Brayden Grimsley v. Phillip Burnett, Jr., in His Individual Capacity and Official Capacity as Commissioner of the Kentucky State Police

CourtCourt of Appeals of Kentucky
DecidedDecember 19, 2025
Docket2023-CA-1149
StatusPublished

This text of Brayden Grimsley v. Phillip Burnett, Jr., in His Individual Capacity and Official Capacity as Commissioner of the Kentucky State Police (Brayden Grimsley v. Phillip Burnett, Jr., in His Individual Capacity and Official Capacity as Commissioner of the Kentucky State Police) is published on Counsel Stack Legal Research, covering Court of Appeals of Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Brayden Grimsley v. Phillip Burnett, Jr., in His Individual Capacity and Official Capacity as Commissioner of the Kentucky State Police, (Ky. Ct. App. 2025).

Opinion

RENDERED: DECEMBER 19, 2025; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-1149-MR

BRAYDEN GRIMSLEY APPELLANT

APPEAL FROM FRANKLIN CIRCUIT COURT v. HONORABLE PHILLIP J. SHEPHERD, JUDGE ACTION NO. 22-CI-00475

PHILLIP BURNETT, JR., IN HIS INDIVIDUAL CAPACITY AND OFFICIAL CAPACITY AS COMMISSIONER OF THE KENTUCKY STATE POLICE; AND HOLLY MCCOY JOHNSON, IN HER INDIVIDUAL CAPACITY AND OFFICIAL CAPACITY AS SECRETARY OF THE FINANCE AND ADMINISTRATION CABINET APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, EASTON, AND MCNEILL, JUDGES. ACREE, JUDGE: Appellant, Brayden Grimsley, seeks reversal of the Franklin

Circuit Court’s September 5, 2022 Order granting the CR1 12.02 dismissal of his

complaint against Phillip Burnett, Jr., in his individual capacity and his official

capacity as Commissioner of the Kentucky State Police (KSP Commissioner) and

Holly McCoy Johnson, in her individual capacity and her official capacity as

Secretary of the Finance and Administration Cabinet (Cabinet). We affirm.

RELEVANT BACKGROUND

On August 3, 2019, then-KSP Trooper Rickey Elmore arrested

Appellant during a traffic stop. There was a near immediate “Post level

preliminary inquiry” into Elmore’s actions. (Record (R.) 171). On August 9,

2019, the KSP Commander of Internal Affairs initiated a formal investigation.

(Id.). Video and audio footage revealed Elmore used excessive force against

Appellant, including tasing him without just cause. Elmore resigned before the

formal investigation completed. All criminal charges against Appellant eventually

were dismissed as lacking probable cause to arrest.

Appellant initiated a federal action solely against Elmore pursuant to

42 U.S.C.2 § 1983. He alleged Elmore’s conduct “was perpetrated with malice

and/or deliberate indifference . . . [,] wantonly, with gross negligence, recklessness

1 Kentucky Rules of Civil Procedure. 2 United States Code.

-2- and/or intent . . . [, and that] no probable cause existed to believe [Appellant]

committed any of the crimes he was charged with . . . .” (R. 47) (Complaint at 6,

Grimsley v. Elmore, No. 2:20-cv-00047-DLB-CJS, 2020 WL 12815036 (E.D. Ky.

Mar. 30, 2020)).

When Elmore was served with summons, he asked the

Commonwealth to provide his legal defense pursuant to KRS3 12.211 et seq., and

KRS 12.213 in particular. The Attorney General declined and so did the Governor.

So, in December 2020, Elmore and another officer similarly accused of improper

police conduct jointly sued the Governor alleging he breached a

statutory duty per Kentucky Revised Statutes (KRS) 12.213 to provide . . . Elmore with defense counsel in the federal civil actions but failed to do so. . . . Elmore also pointed out that the Kentucky Attorney General refused to provide [hi]m with defense counsel; however, [he] did not name the Attorney General as a party to the action.

Tucker v. Beshear, No. 2022-CA-0238-MR, 2023 WL 3666451, at *1 (Ky. App.

May 26, 2023) (describing the circuit court complaint).4

In October 2021, before the circuit court ruled on Elmore’s case

against the Governor, Appellant and Elmore settled the federal Section 1983

3 Kentucky Revised Statutes. 4 Aaron Tucker and Elmore jointly sued the Governor in Franklin Circuit Court presenting identical causes of action. Both were alleged to have engaged in improper use of force in effectuating an arrest, but in separate incidents. Both Tucker and Elmore had less than one year of service with the Kentucky State Police at the time of the incidents. Tucker, 2023 WL 3666451, at *1, *1 n.2.

-3- action. Elmore agreed to a $100,000 judgment, but only paid Appellant $10,000

upon execution of the agreement. A separate provision is more relevant to this

appeal.

That separate provision states:

Defendant [Elmore] agrees to assign his cause(s) of action, rights, entitlement, benefits, privileges, title, and interest, if any, to indemnification pursuant to KRS 16.185, or any other applicable law to Plaintiff [Appellant] . . . The Assignment of Rights for Indemnification Under KRS 16.185 is attached and marked as Exhibit B.

(R. 52) (double emphasis added). Exhibit B says much the same. (R. 61). In

Appellant’s words, he presumed KRS 16.185(1) “creates a substantive, statutory

property right to [the Commonwealth’s] indemnification” of Elmore, (Appellant’s

Br. 12), and that “Elmore established his right to indemnification.” (Id. at 13). On

that basis, Appellant accepted Elmore’s quitclaim of his chose in action against the

Commonwealth that Appellant believes the statute provides.

However, a state trooper’s indemnification pursuant to KRS 16.185 is

contingent upon a declaration by the KSP Commissioner that the trooper’s “act or

omission which resulted in liability was within the scope and course of . . .

employment and occurred during the performance of duty and was committed or

omitted in the good faith belief that the act or omission was lawful and proper.”

KRS 16.185(2). Making roughly the same argument Elmore made in Tucker,

supra, regarding KRS 12.213, Appellant argued KRS 16.185(1) established a right

-4- and, citing KRS 16.185(2) as establishing the KSP Commissioner’s duty to remove

the contingency, demanded he make the necessary declaration. The Commissioner

declined.

At the time Appellant made his demand, no court had interpreted

either KRS 12.213 or KRS 16.185 as creating any property right. However, a

month later, the Franklin Circuit Court did interpret KRS 12.213 in Tucker,

concluding “nothing in the statute creates, or even implies an absolute right for a

former employee to have the state provide a lawyer for the defense of such

claims.” Tucker, 2023 WL 3666451, at *1. Alternatively, the circuit court

concluded KRS 12.212 expressly authorizes the Attorney General to “‘decline to

provide for the defense of a civil action’ when he determines that the conduct for

which the employee was sued ‘was not within the scope and course of his

employment as a state employee,’ or it involved ‘actual malice[.]’” Id. The

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