Field & Main Bank, Inc. F/K/A Ohio Valley Financial Group, Inc., Successor by Merger and F/K/A Ohio Valley Bank, Inc., Successor by Conversion to Ohio Valley National Bank of Henderson v. Commonwealth of Kentucky, Transportation Cabinet, Department of Highways

CourtCourt of Appeals of Kentucky
DecidedJune 5, 2026
Docket2025-CA-0216
StatusPublished

This text of Field & Main Bank, Inc. F/K/A Ohio Valley Financial Group, Inc., Successor by Merger and F/K/A Ohio Valley Bank, Inc., Successor by Conversion to Ohio Valley National Bank of Henderson v. Commonwealth of Kentucky, Transportation Cabinet, Department of Highways (Field & Main Bank, Inc. F/K/A Ohio Valley Financial Group, Inc., Successor by Merger and F/K/A Ohio Valley Bank, Inc., Successor by Conversion to Ohio Valley National Bank of Henderson v. Commonwealth of Kentucky, Transportation Cabinet, Department of Highways) 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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Field & Main Bank, Inc. F/K/A Ohio Valley Financial Group, Inc., Successor by Merger and F/K/A Ohio Valley Bank, Inc., Successor by Conversion to Ohio Valley National Bank of Henderson v. Commonwealth of Kentucky, Transportation Cabinet, Department of Highways, (Ky. Ct. App. 2026).

Opinion

RENDERED: JUNE 5, 2026; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2025-CA-0216-MR

FIELD & MAIN BANK, INC. F/K/A OHIO VALLEY FINANCIAL GROUP, INC., SUCCESSOR BY MERGER AND F/K/A OHIO VALLEY BANK, INC., SUCCESSOR BY CONVERSION TO OHIO VALLEY NATIONAL BANK OF HENDERSON APPELLANT

APPEAL FROM HENDERSON CIRCUIT COURT v. HONORABLE KAREN LYNN WILSON, JUDGE ACTION NO. 21-CI-00688

COMMONWEALTH OF KENTUCKY, TRANSPORTATION CABINET, DEPARTMENT OF HIGHWAYS APPELLEE

OPINION DISMISSING APPEAL AND REMANDING

** ** ** ** **

BEFORE: CALDWELL, COMBS, AND EASTON, JUDGES.

EASTON, JUDGE: This highway condemnation case presents two important,

procedural questions of first impression. The first question is what the proper procedure is when the condemnor ultimately decides to take a lesser interest after

the right to take the property has been determined. Appellant challenges a

Henderson Circuit Court decision granting Appellee’s motion to amend its

condemnation petition years after the circuit court entered the appealable (but not

appealed) Interlocutory Order and Judgment (IOJ). The amendment changed a

small portion of the property affected, reducing the taking from a fee simple

interest to a temporary easement. The Appellant insists that this change was made

in bad faith and that the circuit court erred in not granting an evidentiary hearing

on its challenge to the amendment. After review of the record and applicable law,

we conclude that the law required the change and that no new hearing was

justified.

The second question is what the proper procedure is when a

condemnee claims an inverse taking has occurred, not because of the property

which is the subject of the petition, but because of traffic flow changes from the

larger project involving other properties. The Appellant here believes that it has

lost reasonable access to its property and should be commensurately compensated.

We conclude that the condemnee may assert this as a counterclaim. In these

circumstances, we dismiss1 this appeal and remand for the determination of the fair

1 A motion panel of this Court previously denied a motion to dismiss this appeal. “This Court retains authority to review decisions on motion panel that do not finally dispose of the case when the case is considered by a full-judge panel to which it is assigned.” Commonwealth Bank &

-2- rental value of the temporary easement ultimately taken as a result of the petition

and for further proceedings to address the inverse condemnation claim.

FACTUAL AND PROCEDURAL HISTORY

Appellee, the Kentucky Transportation Cabinet, Department of

Highways (KYTC) filed a Petition for Condemnation of property owned by

Appellant Field & Main Bank (Bank). This condemnation is part of a project to

design a new interchange between KY 351 and the former US 41 in downtown

Henderson. That project is then part of a larger project to complete the gap

between the northern and southern sections of I-69 and includes building a bridge

across the Ohio River. This section of US 41 essentially becomes part of a new

section of I-69. As it may impact Bank, the work has been completed and the

roads as reconfigured are operational.

