Commonwealth of Kentucky, Ex Rel. Attorney General Russell Coleman v. Perry County Fiscal Court, as a Political Subdivision and on Behalf of the Residents of Perry County, Kentucky

CourtCourt of Appeals of Kentucky
DecidedOctober 3, 2025
Docket2024-CA-0629
StatusPublished

This text of Commonwealth of Kentucky, Ex Rel. Attorney General Russell Coleman v. Perry County Fiscal Court, as a Political Subdivision and on Behalf of the Residents of Perry County, Kentucky (Commonwealth of Kentucky, Ex Rel. Attorney General Russell Coleman v. Perry County Fiscal Court, as a Political Subdivision and on Behalf of the Residents of Perry County, 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.

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Commonwealth of Kentucky, Ex Rel. Attorney General Russell Coleman v. Perry County Fiscal Court, as a Political Subdivision and on Behalf of the Residents of Perry County, Kentucky, (Ky. Ct. App. 2025).

Opinion

RENDERED: OCTOBER 3, 2025; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2024-CA-0629-MR

COMMONWEALTH OF KENTUCKY, EX REL. ATTORNEY GENERAL RUSSELL COLEMAN APPELLANT

APPEAL FROM FRANKLIN CIRCUIT COURT v. HONORABLE PHILLIP J. SHEPHERD, JUDGE ACTION NO. 23-CI-00082

PERRY COUNTY FISCAL COURT, AS A POLITICAL SUBDIVISION AND ON BEHALF OF THE RESIDENTS OF PERRY COUNTY, KENTUCKY; ANDREW BESHEAR, GOVERNOR, COMMONWEALTH OF KENTUCKY; CITY OF BARDSTOWN, KENTUCKY; CITY OF BEAVER DAM, KENTUCKY; CITY OF BEREA, KENTUCKY; CITY OF ELIZABETHTOWN, KENTUCKY; CITY OF HAZARD, KENTUCKY; CITY OF KUTTAWA, KENTUCKY; CITY OF MADISONVILLE, KENTUCKY; CITY OF MOREHEAD, KENTUCKY; CITY OF PIKEVILLE, KENTUCKY; CITY OF PRESTONSBURG, KENTUCKY; AND DENNIS KEENE, COMMISSIONER, KENTUCKY DEPARTMENT OF LOCAL GOVERNMENT APPELLEES

OPINION REVERSING AND REMANDING

** ** ** ** **

BEFORE: EASTON, A. JONES, AND LAMBERT, JUDGES.

EASTON, JUDGE: The Appellant, Commonwealth of Kentucky, ex rel. Attorney

General Russell Coleman (“OAG”) appeals from the Order of the Franklin Circuit

Court which held that KRS1 91A.400 is unconstitutionally arbitrary under Section

2 of the Kentucky Constitution as applied to the Appellee, the City of Hazard

(“Hazard”). The circuit court ruled that the statute created an arbitrary

classification by granting similarly situated cities taxing authority while depriving

the same authority to Hazard without any rational basis to do so. The circuit

court’s remedy was affirmative injunctive relief. The circuit court not only

1 Kentucky Revised Statutes. -2- declared the law unconstitutional as applied to Hazard but also ordered the

Governor’s Office of Local Government to include Hazard on the list of cities

eligible to impose the restaurant tax permitted by KRS 91A.400.

We have carefully examined the record and fully considered the

written and oral arguments of the parties. We determine that KRS 91A.400 is

constitutional even as applied to Hazard. We further rule that Hazard is barred by

considerations of equity from receiving the relief granted by the circuit court. We

thus reverse the Franklin Circuit Court and remand for dismissal of the case.

FACTUAL AND PROCEDURAL HISTORY

Some Kentucky constitutional history is required to understand the

context of the statute at issue. Before our most recent state constitution was

enacted in 1891, there were no constitutional provisions specifically governing

municipalities. Cities were chartered by the General Assembly, and a bewildering

array of laws applied to each city as the cities chose their structure and powers with

individualized sanction from the General Assembly. This ineffective ad hoc

approach to city government was a major factor in the decision to enact several

provisions of the 1891 Kentucky Constitution.

