Angela Jackson v. Estate of Gary Day

CourtKentucky Supreme Court
DecidedFebruary 20, 2020
Docket2018-SC-0297
StatusUnpublished

This text of Angela Jackson v. Estate of Gary Day (Angela Jackson v. Estate of Gary Day) 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
Angela Jackson v. Estate of Gary Day, (Ky. 2020).

Opinion

RENDER

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ANGELA JACKSON AND APPELLANTS LAMONT MARSHALL

ON REVIEW FROM COURT OF APPEALS V. CASE NO. 2017-CA-000460-MR JEFFERSON CIRCUIT COURT NO. 15-CI-006537

ESTATE OF GARY DAY AND APPELLEES USAA GENERAL INDEMNITY COMPANY

OPINION OF THE COURT BY JUSTICE HUGHES

AFFIRMING

Appellants Lamont Marshall and Angela Jackson were injured in a two-

vehicle accident with Gary Day in February 2014. Despite a returned

summons in the court record indicating that Day had died in December 2014,

the Appellants did not discover his death until after the two-year statute of

limitations expired. Because they did not properly amend their complaint to

substitute his estate in place of Day individually within the limitations period,

the trial court granted summary judgment and dismissed the complaint based

on this Court’s holding in Gailor v. Alsabi, 990 S.W.2d 597 (Ky. 1999). The

Court of Appeals unanimously affirmed and adopted the trial court’s opinion in

its entirety. Having granted discretionary review and finding no error, we

affirm. FACTS AND PROCEDURAL HISTORY

On February 15, 2014, Lamont Marshall was driving his vehicle with

Angela Jackson riding as his passenger when they were struck in the rear by a

vehicle operated by Gary Day. Both Marshall and Jackson sustained injuries

as a result. Day’s vehicle was insured by State Farm Mutual Automobile

Insurance Company (State Farm) and Marshall’s vehicle was insured by USAA

at the time of the collision. Both Marshall and Jackson received basic

reparation benefits from USAA, with the last benefit payments being made on

May 30, 2014 and July 1, 2014, respectively.

The applicable statute of limitations, Kentucky Revised Statute (KRS)

304.39-230(6), reads as follows:

An action for tort liability not abolished by KRS 304.39-060 may be commenced not later than two (2) years after the injury, or the death, or the date of issuance of the last basic or added reparation payment made by any reparation obligor, whichever later occurs.

By operation of this statute, Marshall’s limitations period expired on May 30,

2016, and Jackson’s on July 1, 2016.

On December 29, 2015, well before the limitations period expired on

their claims, Marshall and Jackson filed a complaint against Day, individually,

alleging negligence and seeking damages for pain and suffering, physical and

mental injuries, and lost wages. Unbeknownst to all parties, Day had died

almost a full year earlier, on December 31, 2014. A civil summons was issued

to Day’s last known address via certified mail and was returned undelivered on

February 5, 2016, with notes stating, “return to sender,” “no such number,”

2 and “unable to forward.” The returned summons gave no indication that Day

was deceased.

On March 8, 2016, Marshall and Jackson amended their complaint to

add USAA as a defendant for underinsured motorist (UIM) benefits. An alias

summons was issued on that date to Day’s last known address via certified

mail and was again returned undelivered on April 12, 2016, with notes stating,

“return to sender,” “unclaimed,” and “unable to forward.” On April 28, 2016,

Marshall and Jackson had another alias summons issued to Day for service via

sheriff. The summons was returned to the clerk’s office on May 18, 2016, with

a notation that Day was “deceased,” although the notation entered on CourtNet

only stated, “alias not found.” Having been unable to effect service upon Day,

Marshall and Jackson sought appointment of a special bailiff in August 2016.

The special bailiff attempted service but reported to Marshall and Jackson’s

attorney that Day’s ex-wife informed him that Day had died on December 31,

2014. State Farm maintains, and Marshall and Jackson do not dispute, that

neither State Farm nor its counsel knew of Day’s death until informed of the

special bailiffs report by Marshall and Jackson’s counsel in August 2016.

On August 19, 2016, after expiration of the statute of limitations for both

Marshall and Jackson, they petitioned the probate court to appoint a public

administrator for Day’s estate (the Estate) and on September 7, 2016, Chris

Meinhart, public administrator, was appointed. Upon motion and with

approval of the court, a second amended complaint was filed on November 1,

2016, which substituted Patricia Smith as administrator of Day’s Estate in

3 place of Day individually. Patricia Smith is an attorney in Meinhart’s office

who routinely represents the public administrator in these matters. On

November 28, 2016, Smith filed a response stating that she was incorrectly

named as the administrator because she is in fact the attorney for the public

administrator. Upon motion and approval of the trial court, Marshall and

Jackson filed a third amended complaint on December 19, 2016, correctly

naming the Estate as a party with Chris Meinhart as the administrator.

On January 12, 2017, USAA filed a motion for summary judgment

arguing that Marshall and Jackson’s claims were time barred by the statute of

limitations. KRS 304.39-230(6). One week later, the Estate filed a similar

motion for summary judgment. Marshall and Jackson responded arguing that

the March 8, 2016 amended complaint, filed within the statute of limitations,

was not a nullity because it named USAA, over whom the court could acquire

jurisdiction, even if the court could not acquire jurisdiction over the deceased

Day. They further maintained that the third amended complaint could relate

back to the original complaint pursuant to Kentucky Rule of Civil Procedure

(CR) 15.03 because counsel for the Estate had notice of the action prior to the

expiration of the statute of limitations and the Estate was not prejudiced in

maintaining a defense.

The trial court concluded that the claims against the Estate were time

barred, relying on Gailor, 990 S.W.2d 597, and accordingly granted summary

judgment in favor of the Estate and USAA. The trial court reasoned that the

Estate could not have acquired knowledge that suit would have been brought

4 against it because it did not even exist as a legal entity within the limitations

period, and that nothing supported the proposition of imputing an attorney’s

knowledge to a non-existent client. Additionally, the trial court held that the

failure to bring suit against the Estate before the limitations period expired

precluded recoveiy of UIM benefits from USAA. As noted, Marshall and

Jackson appealed to the Court of Appeals, which adopted the trial court’s

opinion and order in its entirety.

ANALYSIS

I. Gailor v. Alsabi is applicable and controlling.

Twenty years ago, in Gailor, 990 S.W.2d 597, this Court addressed a case

factually similar to the one before us, dismissing an amended complaint

against a deceased driver’s estate as untimely. Marshall and Jackson argue

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Angela Jackson v. Estate of Gary Day, Counsel Stack Legal Research, https://law.counselstack.com/opinion/angela-jackson-v-estate-of-gary-day-ky-2020.