding an Administrative Law Judge's (ALJ) award of six percent permanent partial disability benefits to Appellant because of a work-related injury, holding that substantial medical evidence supported the six percent permanent partial disability found by the ALJ.On appeal, Appellant argued that the ALJ erred by making insufficient findings to exclude a pre-existing condition in assessing his impairment rating. The Workers' Compensation Board concluded that remand was necessary for the ALJ to address Finley v. DBM Technologies, 217 S.W.3d 261 (Ky. App. 2007). The court of appeals disagreed, holding that the ALJ did not need to apply Finley and that the ALJ based her opinion on substantial medical evidence. The Supreme Court affirmed, holding that the ALJ did not err in limiting her discussion of Finley and that substantial evidence supported the ALJ's findings. View "Wetherby v. Amazon.com" on Justia Law

The Supreme Court affirmed the opinion of the court of appeals affirming the decision of the Workers' Compensation Board reversing the determination of an administrative law judge (ALJ) denying Roger Hall's claim for benefits pursuant to Ky. Rev. Stat. chapter 342, holding that the ALJ erred by finding that Hall's claim was barred under Ky. Rev. Stat. 342.316(4)(a).Hall developed mesothelioma after being exposed to asbestos over the course of his employment. Hall brought a claim for benefits. The ALJ denied the claim, concluding that Hall's mesothelioma was caused by his exposure to asbestos during the course of employment but that his claim was untimely filed pursuant to Ky. Rev. Stat. 342.316(4)(a). The Board reversed. The Supreme Court affirmed, holding that the evidence compelled reversal of the ALJ's order. View "Letcher County Board of Education v. Hall" on Justia Law

The Supreme Court affirmed the opinion of the court of appeals affirming the decision of the Workers' Compensation Board affirming the ALJ's determination that Appellant was not entitled to benefits pursuant to Ky. Rev. Stat. 342 in connection with his injury while working as a bus driver for Transit Authority of River City (TARC), holding that the ALJ's decision denying Appellant benefits was supported by substantial evidence.While operating a TARC bus Appellant was assaulted by a passenger, resulting in injuries. TARC denied Appellant's claim for benefits pursuant to the special defense provided in Ky. Rev. Stat. 342.610(3), asserting that Appellant was the aggressor in the altercation and that he acted outside of the scope of his employment. After reviewing the evidence, the ALJ denied Appellant benefits. The Board and the court of appeals affirmed. The Supreme Court affirmed, holding that there was substantial evidence supporting the ALJ's determination to deny benefits. View "Trevino v. Transit Authority of River City" on Justia Law