Harlan Nursing Home, Inc. v. David Howard as Administrator of the Estate of Reed Howard

CourtCourt of Appeals of Kentucky
DecidedMarch 3, 2022
Docket2019 CA 001261
StatusUnknown

This text of Harlan Nursing Home, Inc. v. David Howard as Administrator of the Estate of Reed Howard (Harlan Nursing Home, Inc. v. David Howard as Administrator of the Estate of Reed Howard) 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
Harlan Nursing Home, Inc. v. David Howard as Administrator of the Estate of Reed Howard, (Ky. Ct. App. 2022).

Opinion

RENDERED: MARCH 4, 2022; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2019-CA-1261-MR

HARLAN NURSING HOME, INC. APPELLANT

APPEAL FROM HARLAN CIRCUIT COURT v. HONORABLE KENT HENDRICKSON, JUDGE ACTION NO. 15-CI-00144

DAVID HOWARD, AS ADMINISTRATOR OF THE ESTATE OF REED HOWARD APPELLEE

AND

NO. 2019-CA-1291-MR

DAVID HOWARD, AS ADMINISTRATOR OF THE ESTATE OF HIS FATHER, REED HOWARD CROSS-APPELLANT

CROSS-APPEAL FROM HARLAN CIRCUIT COURT v. HONORABLE KENT HENDRICKSON, JUDGE ACTION NO. 15-CI-00144

HARLAN NURSING HOME, INC. D/B/A HARLAN HEALTH & REHABILITATION CENTER; FIRST CORBIN LONG TERM CARE, INC.; FORCHT GROUP OF KENTUCKY, INC.; HARLAN REALTY, LLC; AND TERRY FORCHT CROSS-APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: GOODWINE, MAZE, AND McNEILL, JUDGES.

McNEILL, JUDGE: This is a wrongful death/negligence case in which Reed

Howard (hereafter “Mr. Howard”) died due to complications arising from care

provided by the Appellant, Harlan Nursing Home, Inc. (hereafter “Harlan”). The

Appellee is David Howard, as administrator of the estate of Mr. Howard (hereafter

“Estate”). The Estate alleged that Harlan, through its nursing home staff, failed to

provide appropriate bowel and nutritional management, catheter, and wound care,

ultimately causing Mr. Howard’s death. The Estate also brought suit for the same

claims against Britthaven Nursing Home (hereafter “Britthaven”), which entered

into a settlement agreement with the Estate prior to trial and is not a party to this

appeal.

The present case was ultimately tried before a Harlan Circuit Court

jury in June of 2019. At the close of the Estate’s case-in-chief, the court granted

Harlan’s motion for a directed verdict, therefore dismissing the Estate’s wrongful

death claim. The jury ultimately determined that Harlan was negligent and

-2- awarded the Estate damages totaling $958,903.39, appropriating 48% fault to

Harlan and 52% to Britthaven. Harlan filed several post-trial motions, all of which

were denied by the trial court. Harlan appealed to this Court as a matter of right

and raises six issues on appeal, each of which can be placed into one of two

categories: 1) alleged juror misconduct attested to by post-trial juror affidavits,

and 2) alleged evidentiary issues. The Estate cross-appealed, raising two issues

concerning damages.

ANALYSIS

A. Alleged Juror Misconduct

First, Harlan argues that the trial court erred in denying its motion for

a judgment notwithstanding the verdict (JNOV), and its motion for a new trial.

One basis for its motion for a new trial is that the jury, during deliberations, was

provided with deposition transcripts of one of Mr. Howard’s treating physicians

and one of his treating nurses. See McAtee v. Commonwealth, 413 S.W.3d 608,

622 (Ky. 2013) (applying harmless error review where the trial court erred by

permitting the jury to take a recorded testimonial witness statement to the jury

room). In further support of its argument, Harlan contends that there was juror

misconduct, including impermissible independent research apart from the evidence

presented at trial, and that the jury erroneously arrived at a “quotient verdict,”

wherein each juror apportioned fault and one juror took the average thereof for the

-3- final apportionment determination. Harlan also alleges that the jurors discussed

Harlan’s financial standing and that it was owned by a larger corporate entity,

presumably relevant to Harlan’s ability to pay the Estate. It is critical to reiterate

that these arguments arise solely from information provided in post-trial juror

affidavits.

We review a trial court’s ruling on a JNOV for clear error. Peters v.

