James Lang v. Andrew Graham Beshear, Governor

CourtCourt of Appeals of Kentucky
DecidedJune 1, 2023
Docket2022 CA 001056
StatusUnknown

This text of James Lang v. Andrew Graham Beshear, Governor (James Lang v. Andrew Graham Beshear, Governor) 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 Lang v. Andrew Graham Beshear, Governor, (Ky. Ct. App. 2023).

Opinion

RENDERED: JUNE 2, 2023; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2022-CA-1056-MR

JAMES LANG APPELLANT

APPEAL FROM OLDHAM CIRCUIT COURT v. HONORABLE JERRY CROSBY, II, JUDGE ACTION NO. 21-CI-00595

ANDREW GRAHAM BESHEAR, GOVERNOR; CHARLES WARD, INSPECTOR, OLDHAM COUNTY HEALTH DEPARTMENT; COMMONWEALTH OF KENTUCKY; ERIC FREIDLANDER, SECRETARY OF THE CABINET FOR HEALTH AND FAMILY SERVICES; JOHN/JANE DOE, BRANCH MANAGER, ENVIRONMENTAL MANAGEMENT BRANCH; JOHN/JANE DOE, DIRECTOR OF THE DIVISION OF PUBLIC HEALTH AND SAFETY; JOHN/JANE DOES, MEMBERS OF THE OLDHAM COUNTY BOARD OF HEALTH; STEVEN STACK, COMMISSIONER OF THE DEPARTMENT OF PUBLIC HEALTH; AND TERESA GAMSKY, DIRECTOR, OLDHAM COUNTY HEALTH DEPARTMENT APPELLEES OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, CALDWELL, AND CETRULO, JUDGES.

CETRULO, JUDGE: This is an appeal by an inmate at the Roederer Correctional

Complex (“RCC”) from an Order dismissing numerous claims against various

individuals employed by the Commonwealth of Kentucky. While the complaints

are extensive, in a nutshell, the Appellant, James Lang (“Lang”) alleges that the

conditions at the prison did not meet legal requirements and that these conditions

resulted in him contracting COVID-19; that all named defendants are negligent per

se, as well as criminally liable for “official misconduct”; and that he is entitled to

monetary damages. For reasons set forth below, we affirm the Order of the

Oldham Circuit Court.

While it is difficult to discern exactly what Mr. Lang is arguing in his

brief, his complaint was focused on a claim of overcrowding at RCC, which he

alleged resulted in him contracting COVID-19. He alleged in the complaint that

authorities charged with inspecting confinement facilities in Kentucky had failed in

their duty to ensure compliance with various statutes and regulations. He further

alleged that certain defendants falsified official documents and/or failed to inspect

the conditions of his confinement and did not accurately compute the square

footage within the prison to determine the number of prisoners that could be

-2- legally housed therein. Finally, Lang further alleged that he had exhausted all

administrative remedies available to him, a statement which all defendants below

have contested. All defendants below moved for dismissal on the pleadings, on

several grounds, many of which were applicable.1 However, the Oldham Circuit

Court clearly considered all of the pleadings and briefs, and outlined the statutes

relied upon by Lang, before writing a detailed Opinion and Order dismissing all

claims on the basis that Lang had failed to exhaust administrative remedies.

Our review of an Order dismissing a claim under Kentucky Rule of

Civil Procedure (“CR”) 12.02 is de novo. “Since a motion to dismiss for failure to

state a claim upon which relief may be granted is a pure question of law, a

reviewing court owes no deference to a trial court’s determination . . . .” Fox v.

