Aaron Jones v. Ray Pinter D/B/A Ray Pinter Construction

CourtKentucky Supreme Court
DecidedMarch 22, 2022
Docket2021 SC 0138
StatusUnknown

This text of Aaron Jones v. Ray Pinter D/B/A Ray Pinter Construction (Aaron Jones v. Ray Pinter D/B/A Ray Pinter Construction) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aaron Jones v. Ray Pinter D/B/A Ray Pinter Construction, (Ky. 2022).

Opinion

RENDERED: MARCH 24, 2022 TO BE PUBLISHED

Supreme Court of Kentucky 2021-SC-0138-DG

AARON JONES APPELLANT

ON REVIEW FROM COURT OF APPEALS V. NO. 2020-CA-0260 JEFFERSON CIRCUIT COURT NO. 14-CI-001407

RAY PINTER D/B/A RAY PINTER APPELLEE CONSTRUCTION

OPINION OF THE COURT BY CHIEF JUSTICE MINTON

REVERSING AND REMANDING

This personal injury action has been percolating through the Kentucky

courts since 2014. At issue at this stage in the case is whether the trial court

abused its discretion by dismissing this action with prejudice under CR1

41.02(1). We accepted discretionary review to examine further when the

extreme remedy of dismissal of a civil action with prejudice under CR 41.02(1)

is appropriate. Finding an abuse of discretion on this record, we reverse.

I. FACTS AND PROCEDURAL BACKGROUND

In 2014, Appellant Aaron Jones commenced this tort action, alleging

violations of state and federal laws relating to occupational safety. Jones

1 Kentucky Rules of Civil Procedure. served written discovery and deposed Appellee Ray Pinter. But, in 2015, the

trial court dismissed Jones’s case without prejudice for lack of prosecution

under CR 77.02. Jones moved for reinstatement because his counsel failed to

receive the Notice to Dismiss for Lack of Prosecution. Jones also noted that,

contrary to the trial court’s notice, pretrial steps had been taken in the

preceding year between June 6, 2014, and June 6, 2015. The trial court

granted reinstatement, entered a pretrial order, and the parties engaged in

additional discovery.

In 2016, Pinter moved for summary judgment. The trial court denied

Pinter’s motion. Pinter appealed. The Court of Appeals affirmed denial of

summary judgment. This Court denied Pinter’s motion for discretionary review

in December 2018. Later, Jones disclosed expert witnesses, identified lay

witnesses, and noticed alleged damages. Pinter deposed Jones for a second

time.

The trial court entered a pretrial order directing the parties to attempt to

resolve their disputes through mediation before the pretrial conference. The

trial court did not order the parties to attend mediation at a specific date or

time. On October 1, 2019, Jones failed to appear for mediation scheduled by

the parties without notifying Pinter in advance. In response, Pinter moved to

compel mediation and for an order requiring Jones to pay a portion of the fees

related to the missed mediation. The trial court granted the motion and

required Jones to pay Pinter’s share of expenses related to the initial

2 mediation. Jones appeared for a rescheduled mediation on October 30, 2019.

Mediation failed to resolve the parties’ disputes.

Pinter filed a notice for an independent medication examination (“IME”)

under CR 35.01. The trial court did not enter an order requiring Jones to

attend the IME. The parties scheduled the IME for November 1, 2019. Jones

failed to appear without prior notice.

In response, Pinter moved for involuntary dismissal under CR 41.02(1).

Jones responded in opposition. Jones attributed his conduct to memory

impairment caused by injuries he sustained in the 2013 accident at issue in

this case. On January 29, 2020, the trial court found that dismissal with

prejudice was warranted “because by failing to appear for the mediation and

IME, Jones violated the Civil Rules and this Court’s Pre Trial Order and failed

to reasonably cooperate with Pinter’s attempt to prepare his case.”

The Court of Appeals affirmed in a split decision, with one judge

concurring in the result only and another judge dissenting without

explanation. This Court granted discretionary review.

