Central Farm Supply of Kentucky, Inc. v. Commissioner of the Department of Workplace Standards, Education and Labor Cabinet, Commonwealth of Kentucky

CourtCourt of Appeals of Kentucky
DecidedDecember 12, 2025
Docket2024-CA-0488
StatusUnpublished

This text of Central Farm Supply of Kentucky, Inc. v. Commissioner of the Department of Workplace Standards, Education and Labor Cabinet, Commonwealth of Kentucky (Central Farm Supply of Kentucky, Inc. v. Commissioner of the Department of Workplace Standards, Education and Labor Cabinet, Commonwealth of Kentucky) 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.

Bluebook
Central Farm Supply of Kentucky, Inc. v. Commissioner of the Department of Workplace Standards, Education and Labor Cabinet, Commonwealth of Kentucky, (Ky. Ct. App. 2025).

Opinion

RENDERED: DECEMBER 12, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-0488-MR

CENTRAL FARM SUPPLY OF KENTUCKY, INC. APPELLANT

APPEAL FROM FRANKLIN CIRCUIT COURT v. HONORABLE THOMAS D. WINGATE, JUDGE ACTION NO. 21-CI-00764

COMMISSIONER OF THE DEPARTMENT OF WORKPLACE STANDARDS, EDUCATION AND LABOR CABINET, COMMONWEALTH OF KENTUCKY AND KENTUCKY OCCUPATIONAL SAFETY AND HEALTH REVIEW COMMISSION APPELLEES

OPINION REVERSING AND REMANDING

** ** ** ** **

BEFORE: CALDWELL, EASTON, AND L. JONES, JUDGES.

JONES, L., JUDGE: Central Farm Supply of Kentucky, Inc. (Central Farm)

appeals the March 25, 2024 Order of the Franklin Circuit Court dismissing its

petition for administrative review for failure to timely issue a summons to the Commissioner of the Department of Workplace Standards, Education and Labor

Cabinet (Cabinet) and the Kentucky Occupational Safety and Health Review

Commission (KOSHRC). After careful review, we reverse the Order of the

Franklin Circuit Court and remand to the trial court for consideration of the merits

of Central Farm’s petition.

FACTUAL AND PROCEDURAL BACKGROUND

On July 21, 2018, Michael Ransdell, a Central Farm employee, died

after falling through a Plexiglas skylight in the roof of Central Farm’s warehouse.

Central Farm reported the incident to the Kentucky Office of Safety and Health.

Following inspection and review, several citations and penalties were issued for

violation of safety standards.

Central Farm filed a Notice of Contest, and the matter proceeded to an

administrative hearing on February 4, 2020, before a hearing officer. On

November 6, 2020, the hearing officer issued his Findings of Fact; Conclusions of

Law and Recommended Order (Recommended Order), recommending affirming

the citations and penalties. On September 1, 2021, KOSHRC entered a Decision

and Order adopting the Recommended Order.

On September 30, 2021, Central Farm filed an action in Franklin

Circuit Court, with a pleading titled “Notice of Appeal,” naming only the Cabinet

as “Appellee” and alleging, to wit:

-2- Comes Appellant and hereby gives Notice, as per KRS[1] 338.091, of its Appeal to Franklin Circuit Court of the Decision and Order of the Review Commission of September 1, 2021, as well as the Hearing Officer’s Findings of 11/30/21. [sic]

Record (R.) at 10.

A notation in the certified case history prepared by the Franklin

Circuit Court Clerk indicates that a summons was prepared on October 27, 2021,

and returned to Central Farm’s counsel.2 No proof of service was ever filed by any

process server. The “Notice of Appeal” itself, however, contained a Certificate of

Service affirming that a copy of such was sent to counsel at “Workplace Standards

Legal Division,” KOSHRC, and the hearing officer.

On November 17, 2022, Central Farm, the Cabinet, and KOSHRC

(which had not been named in the “Notice of Appeal”) tendered an Agreed Order

Concerning Briefing on Appeal to the Franklin Circuit Court. R. at 12. That

tendered order was signed by the trial court on November 11, 2022. R. at 14.