Grayson, 317 S.W.3d 1, 7 (Ky. 2010). The problem for Lang is that Kentucky law

is clear that inmates can only bring lawsuits regarding the “conditions of their

confinement” once they have exhausted their administrative remedies. Kentucky

Revised Statute (“KRS”) 454.415(1). In reviewing the complaint itself, it is

equally clear that this suit was over a healthcare concern and, as such, a “condition

of his confinement.” We thus incorporate a section of the trial court’s well-

1 Many of the claims herein would also be barred as a matter of law by sovereign or qualified immunity. See Yanero v. Davis, 65 S.W.3d 510 (Ky. 2001). However, the trial court did not proceed to those defenses, finding that Lang had failed to exhaust administrative remedies depriving it of jurisdiction to hear the claims. Thus, we do not address those defenses herein either.

-3- reasoned opinion for a discussion of this statute and the law on exhaustion of

remedies:

The Kentucky Department of Corrections Policies and Procedures 14.6 governs grievances within the prison system in Kentucky. Specifically, 14.6(II)(B) outlines what is considered to be a grievable issue within DOC. Further, KRS 454.415(1)(d) supra specifically states that an inmate may not bring a civil action on a conditions of confinement issue without first exhausting his administrative remedies. See Houston v. Fletcher, Ky.App., 193 S.W.3d 276, 278 (2006) (finding no entitlement to appellate review of claims where inmate did not establish exhaustion of administrative remedies under the same language in a previous version of KRS 454.415). See also Hensley v. Commonwealth, Ky.App., 355 S.W.3d 473, 475 (2011) (“KRS 454.415 sets forth proper procedure for inmates who raise sentence calculation questions. Subsections (1) and (2) state that all administrative remedies must be exhausted. Nothing in Hensley’s brief or the record indicates that he has filed an administrative complaint or appeal. KRS 454.415 specifically forbids inmates from bringing civil actions before exhausting the administrative remedies.”) . . . .

There is no denying that this case involves a conditions of confinement issue. Plaintiff is asserting that due to the prison overcrowding and the state’s failure to comply with the requirements of adequate spacing, he was infected with the COVID virus. He may couch it in other terms but at its core, this is the issue. Plaintiff contends he exhausted his administrative remedies by writing to various individuals in the state addressing this issue. Plaintiff asserts he couldn’t file a grievance as there was no mechanism in place to challenge the inspector’s report. However, KRS 454.415(2) notes that an inmate must still exhaust his administrative remedies even if the remedy the inmate seeks is unavailable.

-4- During the course of the COVID pandemic, many inmates filed CR 60.02 motions requesting relief from their sentence. Many of these inmates were at higher risk than the average individual due to underlying health concerns. However, these requests were denied as the Courts agreed this was not an issue that could be addressed through an inmate’s underlying criminal case. Instead, the Courts noted this was a condition of confinement issue that should be addressed through a civil proceeding. See Merriweather v. Commonwealth, No. 2020-CA-1182- MR, 2021 WL 5977912, at *2 (Ky.App. Dec. 17, 2021) (“When conditions of confinement are at issue, like they are here, the proper venue is for the prisoner to pursue his claims through the grievance system. See KRS 454.415.

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Related

Yanero v. Davis
65 S.W.3d 510 (Kentucky Supreme Court, 2001)
Houston v. Fletcher
193 S.W.3d 276 (Court of Appeals of Kentucky, 2006)
Fox v. Grayson
317 S.W.3d 1 (Kentucky Supreme Court, 2010)
Harrison's Sanitarium, Inc. v. Commonwealth, Department of Health
417 S.W.2d 137 (Court of Appeals of Kentucky (pre-1976), 1967)
Hensley v. Commonwealth
355 S.W.3d 473 (Court of Appeals of Kentucky, 2011)
Martin v. Board of Council of City of Danville
120 S.W.2d 761 (Court of Appeals of Kentucky (pre-1976), 1938)
Goodwin v. City of Louisville
215 S.W.2d 557 (Court of Appeals of Kentucky (pre-1976), 1948)
Kentucky State Police v. Terry Scott
529 S.W.3d 711 (Kentucky Supreme Court, 2017)
Thrasher v. Commonwealth
386 S.W.3d 132 (Court of Appeals of Kentucky, 2012)

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