Chris Meinhart, Administrator of the Estate of Demetra Boyd v. Louisville Metro Government

CourtKentucky Supreme Court
DecidedAugust 23, 2021
Docket2019 SC 0237
StatusUnknown

This text of Chris Meinhart, Administrator of the Estate of Demetra Boyd v. Louisville Metro Government (Chris Meinhart, Administrator of the Estate of Demetra Boyd v. Louisville Metro Government) 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
Chris Meinhart, Administrator of the Estate of Demetra Boyd v. Louisville Metro Government, (Ky. 2021).

Opinion

RENDERED: AUGUST 26, 2021 TO BE PUBLISHED

Supreme Court of Kentucky 2019-SC-0237-DG

CHRIS MEINHART, ADMINISTRATOR OF THE APPELLANTS ESTATE OF DEMETRA BOYD; JUNENEAN HUSTON, AS PARENT, NEXT FRIEND AND ON BEHALF OF DEMETRICK BOYD, JR., A MINOR; TOSCA BELL, AS PARENT, NEXT FRIEND AND ON BEHALF OF LYNN-ASIA BELL, A MINOR; TOSCA BELL, AS PARENT, NEXT FRIEND AND ON BEHALF OF KEI-VONTEZ BELL, A MINOR; TOSCA BELL, AS PARENT, NEXT FRIEND AND ON BEHALF OF CORTEZ MOORE; LYNN TILLMAN AND DARNELL BOYD, AS PARENTS, NEXT FRIENDS AND ON BEHALF OF DEMETRIUS BOYD, A MINOR; DEMETRICK BOYD, SR.; AND AIRECA SMITH, INDIVIDUALLY AND AS PARENT AND NEXT FRIEND OF LOUIS SIMMONS, III, A MINOR

ON REVIEW FROM COURT OF APPEALS V. NOS. 2017-CA-0043 AND 2017-CA-0594 JEFFERSON CIRCUIT COURT NO. 08-CI-000204

LOUISVILLE METRO GOVERNMENT; THOMAS APPELLEES PUGH, INDIVIDUALLY AND IN HIS OFFICIAL CAPACITY AS A LOUISVILLE/JEFFERSON COUNTY METRO POLICE OFFICER; EMPIRE FIRE AND MARINE INSURANCE CO.; AND ENTERPRISE RENT-A-CAR COMPANY OF KENTUCKY

OPINION OF THE COURT BY JUSTICE NICKELL

AFFIRMING

The question presented in this appeal is whether a police officer is entitled to

qualified official immunity from liability for the decision to initiate a police

pursuit that ended in a fatal automobile accident. After years of litigation and multiple interlocutory appeals, the Court of Appeals ultimately rejected the trial

court’s determination the officer’s actions were ministerial rather than

discretionary. The Court of Appeals, therefore, concluded the officer was

shielded from liability. We granted discretionary review and, following a careful

review of the record, affirm the decision of the Court of Appeals.

On January 6, 2007, Louisville Metro Police Department (“LMPD”) Officer

Thomas Pugh engaged in a pursuit of Donta Jones who was a suspect in an

assault and purse snatching which had occurred near Fourth Street Live in

downtown Louisville. Officer Pugh had been alerted by a “frantic” victim she

had just been robbed and “felt lucky to be alive.” As he was speaking to the

victim, Jones drove past, and the victim identified him as her assailant. Officer

Pugh began maneuvering his cruiser behind Jones’ vehicle and activated his

emergency lights. Jones came to a stop and the officer stepped from his

cruiser. However, as Officer Pugh reached the rear bumper of the stopped car,

Jones started his vehicle and drove away. Officer Pugh returned to his cruiser,

activated his siren in addition to his emergency lights, and initiated a pursuit.

Less than two minutes after the pursuit began, with Officer Pugh trailing

approximately a block away, Jones entered an intersection against a red traffic

light and collided with a vehicle being operated by Demetrick Boyd, Sr.

