Jaime Morales v. City of Georgetown, Kentucky

CourtKentucky Supreme Court
DecidedOctober 24, 2024
Docket2023-SC-0248
StatusUnpublished

This text of Jaime Morales v. City of Georgetown, Kentucky (Jaime Morales v. City of Georgetown, Kentucky) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jaime Morales v. City of Georgetown, Kentucky, (Ky. 2024).

Opinion

RENDERED: OCTOBER 24, 2024 TO BE PUBLISHED

Supreme Court of Kentucky 2023-SC-0248-DG

JAIME MORALES APPELLANT

ON REVIEW FROM COURT OF APPEALS V. NO. 2022-CA-0009 SCOTT CIRCUIT COURT NO. 19-CI-00593

CITY OF GEORGETOWN, KENTUCKY; APPELLEES OFFICER JOSEPH ENRICCO, INDIVIDUALLY AND IN HIS CAPACITY AS A DEPUTY WITH THE GEORGETOWN POLICE DEPARTMENT; GEORGETOWN POLICE DEPARTMENT; AND LIEUTENANT JAMES WAGONER, INDIVIDUALLY AND IN HIS CAPACITY AS A LIEUTENANT WITH THE GEORGETOWN POLICE DEPARTMENT

AND

2023-SC-0265-DG

LIEUTENANT JAMES WAGONER, APPELLANT INDIVIDUALLY AND IN HIS CAPACITY AS A LIEUTENANT WITH THE GEORGETOWN POLICE DEPARTMENT

ON REVIEW FROM COURT OF APPEALS V. NO. 2022-CA-0009 SCOTT CIRCUIT COURT NO. 19-CI-00593

JAIME MORALES; CITY OF GEORGETOWN, APPELLEES KENTUCKY; OFFICER JOSEPH ENRICCO, INDIVIDUALLY AND IN HIS CAPACITY AS A DEPUTY WITH THE GEORGETOWN POLICE DEPARTMENT; AND GEORGETOWN POLICE DEPARTMENT

OPINION OF THE COURT BY JUSTICE KELLER

AFFIRMING IN PART, REVERSING IN PART, AND REMANDING Jaime Morales was employed as a Sheriff’s Deputy with the Scott County

Sheriff’s Office (“SCSO”) when he was tragically shot in the line of duty, and

paralyzed, during a September 2018 law enforcement operation to apprehend

an alleged bank robber. Morales thereafter brought a negligence suit against

multiple employees of the City of Georgetown (“City”) and the Georgetown Police

Department (“GPD”). More than six years after Morales sustained his injuries,

this Court is now tasked with determining whether the Scott Circuit Court

erred in ruling that each of the government defendants was immune from suit.

After a thorough review of the record, the applicable law, and the arguments of

the parties, we affirm the decision of the Court of Appeals in part, reverse in

part, and remand to the Scott Circuit Court for further proceedings consistent

with this Opinion.

I. FACTS AND BACKGROUND

On September 11, 2018, deputies of the United States Marshals Service

requested assistance from local law enforcement authorities in apprehending

alleged fugitive bank robber, Edward Reynolds. The U.S. Marshals Service had

tracked Reynolds to an interstate rest area off I-75 in Scott County where he

was purportedly asleep in his car.

At the time of the U.S. Marshals Service’s request for assistance, Jaime

Morales served as a member of the SCSO and GPD Joint Special Response

Team (“SRT”), a joint law enforcement group comprised of members of the

SCSO and the GPD who are specially trained in tactical operations. On

September 11, 2018, GPD Lieutenant Michael Wagoner (“Lt. Wagoner”) was the

2 SRT’s Co-Commander and the on-duty supervisor that evening. Upon receiving

the U.S. Marshals Service’s request for assistance, members of the GPD

undertook a threat matrix assessment to determine the appropriate level of law

enforcement response. The GPD’s threat matrix assessment produced a score

of fourteen, which, according to the record, did not necessitate a formal

response, or “call-out,” from the SRT. Nonetheless, Lt. Wagoner did utilize SRT

members, including members of the SCSO, in his response to the U.S.