II. STANDARD OF REVIEW

We review dismissals under CR 41.02 for abuse of discretion.2 Under

this standard of review, we will reverse the trial court’s dismissal only if it was

arbitrary, unreasonable, unfair, or unsupported by sound legal principles.3

2 Jaroszewski v. Flege, 297 S.W.3d 24, 32 (Ky. 2009). 3 Goodyear Tire & Rubber Co. v. Thompson, 11 S.W.3d 575, 581 (Ky. 2000).

3 III. ANALYSIS

Under CR 41.02(1), a defendant may move for dismissal of an action or

claim for three reasons.4 First, a defendant may move for dismissal based on

plaintiff’s failure to prosecute.5 Second, a defendant may move for dismissal

due to plaintiff’s failure to comply with the Kentucky Rules of Civil Procedure.6

Third, a defendant may move for dismissal for plaintiff’s failure to comply with

any order of the court.7 Consideration of a motion to dismiss under CR

41.02(1) requires fact-specific determinations that are left to the sound

discretion of the trial court.8 The trial court must base its assessment on the

totality of the circumstances.9

Still, a trial court’s discretion is not unfettered and is subject to an

important limitation. Our courts have long recognized that CR 41.02(1)

dismissal with prejudice is an “extreme remedy.”10 As a result, we must

“carefully scrutinize the trial court's exercise of discretion” when reviewing

dismissal with prejudice under CR 41.02(1).11

4 CR 41.02(1) (“For failure of the plaintiff to prosecute or to comply with these rules or any order of the court, a defendant may move for dismissal of an action or of any claim against him.”). 5 Id. 6 Id. 7 Id. 8 Jaroszewski, 297 S.W.3d at 32. 9 See id. at 36. 10 Id. at 40. Cf. Manning v. Wilkinson, 264 S.W.3d 620, 624 (Ky. App. 2007);

Toler v. Rapid American, 190 S.W.3d 348, 351 (Ky. App. 2006); Polk v. Wimsatt, 689 S.W.2d 363, 364–65 (Ky. App. 1985). 11 Manning, 264 S.W.3d at 624.

4 In considering the totality of the circumstances, trial courts may consider

the factors espoused in Ward v. Housman.12 Ward provides a nonexclusive list

of factors for consideration when analyzing the totality of the circumstances

relevant to a motion to dismiss for lack of prosecution under CR 41.02.13 The

Ward factors are: “1) the extent of the party's personal responsibility; 2) the

history of dilatoriness; 3) whether the attorney's conduct was willful and in bad

faith; 4) meritoriousness of the claim; 5) prejudice to the other party, and 6)

alternative sanctions.”14

The trial court dismissed this action both for Jones’s noncompliance with

the court’s orders and for his failure to prosecute. We consider each in turn.

A. Dismissal for Noncompliance with Court Orders

The trial court concluded that dismissal was warranted in part because

Jones violated orders of the court by failing to appear for mediation and the

IME. But, on this record, to the extent Jones violated any court orders, those

violations were insufficient to warrant the extreme remedy of dismissal with

prejudice.

First, the trial court incorrectly relied on the missed mediation as a basis

for dismissal because Jones ultimately complied with the court’s pretrial order,

which required the parties to attempt to resolve their disputes through

mediation before the pretrial conference.

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Related

Scarborough v. Eubanks
747 F.2d 871 (Third Circuit, 1984)
Toler v. Rapid American
190 S.W.3d 348 (Court of Appeals of Kentucky, 2006)
Polk v. Wimsatt
689 S.W.2d 363 (Court of Appeals of Kentucky, 1985)
Manning v. Wilkinson
264 S.W.3d 620 (Court of Appeals of Kentucky, 2007)
Goodyear Tire and Rubber Co. v. Thompson
11 S.W.3d 575 (Kentucky Supreme Court, 2000)
Nolan v. Neeley-Thoms
290 S.W.3d 89 (Court of Appeals of Kentucky, 2009)
Jaroszewski v. Flege
297 S.W.3d 24 (Kentucky Supreme Court, 2009)
Ward v. Housman
809 S.W.2d 717 (Court of Appeals of Kentucky, 1991)

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Aaron Jones v. Ray Pinter D/B/A Ray Pinter Construction, Counsel Stack Legal Research, https://law.counselstack.com/opinion/aaron-jones-v-ray-pinter-dba-ray-pinter-construction-ky-2022.