Bank’s complaint focuses on how the project changes access from KY

351. KY 351 is known as Zion Road as it enters Henderson and then becomes 2nd

Street as one heads toward the Ohio River. Bank has a drive-thru branch at 1720

2nd Street, and this is the property at issue.

The overall project design involves three roundabouts on KY 351.

The first two roundabouts as one heads toward the Ohio River and approaches

Trust Co. v. Young, 361 S.W.3d 344, 350 (Ky. App. 2012). The issues presented here justified further briefing and oral argument to determine if dismissal of the appeal was proper and to determine the parameters of remand.

-3- Bank’s branch serve to provide access to I-69 (formerly US 41 at that location).

The last roundabout is to the right on 2nd Street as one faces that street from the

front of Bank’s branch. The impact of these roundabouts is that the new traffic

pattern prohibits a left turn across 2nd Street to get into Bank property. But Bank

customers apparently still have access by turning right from 2nd Street and by

turning left onto Franklin Street with a cut-through back to Bank’s 2nd Street

property.

The location of the last roundabout barely touched Bank’s property.

What was needed most was a relatively small temporary easement for the

construction, but KYTC did originally seek 82 square feet in fee simple in addition

to 657 square feet as a temporary easement. Considering the attraction basketball

has in this Commonwealth, the parties offer the dimensions of 82 square feet as

equivalent to one-third the size of a standard free-throw lane on a basketball court.

It might also be described as just about one-half of a single, standard parking lot

space. Literally, the fee parcel was just the very tip of a corner of Bank’s lot. This

tip was not being utilized in any way by Bank and the temporary or permanent

taking of this tip itself in no way impacted Bank’s access to its property.

The court-appointed commissioners determined a total award of

$1,900.00. Despite this assessment, KYTC voluntarily paid $5,800.00 into court.

Bank did not object to the right to take but did not like the highway design and its

-4- impact on access for its customers. It wanted to be heard by KYTC, including

input on details of the work to be done.2

And Bank clearly took exception to the amount of compensation

offered. In March 2022, the trial court entered the IOJ, ruling that KYTC had the

right to condemn the property and allowing it to take possession. Both parties filed

exceptions as to compensation, and the case eventually proceeded to mediation in

an unsuccessful effort to resolve the compensation issue.

After the mediation, KYTC redesigned the interchange to take none of

Bank’s property in fee and filed a Motion to Amend its Petition to take all 739

square feet only as a temporary easement. The circuit court received briefs and

heard arguments before entering an order without conducting an evidentiary

hearing on Bank’s challenge to the amended actual taking. The trial court granted

KYTC’s motion, and the commissioners, after resubmission to them for a new

valuation, returned a value of $2,145.00. This appeal followed. All issues have

been properly preserved, and the parties’ respective briefs comply with the

Kentucky Rules of Appellate Procedure (RAP).

2 While it might be expected that those who take property would consider construction-related concerns of those whose property has been taken and try to work with them, the property owner has no right to dictate any terms of the construction process. See Allard v. Big Rivers Electric Corporation, 602 S.W.3d 800 (Ky. App. 2020). A recent addition as Kentucky Revised Statute (KRS) 416.610(2)(e) requires consideration of access during construction.

-5- STANDARD OF REVIEW

Ultimately, this appeal turns on the propriety of the amendment of the

petition. CR3 15.01 provides that a party may amend his pleading by leave of court

and such leave “shall be freely given when justice so requires.” “While liberality

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Field & Main Bank, Inc. F/K/A Ohio Valley Financial Group, Inc., Successor by Merger and F/K/A Ohio Valley Bank, Inc., Successor by Conversion to Ohio Valley National Bank of Henderson v. Commonwealth of Kentucky, Transportation Cabinet, Department of Highways, Counsel Stack Legal Research, https://law.counselstack.com/opinion/field-main-bank-inc-fka-ohio-valley-financial-group-inc-successor-kyctapp-2026.