James Harrison v. Catherine Weicht

CourtCourt of Appeals of Kentucky
DecidedJanuary 7, 2021
Docket2019 CA 001664
StatusUnknown

This text of James Harrison v. Catherine Weicht (James Harrison v. Catherine Weicht) 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
James Harrison v. Catherine Weicht, (Ky. Ct. App. 2021).

Opinion

RENDERED: JANUARY 8, 2021; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2019-CA-1664-MR

JAMES HARRISON APPELLANT

APPEAL FROM FRANKLIN CIRCUIT COURT v. HONORABLE PHILIP J. SHEPHERD, JUDGE ACTION NO. 19-CI-00796

CATHERINE WEICHT; DeEDRA HART; SARAH ELLEN EADS ADKINS; AMY BARKER; LILA EDMONSON; JOHN and JANE DOE(S) APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, MAZE, AND MCNEILL, JUDGES.

MAZE, JUDGE: James Harrison appeals the dismissal of his petition for

declaration of rights as time-barred. Having reviewed appellant’s arguments for

reversal in light of the record, we affirm. Appellant filed an open records request with the Kentucky State

Penitentiary (KSP) seeking to inspect intake medical records revealing the names

of the persons “who conducted the intake records.” The custodian of the records,

appellee Lila Edmonson, denied the request due to appellant’s failure to use the

specific form for requesting medical records, stating:

When submitting a medical record request it is a requirement that the Request to View/Obtain Health Information form be utilized, signed and dated by a CTO/UA and INMATE. Since the form was not utilized, signed and dated by a CTO[1]/UA your request has been denied.

Please resubmit your request on a new Request to View/Obtain Health Information form with the proper signatures.

Rather than resubmit his request on the proper form, appellant appealed

Edmonson’s decision to the Office of the Attorney General as provided for in

KRS2 61.880(2).

Thereafter, appellee Sarah Adkins, acting on behalf of the Attorney

General, issued a written decision concluding that KSP did not violate the Open

Records Act “in denying Appellant’s requests based upon his failure to obtain the

correct form from his caseworker, and his failure to use that form to request

1 The record discloses that a “CTO” is also known as a caseworker. 2 Kentucky Revised Statutes.

-2- medical records.” Appellant then filed in Franklin Circuit Court the complaint at

issue in this appeal.

In his complaint, appellant asserted that Adkins, along with officials

of KSP and the Department of Corrections, violated the intent of the Open Records

Act, as well as KRS 13A.120, KRS 13A.130, KRS 522.020, and other unspecified

laws. Appellee Adkins moved to dismiss the complaint on the basis of sovereign

and qualified immunity. Appellees DeEdra Hart and Lila Edmonson subsequently

filed separate motions to dismiss alleging that the complaint was time-barred and

that they were not proper parties to an open records appeal. The Franklin Circuit

Court thereafter entered an order dismissing the complaint as time-barred under

KRS 61.880(5)(a) and stating that the decision of the Attorney General now has

the force of law. The order also stated that Warden DeEdra Hart was neither

properly served nor a proper party to the appeal. This appeal follows the denial of

appellant’s motion to reconsider that order.

We commence our discussion with a review of the dictates of KRS

61.880(5)(a) and (b):

(a) A party shall have thirty (30) days from the day that the Attorney General renders his decision to appeal the decision. An appeal within the thirty (30) day time limit shall be treated as if it were an action brought under KRS 61.882.

(b) If an appeal is not filed within the thirty (30) day time limit, the Attorney General’s decision shall have

-3- the force and effect of law and shall be enforceable in the Circuit Court of the county where the public agency has its principal place of business or the Circuit Court of the county where the public record is maintained.

(Emphasis added.) In City of Fort Thomas v. Cincinnati Enquirer, the Supreme

Court of Kentucky had occasion to address the proper interpretation of that statute:

To begin, it is helpful to observe that when an agency denies an ORA request, the requester has two ways to challenge the denial. He or she may, under KRS 61.882, file an original action in the Circuit Court seeking injunctive and/or other appropriate relief. Alternatively, under KRS 61.880, he or she may, as was done in this case, ask the Attorney General to review the matter. Once the Attorney General renders a decision either party then has thirty days within which to bring an action pursuant to KRS 61.882(3) in the Circuit Court. Although the statutes refer to this second type of Circuit Court proceeding as an “appeal” of the Attorney General’s decision, it is an “appeal” only in the sense that if a Circuit Court action is not filed within the thirty-day limitations period, the Attorney General’s decision becomes binding on the parties and enforceable in court.

406 S.W.3d 842, 848 (Ky. 2013) (emphasis added). Thus, although timeliness was

not directly in question in that case, the Supreme Court nevertheless acknowledged

that if a circuit court action is not filed within the thirty-day limitations period, the

decision of the Attorney General “becomes binding on the parties and enforceable

in court.” Id.

This brings us to the arguments appellant presses in this appeal.

Although he argues that the circuit court erred in dismissing his complaint,

-4- appellant does not address the timeliness of his circuit court action. Rather, he

attempts to predicate error in the dismissal of the complaint on issues he advanced

in a document filed two days after entry of the order dismissing the complaint as

untimely. That document, as typed, was styled “REPLY TO DEFENDANTS

ADKINS, HART AND EDMONSON MOTIONS TO DISMISS.” Above the

typed style were the handwritten words “Amendment to Complaint and. . . .”

Appended to the reply was a “Health Services Staff Contact Form” dated August

22, 2019, requesting “one free copy of my medical records” and stating:

WellPath is a healthcare provider corporation contract entity and KRS 422.317 mandates providing one free copy to the patient upon request which I hereby [in] this instrument being requested.[sic]

The form also contained a section for a “Staff Response” which had been

completed as follows:

Mr. Harrison – I am attaching to this correspondence the proper form that must be [filled] out for any and all medical records requests for the Department of Corrections. Please fill the attached request to view/obtain Health Information out and return it to medical. Thank you.

The appropriate Department of Corrections’ form was in fact attached to the staff

response.

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Related

City of Fort Thomas v. Cincinnati Enquirer
406 S.W.3d 842 (Kentucky Supreme Court, 2013)

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James Harrison v. Catherine Weicht, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-harrison-v-catherine-weicht-kyctapp-2021.