Estate of Karen Burden, by Michael Hoskins, Personal Representative v. Lawrence Hardison

CourtCourt of Appeals of Kentucky
DecidedDecember 22, 2020
Docket2018 CA 001601
StatusUnknown

This text of Estate of Karen Burden, by Michael Hoskins, Personal Representative v. Lawrence Hardison (Estate of Karen Burden, by Michael Hoskins, Personal Representative v. Lawrence Hardison) 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
Estate of Karen Burden, by Michael Hoskins, Personal Representative v. Lawrence Hardison, (Ky. Ct. App. 2020).

Opinion

RENDERED: DECEMBER 23, 2020; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2018-CA-1601-MR

ESTATE OF KAREN BURDEN, BY MICHAEL HOSKINS, PERSONAL REPRESENTATIVE APPELLANT

APPEAL FROM BULLITT CIRCUIT COURT v. HONORABLE RODNEY BURRESS, JUDGE ACTION NO. 13-CI-01276

LAWRENCE HARDISON AND LINDA HARDISON APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: GOODWINE, TAYLOR, AND K. THOMPSON, JUDGES.

TAYLOR, JUDGE: The Estate of Karen Burden, by Michael Hoskins, Personal

Representative (the Estate), brings this appeal from a July 10, 2018, Order of the

Bullitt Circuit Court granting summary judgment for Lawrence Hardison and Linda Hardison (the Hardisons) and dismissing the Estate’s negligence claim. We

affirm.

BACKGROUND

Karen Burden (Karen) resided with the Hardisons in their home in

Shepherdsville, Kentucky. On June 30, 2013, Karen assisted Lawrence and Linda

in collecting brush on their property and assembling it into a large pile. Linda

decided to burn the brush pile and poured gasoline on the brush. At her deposition,

Linda testified that she poured gasoline on the brush pile, in Karen’s presence.

Linda also testified that Karen directed her to pour additional gasoline on at least

two other spots in the pile. Linda then testified she had left her matches to light the

pile at the house which she went to retrieve. Before leaving for the house, Karen

suggested to Linda that she could light the pile with her cigarette lighter. Linda

testified that she adamantly told Karen not to light the pile with her cigarette

lighter and continued walking away. Linda further testified that shortly after

telling Karen not to light the pile, Linda heard a “boom” and saw Karen rolling

downhill away from the fire. Karen had lit the brush pile with her lighter which

exploded. As a result, Karen suffered serious burns and injuries.

On December 20, 2013, Karen filed a negligence action against the

Hardisons in Bullitt Circuit Court. The complaint alleged that Karen had no

knowledge that the brush had been soaked with gasoline by Linda and that Linda

-2- instructed Karen to light the brush. On December 27, 2013, Karen died. On

March 31, 2014, the Estate filed an amended complaint alleging Karen died from

her burn injuries.1

The circuit court granted summary judgment to the Hardisons by

order entered July 10, 2018. By order entered October 18, 2018, the court denied

the Estate’s Kentucky Rules of Civil Procedure (CR) 59.05 motion to alter, amend,

or vacate the summary judgment. This appeal follows.

STANDARD OF REVIEW

In Kentucky, the standard of review on appeal of a summary judgment

is “whether the trial court correctly found that there were no genuine issues as to

any material fact and that the moving party was entitled to judgment as a matter of

law.” Scifres v. Kraft, 916 S.W.2d 779, 781 (Ky. App. 1996) (citing CR 56.03).

“The record must be viewed in a light most favorable to the party opposing the

motion for summary judgment and all doubts are to be resolved in his favor.”

Steelvest, Inc. v. Scansteel Service Ctr, Inc., 807 S.W.2d 476, 480 (Ky. 1991).

Summary judgment is not a substitute for trial. Id.

1 Lawrence Hardison and Linda Hardison (the Hardisons) state in their brief that Karen Burden (Karen) died from cancer. The amended complaint filed by the Estate of Karen Burden (the Estate) alleges Karen died from the injuries she sustained from the fire. Record on Appeal at 22. The Estate’s appellate brief does not reference a claim for wrongful death or that Karen died from her burn injuries. The order granting summary judgment found that Karen died “from health issues not related to this incident.” Record on Appeal at 232.

-3- And, relevant to our review in this appeal as will be discussed, is the

sufficiency of evidence presented by a party in opposition to a properly supported

motion for summary judgment. Such a motion will not be defeated without the

responding party presenting some affirmative evidence establishing that there

exists a genuine issue of material fact. Steelvest, 807 S.W.2d at 482; Hubble v.

