Jaime Morales v. City of Georgetown, Kentucky

CourtCourt of Appeals of Kentucky
DecidedMay 11, 2023
Docket2022 CA 000009
StatusUnknown

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 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
Jaime Morales v. City of Georgetown, Kentucky, (Ky. Ct. App. 2023).

Opinion

RENDERED: MAY 12, 2023; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2022-CA-0009-MR

JAIME MORALES APPELLANT

APPEAL FROM SCOTT CIRCUIT COURT v. HONORABLE BRIAN K. PRIVETT, JUDGE ACTION NO. 19-CI-00593

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

OPINION AFFIRMING IN PART, REVERSING IN PART, AND REMANDING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; ACREE AND MCNEILL, JUDGES. ACREE, JUDGE: Appellant, Jamie Morales, appeals the Scott Circuit Court’s

December 28, 2021 Opinion and Order granting the Appellees’ motions for

summary judgment. The circuit court determined various forms of immunity

prevented Appellant’s pursuit of any of his claims against any of the Appellees.

Having reviewed the record, we affirm in part, reverse in part, and remand.

BACKGROUND

Appellant is a former special deputy of the Scott County Sheriff’s

Office (SCSO). On September 11, 2018, he and other law enforcement officers

participated in an operation to apprehend Edward Reynolds. During the mission,

Appellant was paralyzed, struck by a bullet fired by someone other than Reynolds.

Reynolds was suspected of robbing banks in Florida and North

Carolina and was being surveilled by United States Marshals. Marshal Roger

Daniel called 911 to request local law enforcement assistance in apprehending

Reynolds. He told the dispatcher Reynolds’ vehicle was parked at a Scott County

interstate rest area, and that Reynolds was asleep inside. The dispatcher routed the

call to Lieutenant Gary Crump of the Georgetown Police Department (GPD).

Although employed by the GPD, Crump decided to refer the matter to

leadership of the GPD’s Special Response Team (SRT), a specialized law

enforcement unit which includes members from both the GPD and SCSO.

-2- According to the General Order governing its operations,1 the SRT is responsible

for “respond[ing] to critical or unusual incidents if needed[,]” including high-risk

arrests and execution of search warrants, hostage situations, and active shooters.

The General Order states that SRT leadership is comprised of a Commander2 and

two Team Leaders, selected by the GPD Chief of Police; SRT leadership is

“responsible for unit training” and “coordination of assigned team members[.]”

The Commander, or Commanders, and Team Leaders are “in charge of the tactical

planning and execution of the plan at any and all call-outs.”3 Only at the direction

of the Chief of Police or his designee may SRT leadership deviate from the

General Order.

The General Order outlines SRT member selection and training

requirements. SCSO and GPD employees may apply to join the SRT and, should

there be an opening on the team, must undergo physical agility and firearms

1 The General Order to which the parties refer throughout the arguments is a written document denominated “City of Georgetown, Division of Police, General Order No. 47.” It shows the last revision date as April 23, 2015. However, none of the parties explains the origin of the General Order. For purposes of our analysis, we have inferred that it is either a product of the Georgetown City Council’s legislative function as an ordinance or was promulgated by the Georgetown Police Department pursuant to an authorized delegation to that department of the city council’s rulemaking authority. 2 As will be discussed infra, the SRT has two Commanders. 3 A “call-out” means an incident for which the SRT is designed to respond, and to which it does respond.

-3- proficiency testing, as well as sit for an interview and administrative review. New

members must complete a basic Special Weapons Attack Team (SWAT) class.

Under “Team member commitment and standards” the General Order

provides ongoing training requirements for SRT members. These include physical

fitness tests, bi-annual handgun and rifle qualification, and monthly training.

Members must participate in all training, unless their absence is excused: “[t]eam

members must have 100% participation in all monthly training unless absence is

approved by the Team Commander, or Team Leaders.” (Emphasis original.) If a

team member has three unexcused absences within a six-month period, he or she is

to be removed from the team.

The General Order also contains a section entitled “Equipment.” It

states that SRT members are to be issued tactical clothing and personal use

equipment. While on duty, the member is required to keep the equipment with him

and to “always carry them.” The team member is required to keep his equipment

at home and accessible when off duty.

At the time of the incident that resulted in Appellant’s injuries, the

SRT included four SCSO employees: Sergeant Devon Brinegar, Deputy Michael

Jacobs, Lieutenant Joseph Hudnall, and Appellant. The team also included four

GPD employees: Sergeant Josh Nash, Appellee Lieutenant James Wagoner,

Lieutenant Gary Crump, Appellee Officer Joseph Enricco, and Sergeant Nicholas

-4- Lodal. Lieutenant Hudnall and Lieutenant Wagoner were the SRT’s joint-

commanders. Lieutenant Crump is also a trained hostage negotiator, and Sergeant

Lodal is an emergency medical technician (EMT). Wagoner was the SRT

commander on duty when Crump referred Marshal Daniel’s request for local law

enforcement backup; Hudnall was off duty at the time.

Lodal and Crump completed a risk matrix, which produced a score of

“14” – a score indicating the risk involved in law enforcement’s response was not

so high that an official SRT “call-out” was required. However, and as the circuit

court noted, whether the operation was a formal SRT call-out remains a disputed

issue.

Once the officers were assembled, Wagoner, Enricco, Crump, and

Lodal boarded the ballistically-rated armored SRT vehicle and drove to a rally

point: a Cracker Barrel restaurant near Reynolds’ vehicle. Other SRT members –

Appellant, Brinegar, and Jacobs – also met at the rally point. In addition to then-

current SRT members, GPD Officer Chris Wallace and a former SRT member,

SCSO Sergeant Jeremy Nettles, participated. Appellant had replaced Nettles

following the latter’s departure from the SRT.

Following a briefing, Appellant, Wagoner, Lodal, Crump, Enricco,

Jacobs, and Brinegar loaded into the SRT vehicle. Appellant observed the GPD

members of the SRT were wearing protective tactical vests; these vests contain

-5- metal plates designed to protect the wearer from gunfire. Appellant asked Brinegar

whether he should wear his, and Brinegar told him that he did not believe the vests

would be necessary. At some point, Appellant asked Nettles the same question,

and Nettles also stated his belief that the vests were unnecessary. Both Nettles and

Brinegar were Appellant’s superiors at SCSO.

Wagoner drove the SRT vehicle to the rest area and parked behind

Reynolds’ vehicle, blocking him from escaping. All SRT members exited the

vehicle. Jacobs immediately approached the driver’s side of Reynolds’ vehicle,

followed by Appellant, Enricco, and Brinegar; the four of them stood close to one

another against Reynolds’ vehicle. Nettles also approached and positioned himself

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