James Jones v. Energy and Environment Cabinet

CourtCourt of Appeals of Kentucky
DecidedMarch 14, 2024
Docket2023 CA 000605
StatusUnknown

This text of James Jones v. Energy and Environment Cabinet (James Jones v. Energy and Environment Cabinet) 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 Jones v. Energy and Environment Cabinet, (Ky. Ct. App. 2024).

Opinion

RENDERED: MARCH 15, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

No. 2023-CA-0605-MR

JAMES JONES APPELLANT

APPEAL FROM FRANKLIN CIRCUIT COURT v. HONORABLE PHILLIP J. SHEPHERD, JUDGE ACTION NO. 22-CI-00208

ENERGY AND ENVIRONMENT CABINET; NICK DARNELL; MICHAEL DARNELL; AND DARNELL PUMPKINS APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; EASTON AND GOODWINE, JUDGES.

EASTON, JUDGE: This is an administrative appeal of the revocation of Appellant

James Jones’ (“Jones”) construction permit for a Concentrated Animal Feeding Operation (in this case, “Hog Barns”) by the Energy and Environment Cabinet,

Division of Water (“Cabinet”). After review of the record, and for the reasons

which follow, we affirm the Franklin Circuit Court.

FACTUAL AND PROCEDURAL HISTORY

In June 2019, Jones filed an application for a permit to construct a

wean-to-finish deep pit hog facility1 consisting of two barns, designed for 7,800

hogs, in Graves County, Kentucky. The Hog Barns would be serviced by animal

waste containment pits, which must be approved by the Cabinet as part of a waste

handling system. In October 2019, the Cabinet issued a construction permit to

Jones for his Hog Barns with waste containment pits.

The permit application required identification of “significant features”

within one mile of the boundaries of the property where the Hog Barns would be

built. The application process also required siting criteria for certain “setback

features” which must be located at least 1,500 feet away from the Hog Barns

operation. The wording of “setback features” includes a “dwelling not owned by

applicant, church, school, schoolyard, business, park or other structure to which the

general public has access.”

1 In this model, pigs are brought in at weaning and are housed at the same facility until they have reached the desired weight. -2- In February 2020, Jones received a letter from the Cabinet that his

construction permit was being revoked. The letter stated two reasons for the

revocation. First, a neighboring farm with a seasonal business, Darnell Pumpkins,

has public access and, if the entire acreage of the Darnell farm is considered, then

Darnell Pumpkins is a business located within the setback of the siting criteria for

the permit. Second, Jones had failed to include a Nutrient Management Plan

(“NMP”) with his application. The letter stated the revocation of the permit is a

final decision, but it would not preclude the submission of an application for the

same site or facility. The letter also gave instructions on how to request a hearing

to challenge the revocation.

Jones requested such a hearing. In March 2020, he filed a complaint

with the Cabinet’s Office of Administrative Hearings, challenging the revocation

of the construction permit. Virginia Baker Gorley was assigned as the Hearing

Officer. In July 2020, the Hearing Officer allowed Nick Darnell, Michael Darnell,

and Darnell Pumpkins (collectively, “Darnells”) to intervene. Michael Darnell is

the owner of Darnell Pumpkins, and Nick Darnell operates the pumpkin patch part

of the family business. A hearing was held in April 2021.

The Hearing Officer issued her report in August 2021, recommending

the revocation be upheld on the basis that Jones failed to identify a “significant

feature,” the Darnell Pumpkins patch, which existed within one mile of the

-3- property boundary of the facility proposed in his application. The Hearing Officer

recommended that the basis of the revocation should not be because Jones did not

submit an NMP with his application, as the Hearing Officer believed the law did

not require an NMP to be submitted for a “construction” application. The Hearing

Officer further stated the Cabinet acted in accordance with the requisite statutes in

revoking Jones’ permit without a prior hearing. Finally, the Hearing Officer

determined that the issues regarding the setback criteria were moot because the

revocation should be upheld for other reasons.

The Cabinet’s Secretary, Rebecca Goodman (“Secretary”), issued her

Final Order in February 2022. The Secretary partially adopted and partially

rejected the Hearing Officer’s conclusions. The Secretary determined the permit

revocation should be upheld both because Jones failed to identify a significant

feature in his application and because he did not include an NMP with the

application. The Secretary agreed with the Hearing Officer that the setback criteria

finding was moot and that the Cabinet complied with the law in revoking the

permit without a hearing.

Jones then filed an Appeal and Petition for Review in the Franklin

Circuit Court in March 2022. All parties briefed their positions, and oral

arguments were held in November 2022. The circuit court issued its Opinion and

Order on February 24, 2023. From this Order Jones appeals.

-4- The circuit court’s Order affirmed the Secretary’s Final Order to

revoke Jones’ construction permit. The circuit court concluded Jones’ permit was

issued prematurely, and the Cabinet acted properly in revoking the permit. The

circuit court also concluded that the post-revocation hearing afforded due process

to Jones. According to the circuit court, Jones’ application was incomplete, as it

did not have the required NMP attached. The circuit court also found Jones’

application deficient as it did not disclose Darnell Pumpkins as a “significant land

feature,” which then should have been identified as being within one mile of the

property boundaries of the Hog Barns operation. The circuit court’s Order did not

address whether the setback criteria issue was moot.

In the hearings below, Jones challenged the propriety of the Cabinet

revoking the permit prior to an administrative hearing, but he appears to have

abandoned that argument, as it was not addressed in his brief. Failure to address an

issue in an appellant brief is deemed to waive that argument. Grange Mut. Ins. Co.

v. Trude, 151 S.W.3d 803, 815 (Ky. 2004).

There are essentially three questions. The first two questions were

addressed by the circuit court as a basis for its Order. First, was an NMP required

for a construction permit? Second, was Darnell Pumpkins a “significant feature”

that must be disclosed with the permit application? Finally, was the 1,500 feet set-

-5- back determination regarding the pumpkin patch rendered moot by the Secretary’s

holdings, or must we decide that question?

STANDARD OF REVIEW

“Generally, our review of the decision of an administrative agency is

highly deferential, and we reverse only if the decision was arbitrary, unsupported

by substantial evidence, or otherwise erroneous as a matter of law. Substantial

evidence means evidence of substance and relevant consequence having the fitness

to induce conviction in the minds of reasonable men. However, we review

questions of law de novo, including the application and interpretation of statutes.”

River City Fraternal Ord. of Police Lodge No. 614, Inc. v. Louisville/Jefferson

Cnty. Metro Gov’t, 664 S.W.3d 486, 493 (Ky. 2022), reh’g denied (Feb. 16, 2023)

(internal quotation marks and citations omitted). In determining arbitrariness, “the

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Related

Grange Mutual Insurance Co. v. Trude
151 S.W.3d 803 (Kentucky Supreme Court, 2004)
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Commonwealth, Cabinet for Health Services v. Family Home Health Care, Inc.
98 S.W.3d 524 (Court of Appeals of Kentucky, 2003)
Louisville Gas & Electric Co. v. Kentucky Waterways Alliance
517 S.W.3d 479 (Kentucky Supreme Court, 2017)

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James Jones v. Energy and Environment Cabinet, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-jones-v-energy-and-environment-cabinet-kyctapp-2024.