Wooten, 297 S.W.3d 55, 65 (Ky. App. 2009). “[W]e are to affirm unless there is a

complete absence of proof on a material issue in the action, or if no disputed issue

of fact exists upon which reasonable men could differ.” Storm v. Martin, 540

S.W.3d 795, 800 (Ky. 2017) (citation omitted). However, because Harlan does not

specifically challenge the sufficiency of the evidence, we need not address the trial

court’s denial of Harlan’s JNOV motion. As to Harlan’s motion for a new trial,

“[t]he trial court is vested with a broad discretion in granting or refusing a new

trial, and [appellate courts] will not interfere unless it appears that there has been

an abuse of discretion.” Savage v. Three Rivers Med. Ctr., 390 S.W.3d 104, 111

(Ky. 2012) (citations omitted); see also Brown v. Commonwealth, 174 S.W.3d 421,

428 (Ky. 2005) (applying abuse of discretion to review of denial of motion for new

trial based on allegations of juror misconduct). We summarized the relevant law

concerning alleged juror misconduct in Crawford v. Marshall Emergency Services

-4- Associates, PSC, 431 S.W.3d 442, 445-46 (Ky. App. 2013). For the following

reasons however, we need not address Harlan’s claim on its merits.

Harlan does not discuss how the alleged misconduct came to the

attention of counsel. The affidavits were not attached as exhibits to its post-trial

motions; rather, they were filed “under seal,” although it appears that this

procedure was improperly observed. In its order denying Harlan’s post-trial

motions, the trial court notably provided the following commentary:

This is not a circumstance in which a party files a timely “skeletal” or “placeholder” motion regarding matters of record to be supplemented later by more thorough argument. Here, the affidavits are the only matters that could have given any substance to the jury-misconduct portions of the motion, and they were deliberately withheld from the [Estate], and the affiants remained unidentified, long after the 10-day limit in CR[1] 59.02 had expired.

...

Worse, [Harlan] withheld the affidavits in a patent attempt to prevent [the Estate] taking [its] own steps to address the allegations.

It is unclear whether the trial court in the present case reviewed the affidavits.

However, the court expressly stated in its order that it did not open the envelope

containing the fourth affidavit, as it did not arrive until after the hearing on the

matter and was submitted ex parte. Ultimately the court denied Harlan’s motion

1 Kentucky Rules of Civil Procedure.

-5- for a new trial on the basis that the court was divested of jurisdiction. More

precisely, the order at issue here indicates that while Harlan timely submitted its

motion for a new trial, it did not submit the supporting affidavits until several days

later, which violates the dictates of CR 59. See Ligon Specialized Hauler, Inc. v.

Smith, 691 S.W.2d 902, 904 (Ky. App. 1985) (“The rule’s opening language and

constraints on the opposing party imply that the moving party must satisfy CR

59.02’s 10 day deadline for supporting grounds and affidavits, as well as the

motion itself.”). We addressed a similar issue in Young v.

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

Related

Hoskins v. Maricle
150 S.W.3d 1 (Kentucky Supreme Court, 2004)
Hornback v. Hornback
636 S.W.2d 24 (Court of Appeals of Kentucky, 1982)
Parker v. Commonwealth
291 S.W.3d 647 (Kentucky Supreme Court, 2009)
Brown v. Commonwealth
174 S.W.3d 421 (Kentucky Supreme Court, 2005)
Potter v. Eli Lilly and Co.
926 S.W.2d 449 (Kentucky Supreme Court, 1996)
Horton v. Union Light, Heat & Power Co.
690 S.W.2d 382 (Kentucky Supreme Court, 1985)
Muncy v. Commonwealth
299 S.W.3d 281 (Court of Appeals of Kentucky, 2009)
Goodyear Tire and Rubber Co. v. Thompson
11 S.W.3d 575 (Kentucky Supreme Court, 2000)
Bowling v. Commonwealth
168 S.W.3d 2 (Kentucky Supreme Court, 2004)
Peters v. Wooten
297 S.W.3d 55 (Court of Appeals of Kentucky, 2009)
Zurich American Insurance Co. v. Journey Operating, LLC
323 S.W.3d 696 (Kentucky Supreme Court, 2010)
Berrier v. Bizer
57 S.W.3d 271 (Kentucky Supreme Court, 2001)
Irvine Toll Bridge Co. v. Williams
3 S.W.2d 193 (Court of Appeals of Kentucky (pre-1976), 1928)
Ligon Specialized Hauler, Inc. v. Smith
691 S.W.2d 902 (Court of Appeals of Kentucky, 1985)
Hashmi v. Kelly
379 S.W.3d 108 (Kentucky Supreme Court, 2012)
Savage v. Three Rivers Medical Center
390 S.W.3d 104 (Kentucky Supreme Court, 2012)
McAtee v. Commonwealth
413 S.W.3d 608 (Kentucky Supreme Court, 2013)
Crawford v. Marshall Emergency Services Associates, PSC
431 S.W.3d 442 (Court of Appeals of Kentucky, 2013)
Montgomery v. Viers
114 S.W. 251 (Court of Appeals of Kentucky, 1908)
Storm v. Martin
540 S.W.3d 795 (Missouri Court of Appeals, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Harlan Nursing Home, Inc. v. David Howard as Administrator of the Estate of Reed Howard, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harlan-nursing-home-inc-v-david-howard-as-administrator-of-the-estate-of-kyctapp-2022.