Marshals Service’s request for assistance.

Lt. Wagoner specifically testified at deposition that there were several

SRT-trained GPD officers on-duty the night of September 11, 2018, and that he

planned “to take those officers that were SRT-trained and take the [SRT’s

armored] truck and go to the rest area and call [Reynolds] out.” Lt. Wagoner

testified that, prior to engaging with Reynolds, he drove several GPD-affiliated

SRT members to a local Cracker Barrel restaurant where they planned to meet

with multiple SCSO members of the SRT.

Lt. Wagoner testified that, at the Cracker Barrel, he gathered everyone

around the SRT armored truck and explained the plan he had formulated to

apprehend Reynolds. According to Lt. Wagoner, he planned to park the SRT’s

armored truck behind Reynolds’s car, blocking him in. The SRT members

would then exit the armored truck, line up behind the truck, and order

Reynolds to exit his car peacefully. If Reynolds refused to surrender, a trained

hostage negotiator would then negotiate with Reynolds.

3 The actual events that transpired the night of September 11, 2018,

however, did not unfold according to the purported plan. Once Lt. Wagoner had

parked the SRT armored truck behind Reynolds’s car, the SRT members did

indeed exit the truck. But rather than line up behind the truck, SCSO Deputies

Jordan Jacobs and Jaime Morales immediately approached the driver’s side of

Reynolds’s car. GPD Officer Joseph Enricco and SCSO Sergeant Devon

Brinegar thereafter followed, so that all four were positioned on the driver’s side

of Reynolds’s car, shoulder to shoulder. When the SRT members yelled for

Reynolds to exit his vehicle, Reynolds awoke, started his vehicle, and tried to

reverse but was blocked in by the SRT armored truck. Morales then broke the

driver’s side window of Reynolds’s car, and Reynolds subsequently reached for

a handgun from his center console. When the SRT members saw that Reynolds

was brandishing a gun, they fired their own weapons, killing Reynolds. This

entire encounter, from the time the SRT members exited the armored truck to

the time that gunfire had ceased, lasted approximately thirty-four seconds.

Amid this chaos, however, Morales was also shot in the spine, rendering

him paraplegic. The bullet that injured Morales is still lodged in his spine, and

therefore unable to be subjected to ballistics testing. Accordingly, no one knows

for certain who fired the shot paralyzing Morales; we do know, however, that

Reynolds did not fire any shots from his gun. Morales alleges that it was GPD

Officer Enricco, positioned to his right, who inadvertently shot him from

behind.

4 According to the circuit court record, Morales understandably enjoyed an

outpouring of support from his community after this tragic incident. After

Morales was wounded in the line of duty, members of the Georgetown and

Scott County community held fundraisers and made t-shirts to raise money for

his recovery and care.

In September 2019, nearly a year after the SRT operation to apprehend

Edward Reynolds, Morales filed a Complaint in Scott Circuit Court naming

both Officer Enricco and Lt. Wagoner as defendants in their official and

individual capacities. Morales alleged that both Officer Enricco and Lt.

Wagoner were negligent in the fulfillment of their law enforcement duties, thus

causing his injuries. Morales’s Complaint also asserted negligence and

vicarious liability claims against the City of Georgetown and the GPD. More

than two years later, in December 2021, the Scott Circuit Court entered an

order granting summary judgment to each of the government defendants on

immunity grounds. Specifically, the circuit court concluded that both Officer

Enricco and Lt. Wagoner were entitled to qualified official immunity from any

alleged torts arising from their “discretionary” actions in apprehending

Reynolds. Further, the circuit court ruled that the City and the GPD were each

immune from Morales’s claims of vicarious liability and negligence.

On appeal, the Court of Appeals affirmed the judgment of the circuit

court in part, and reversed in part, after concluding that Lt. Wagoner, the City,

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