Following the parties’ submission of briefs on the merits of the

administrative appeal, the trial court, on July 17, 2023, entered an order, sua

1 Kentucky Revised Statutes. 2 The notation provides as follows:

10/27/2021 Summons Filed – COMMISSIONER OF @0001020409 WORKPLACE STANDARD, C . . . RETURNED TO ATTORNEY/PETITIONER

-3- sponte, raising the issue as to whether “Central Farm has complied with the

requirements to invoke judicial review.” R. at 493. In particular, the trial court

noted that:

Central Farm did not file a petition for judicial review but instead filed a “Notice of Appeal” and failed to “include the names and addresses of all parties to the proceeding and the agency involved, and a statement of the grounds on which the review is requested. KRS 13B.140(1). Moreover, the Court is not in possession of the administrative record. There has been no designation of the record nor has the agency transmitted the record to the Court for review.

“As a general rule, ‘[t]here is no appeal to the courts from an action of an administrative agency as a matter of right. When grace to appeal is granted by statute, a strict compliance with its terms is required.’” Ky. Unemployment Ins. Comm’n v. Wilson, 528 S.W.3d 336, 339 (Ky. 2017) (quoting Bd. of Adjustments of City of Richmond v. Flood, 581 S.W.3d 1, 2 (Ky. 1978)). The Court is required to ensure litigants strictly comply with the requirements for an administrative appeal. The Court may not apply the lesser doctrine of substantial compliance to administrative appeals. Kentucky Unemployment Ins. Comm’n v. Carter, 689 S.W.2d 360, 361 (Ky. 1985).

R. at 493.

To address those concerns, the trial court ordered the parties to brief

“whether Central Farm has strictly complied with the requirements for judicial

-4- review in order to invoke this Court’s jurisdiction.” Id. Following briefing,3 the

trial court entered an order on March 25, 2024, dismissing Central Farm’s

administrative appeal, finding that Central Farm “failed to strictly comply with

KRS 338.091(1)” by failing to issue a summons until October 27, 2021, well

outside the thirty-day window provided by KRS 338.091(1) to appeal a final

decision by the Cabinet. R. at 542. From that March 25, 2024 Order, Central

Farm filed a timely appeal.

On appeal, Central Farm argues that dismissal of its administrative

appeal on jurisdictional grounds was in error. Furthermore, Central Farm argues

that the citations and penalties issued were an abuse of discretion and contrary to

the law. We agree that the trial court’s decision to dismiss Central Farm’s

administrative appeal was in error because the Cabinet and KOSHRC waived any

defects in Central Farm’s invocation of judicial review. However, we decline to

address Central Farm’s arguments as to the merits of the citations and penalties,

finding that task more appropriate for the trial court on remand.

3 On August 16, 2023, Central Farm filed an “Amended Notice of Appeal/Petition for Review” naming the Cabinet and KOSHRC as “Appellees.” R. at 518-519. Alongside that “Amended Notice,” Central Farm filed a “Designation of Record,” R. 526-527, and a Response to the trial court’s July 17, 2023 Order. R. at 528-529. In that Response, Central Farm asked leave of the trial court to file the “tendered Amended Notice of Appeal/Petition for Review and Designation of the Record.” R. at 528-529. It does not appear from the record before us that the trial court ever ruled on Central Farm’s request for leave to file that Amended Notice or Designation of the Record.

-5- STANDARD OF REVIEW

The trial court disposed of Central Farm’s administrative appeal

solely on the issue of whether Central Farm complied with the statutory

requirements necessary to invoke its jurisdiction, and thus whether the trial court

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Central Farm Supply of Kentucky, Inc. v. Commissioner of the Department of Workplace Standards, Education and Labor Cabinet, Commonwealth of Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/central-farm-supply-of-kentucky-inc-v-commissioner-of-the-department-of-kyctapp-2025.