The Chairman of the Committee on Municipalities for the 1890-91

Constitutional Convention reported what would become Section 156 of the

Constitution and followed with these comments:

-3- The trend of all action on the part of the Convention has been to secure, as far as possible, uniformity in the operation in the laws of the Commonwealth. We have had in Kentucky special legislation run mad. No two cities in the Commonwealth are governed by a similar code of laws, and in the ordinary routine of corporate work and corporate action no two are controlled by similar provisions, but each, according to the caprice and whim of each particular local representation “did that which was right in its own eyes.”

1890-91 Const. Debates at 2228.

KY CONST. Section 156 established six classes of cities based on their

population. The goal was to have all cities within a class governed by the same

laws as to organization and powers of such cities. Of relevance to the issue

presented by this case, a “fourth class city” was a city with a population between

3,000 and 7,999 residents.

The duty of the General Assembly with respect to these classifications

was mandatory:

The General Assembly shall assign the cities and towns of the classes to which they respectively belong, and change assignments made as the populations of said cities may increase or decrease, and in the absence of other satisfactory information as to their population shall be governed by the last proceeding Federal census in so doing; but no city or town shall be transferred from one class to another, except in pursuance of a law previously enacted and providing therefore.

1890-91 Const. Debates at 6039 (emphasis added).

-4- The purpose of the requirement for legislative action to reclassify a

city was not so that the population categories could be ignored. The purpose was

instead to provide notice to the cities and their respective residents to prepare for

the changes coming with a reclassification. 1890-91 Const. Debates at 2133-34.

The classes were “fixed by the Constitution” not by the whim of the General

Assembly. 1890-91 Const. Debates at 2130. The drafters were justifiably

concerned about leaving the classes to the legislative branch. “Left to the General

Assembly, classification might become the subject of ‘legislative jugglery.’” Id.

Over the next hundred years, legislative jugglery is what we got.

Numerous statutes governed how cities of certain classes were governed and what

they could do. Despite the constitutional mandate, a city did not have to move to

another class if it did not want to do so. That city might like certain aspects of

being in one class over another. Without a legislative change to the classification,

there could be no change in classification according to Section 156. The result was

that many cities were not reclassified yet were obviously not in the correct class.

The concern about this potential and eventually realized problem was

expressed during the convention. Delegate Bullitt from McCracken County asked:

“There is no apprehension that Louisville might sink below its present

-5- population?” to which Chairman Young2 answered: “It provides, where a city

does, the Legislature shall place it in a smaller class.” 1890-91 Const. Debates at

2132 (emphasis added).

We will discuss only two cities, both participants in this case, to make

the point about inaccurate classification. In this discussion, we will rely (as the

General Assembly was supposed to do) on the United States Decennial Census

data.3 Elizabethtown was classified as a fourth class city as of 2014 despite its

population of over 30,000. Hazard was then classified as a third class city despite

its population of approximately 5,000.

Elizabethtown was in fact a fourth class city for many of the years

between 1930 and 1960. It crossed the line into third class status sometime

between 1950 and 1960. Hazard may never have been a third class city by

population. The closest it got was in the 1940 census which listed a population of

7,397. We are told that Hazard’s designation as a third class was made in 1950. It

2 Bennett Henderson Young was the Chairman of the Committee on Municipalities. Originally from Nicholasville, Young was an officer in the Confederate Army. He led the raid on St. Albans, Vermont, from Canada during the Civil War.

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Commonwealth of Kentucky, Ex Rel. Attorney General Russell Coleman v. Perry County Fiscal Court, as a Political Subdivision and on Behalf of the Residents of Perry County, Kentucky, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-of-kentucky-ex-rel-attorney-general-russell-coleman-v-perry-kyctapp-2025.