Donna Hardin v. Steven Pond

CourtCourt of Appeals of Kentucky
DecidedApril 20, 2023
Docket2021 CA 000499
StatusUnknown

This text of Donna Hardin v. Steven Pond (Donna Hardin v. Steven Pond) 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
Donna Hardin v. Steven Pond, (Ky. Ct. App. 2023).

Opinion

RENDERED: APRIL 21, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2021-CA-0499-MR

DONNA HARDIN APPELLANT

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE A. C. MCKAY CHAUVIN, JUDGE ACTION NO. 20-CI-004041

STEVEN POND APPELLEE

OPINION VACATING AND REMANDING

** ** ** ** **

BEFORE: CALDWELL, MCNEILL, AND TAYLOR, JUDGES.

TAYLOR, JUDGE: Donna Hardin brings this appeal from an April 14, 2021,

Opinion and Order of the Jefferson Circuit Court granting summary judgment and

dismissing Hardin’s negligence claims against Steven Pond upon the basis of

qualified official immunity. We vacate and remand. BACKGROUND

Pond was a police officer with the Louisville Jefferson County Metro

Government. On July 16, 2019, Officer Pond was on patrol in his police cruiser

and spotted a stolen vehicle at a Speedway gas station. Officer Pond confirmed

that the vehicle was stolen and then ordered the driver out of the vehicle. The

driver disregarded Officer Pond’s commands and drove away in the vehicle.

Officer Pond pursued the driver of the stolen vehicle. The driver lost control of the

stolen vehicle and hit a vehicle driven by Hardin. Hardin suffered injuries as a

result of the accident.

On July 13, 2020, Hardin filed a complaint against, inter alios, Officer

Pond. Hardin alleged that Officer Pond negligently and in violation of various

Louisville Metro Police Department Standard Operating Procedures (SOP)

initiated and continued the vehicle pursuit that caused the accident and her injuries.

In particular, Hardin claimed:

FIRST CAUSE OF ACTION (General Negligence in the Pursuit of Subject)

....

33) In violation of SOP 12.1.1 Policy, the officer should never have initiated the pursuit because the defendant was not committing a violent felony. Browning’s vehicle is defined as a “speeding vehicle” for the purposes of the policy. A violent felony for purposes of this policy does not include theft of vehicle. Specifically, the policy defines “violent felony offender” which includes several

-2- offenses all involving danger of serious injury to individuals. [Hardin] contends that [Louisville Metro Police Department] LMPD is negligent in the initiation and in the pursuit of Browning.

34) In violation of SOP 12.1.1, the officer should not initiate a pursuit when the conditions of pursuit cause a violent felony. As detailed in the facts above, the officer states before he ever gets into his vehicle the Defendant (Pond) states, “Sub. then pulled out of the parking lot at a high rate of speed with the intent to elude police. By fleeing, sub. created a substantial risk of serious physical injury or death to others on the roadway.” This specific fact as stated by the officer in his Uniform Citation, was indication that the pursuit should not have occurred and that the damage to [Hardin] should have been foreseeable.

35) In violation of SOP 12.1.3, the officer failed to evaluate these factors before the pursuit, and failed to recognize them. Particularly, the officer failed to recognize the area or location characteristics. Specifically, the pursuit proceeded down Greenwood Road in a highly traveled area in a residential section of . . . Jefferson County. The officer failed to recognize that the pursuit in this congested area was a foreseeable cause of the injuries to [Hardin].

36) Pursuant to SOP 12.1.9, the officer was required to terminate the pursuit for several reasons. Primarily, the officer must terminate the pursuit when he believes it is not safe to continue the pursuit. Officer states that the Browning left the parking lot at a high rate of speed and continued at a high rate of speed. Officer states the Browning struck another vehicle before colliding into [Hardin]. Under circumstances manifesting extreme indifference to the value of human life, Browning wantonly engaged in conducted [sic] causing him to strike Mr. Keeney’s vehicle which created a risk of substantial danger of death or serious physical injury.

-3- Further, the officer should terminate the pursuit when the officer loses visual contact with the subject. The officer should have concluded this pursuit immediately when Browning sped off and out of sight before the officer was ever in his vehicle.

37) Pursuant to SOP 12.1.3, the officer should have considered the nature and seriousness of the underlying offense. In particular, the underlying offense is theft of the motor vehicle. In the additional facts, LMPD had the specific information that Browning was photographed taking the vehicle by witness, which allowed detectives to make an identification. Browning had a prior record and could have been easily identified by mugshot or other identification programs. Further, the value of the vehicle listed as $6,500 per the Officer’s report. The officer could easily have let Browning leave, and no individual would have been injured and they could have later identified Browning by photograph. Additionally, the officer initiated this pursuit under circumstances manifesting extreme indifference to the value of human life as the officer wantonly engaged in conduct over a $6,500 vehicle, when they had pictures of Browning and identifiable information of the vehicle. There is no justification for this negligent, high-speed pursuit, which was foreseeable to result in death or serious physical injury.

SECOND CAUSE OF ACTION (Intentional Infliction of Emotional Distress – Against The Individual Defendants)

45) The foregoing conduct caused [Hardin] to suffer severe and extreme emotional distress. The individual defendants’ conduct was the proximate cause of harm

-4- and damage to [Hardin], and by reason of the foregoing alleged acts and conduct, [Hardin] is entitled to damages against the individual defendants, all according to proof at trial.

46) The individual defendants engaged in the aforementioned acts maliciously, callously, oppressively, wantonly, recklessly, fraudulently, with deliberate, indifference to the rights allegedly violated, despicably and with evil motive and/or intent, and in disregard of the rights of the [Hardin]. [Hardin] is therefore entitled to and does seek exemplary damages against the individual defendants.

THIRD CAUSE OF ACTION (Negligent Infliction of Emotional Distress – Against The Individual Defendants)

48) [Hardin] hereby incorporates by references all of the allegations contained in paragraphs 1 through 47 above, and though fully set forth herein.

49) The negligent actions of the individual defendants, as set forth above, [were] extreme and outrageous. Said negligent conduct was foreseeable to cause, and was the proximate cause of, severe emotional distress to [Hardin]. The individual defendants, by their negligent acts and/or omissions, conducted themselves in a manner that went beyond all common notions of decency. The individual defendants engaged in conduct intended to cause extreme indifference to human life. The individual defendants, through their actions and the actions of their agents, directly injured [Hardin] by their failure to act in accordance with common notions of fairness and decency.

50) The foregoing negligent conduct caused [Hardin] to suffer severe and extreme emotional distress. The

-5- individual defendants’ negligent actions [were] the proximate cause of harm and damage to [Hardin], and by reason of the foregoing alleged acts and conduct, [Hardin] is entitled to damages against the individual defendant, all according to proof at trial.

Complaint at 6 – 10.

Officer Pond filed a motion to dismiss. Pond argued he was entitled

to qualified official immunity. Specifically, Pond maintained that his decision to

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Bluebook (online)
Donna Hardin v. Steven Pond, Counsel Stack Legal Research, https://law.counselstack.com/opinion/donna-hardin-v-steven-pond-kyctapp-2023.