Johnson, 841 S.W.2d 169, 171 (Ky. 1992). This affirmative evidence must also be

admissible. Walker v. Commonwealth, 503 S.W.3d 165, 177 (Ky. App. 2016).

ANALYSIS

A. Evidence Admissibility Issues

In responding to the Hardisons’ motion for summary judgment, the

Estate relied on a videotaped statement by Karen taken under oath on November

18, 2013, prior to the filing of the complaint and Karen’s death. The circuit court

concluded this was inadmissible hearsay evidence. The Estate also responded to

the motion with two recorded statements of neighbors living near the Hardisons

who were working nearby when the explosion occurred. The statements were

taken by an investigator retained by the Estate. The statements were not taken

under oath nor in the presence of counsel. As with Karen’s statement, the circuit

-4- court declined to consider these statements, since the witnesses gave no sworn

testimony that was part of the record before the court.2

The Estate argues that the circuit court erred in failing to consider this

evidence to rebut the motion for summary judgment. Accordingly, we will review

this issue first.

As for Karen’s sworn statement taken prior to the litigation, the Estate

appears to concede that her statement was hearsay evidence but argues it is still

admissible under the exception set out in Kentucky Rules of Evidence (KRE)

804(b)(1), which reads as follows:

(1) Former Testimony. Testimony given as a witness at another hearing of the same or a different proceeding, or in a deposition taken in compliance with law in the course of the same or another proceeding, if the party against whom the testimony is now offered, or, in a civil action or proceeding, a predecessor in interest, had an opportunity and similar motive to develop the testimony by direct, cross, or redirect examination.

The Estate contends Karen’s statement falls under this hearsay

exception because she is unavailable as a witness and the Hardisons’ insurance

carrier was notified that the statement was being taken and thus, the carrier became

the Hardisons’ predecessor in interest. What qualifies as a predecessor in interest

under Kentucky law is unsettled. However, we need not determine here whether

2 For some unexplained reason, these witnesses had not been deposed during the four-year history of the case.

-5- the Hardisons’ insurance carrier was their predecessor in interest because KRE

804(b)(1) applies only to testimony given in a court or similar legal proceeding.

When Karen made her statement, there was no pending litigation and, thus, there

were no pending legal proceedings at that time. See BLACK’S LAW DICTIONARY

(11th ed. 2019) (defining “proceeding” as “[t]he regular and orderly progression of

a lawsuit, including all acts and events between the time of commencement and the

entry of judgment.”). Additionally, taking a sworn statement in contemplation of

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cargill v. Greater Salem Baptist Church
215 S.W.3d 63 (Court of Appeals of Kentucky, 2006)
Steelvest, Inc. v. Scansteel Service Center, Inc.
807 S.W.2d 476 (Kentucky Supreme Court, 1991)
Rogers v. Professional Golfers Ass'n of America
28 S.W.3d 869 (Court of Appeals of Kentucky, 2000)
Turner v. Commonwealth
5 S.W.3d 119 (Kentucky Supreme Court, 1999)
Kentucky River Medical Center v. McIntosh
319 S.W.3d 385 (Kentucky Supreme Court, 2010)
Hubble v. Johnson
841 S.W.2d 169 (Kentucky Supreme Court, 1992)
Scifres v. Kraft
916 S.W.2d 779 (Court of Appeals of Kentucky, 1996)
Hopkins v. Ratliff
957 S.W.2d 300 (Court of Appeals of Kentucky, 1997)
Dick's Sporting Goods, Inc. v. Webb
413 S.W.3d 891 (Kentucky Supreme Court, 2013)
Shelton v. Kentucky Easter Seals Society, Inc.
413 S.W.3d 901 (Kentucky Supreme Court, 2013)
Carter v. Bullitt Host, LLC
471 S.W.3d 288 (Kentucky Supreme Court, 2015)
Goodwin v. Al J. Schneider Co.
501 S.W.3d 894 (Kentucky Supreme Court, 2016)
Walker v. Commonwealth
503 S.W.3d 165 (Court of Appeals of Kentucky, 2016)
Grubb v. Smith
523 S.W.3d 409 (Kentucky Supreme Court, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Estate of Karen Burden, by Michael Hoskins, Personal Representative v. Lawrence Hardison, Counsel Stack Legal Research, https://law.counselstack.com/opinion/estate-of-karen-burden-by-michael-hoskins-personal-representative-v-kyctapp-2020.