(“Boyd”). Tragically, Demetra Boyd, an unrestrained minor passenger in Boyd’s

vehicle, was ejected from the vehicle and died from her resulting injuries. It

was her twelfth birthday. Boyd and his other six unrestrained minor

passengers sustained injuries. Officer Pugh was not involved in the collision.

2 Jones subsequently pled guilty to multiple criminal charges and received a

prison sentence of fifteen years.

In January 2008, Demetra’s estate and the parents of the other injured

children initiated civil actions against Jones, Boyd, Officer Pugh,1 Louisville

Metro Government (“Metro”), Enterprise Rent-A-Car, and Empire Fire and

Marine Insurance Co.2 Shortly thereafter, Officer Pugh and Metro moved to

dismiss the actions against them on immunity grounds. In denying Officer

Pugh’s motion, the trial court relied on Jones v. Lathram, 150 S.W.3d 50 (Ky.

2004),3 to conclude he was not entitled to immunity. The trial court did not

rule on Metro’s motion. Officer Pugh filed an interlocutory appeal from the

adverse decision. A unanimous panel of the Court of Appeals concluded Jones

was highly distinguishable and reversed the trial court. The matter was

remanded for further discovery to obtain sufficient evidence regarding LMPD’s

1 Officer Pugh was sued in both his individual capacity and in his official capacity as an LMPD officer.

2Boyd had borrowed the vehicle he was driving from a friend who had rented it from Enterprise. The car was insured by Empire.

3 In Jones, a Kentucky State Trooper was responding to a call for assistance from a local sheriff’s deputy when he collided with another vehicle in a “blind” intersection, killing the other driver. The trooper was not in pursuit of another vehicle. In denying the trooper qualified official immunity, we held “the act of safely driving a police cruiser, even in an emergency, is not an act that typically requires any deliberation or the exercise of judgment. Rather, driving a police cruiser requires reactive decisions based on duty, training, and overall consideration of public safety.” 150 S.W.3d at 53. The issue in Jones revolved around whether the trooper negligently operated his vehicle and adhered to standards for driving. Jones did not address whether initiation, continuation, and termination of a pursuit constituted a ministerial or discretionary act.

3 pursuit policies and Officer Pugh’s compliance therewith to enable the trial

court to properly rule on the immunity issue.

Nearly two years later, after extensive discovery had occurred related to

LMPD’s Standard Operating Procedures (“SOPs”) for pursuits,4 Officer Pugh

moved for summary judgment, again arguing he was entitled to qualified

official immunity. The motion was held in abeyance at Appellants’ request for

over three years, during which time more discovery was undertaken. In

December 2016, the trial court entered an order finding Officer Pugh had not

violated any of LMPD’s pursuit policies and was required to employ discretion

as to the means and method of pursuing Jones. Nevertheless, the trial court

denied Officer Pugh’s motion upon concluding the SOPs created a ministerial

duty rather than a discretionary one, and whether Officer Pugh acted

negligently in performing the ministerial act was a question for a jury to

resolve. This decision was based on the repeated use of the word “shall” in the

SOPs which the trial court believed rendered compliance merely the execution

of specific acts arising from certain and fixed facts.

Officer Pugh filed an interlocutory appeal seeking review of the trial

court’s second denial of qualified official immunity. While Officer Pugh’s appeal

was pending, the trial court denied Metro’s motion to dismiss based on

sovereign immunity, and Metro filed an interlocutory appeal of the adverse

4 During this period, Officer Pugh was deposed to provide the trial court sufficient testimony to independently make a determination regarding his compliance with the SOPs. LMPD had previously conducted an internal investigation and determined Officer Pugh had not violated the SOPs in his pursuit of Jones.

4 ruling. The two cases were consolidated for consideration by a single panel of

the Court of Appeals. On March 29, 2019, the Court of Appeals rendered its

Opinion5 wherein it explicitly rejected the trial court’s ruling the SOPs created a

ministerial duty. It concluded while the SOPs required an officer to consider

various factors in determining whether a pursuit was warranted, the officer is

left to balance the facts and assess whether to institute or terminate a pursuit.

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