Jena Lhotsky v. Guy Sutcliffe

CourtCourt of Appeals of Kentucky
DecidedOctober 17, 2025
Docket2024-CA-1521
StatusPublished

This text of Jena Lhotsky v. Guy Sutcliffe (Jena Lhotsky v. Guy Sutcliffe) 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
Jena Lhotsky v. Guy Sutcliffe, (Ky. Ct. App. 2025).

Opinion

RENDERED: OCTOBER 17, 2025; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-1521-MR

JENA LHOTSKY AND JENA LHOTSKY, AS GUARDIAN, CONSERVATOR, AND NEXT FRIEND FOR ALEX LHOTSKY, A DISABLED ADULT APPELLANTS

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE ANN BAILEY SMITH, JUDGE ACTION NO. 21-CI-002784

GUY SUTCLIFFE APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: CETRULO, L. JONES, AND LAMBERT, JUDGES.

CETRULO, JUDGE: This is an appeal from an Opinion and Order granting

summary judgment in favor of Guy Sutcliffe (“Sutcliffe”) following a tragic single

car accident involving Alex Lhotsky (“Lhotsky”). For reasons set forth herein, we

affirm the Jefferson Circuit Court. FACTS

On August 28, 2020, Lhotsky was a passenger in a vehicle driven by

his friend, Willard Patterson (“Patterson”). The two had been to dinner and both

had consumed alcoholic beverages. They were driving home on U.S. Highway 42

(“Highway 42”) in Prospect, Kentucky during a heavy rain. According to crash

data retrieval, Patterson was driving 34 miles per hour over the speed limit when

he lost control of his vehicle. It left the roadway, ultimately colliding with a stone

mailbox located adjacent to Highway 42. Patterson did not survive the accident.

His postmortem blood toxicology revealed a 0.067% blood alcohol concentration

in his system. Lhotsky survived, but sustained serious and permanent brain

injuries, among other injuries to his body.

In May 2021, his wife and now guardian, Jena Lhotsky, filed suit

against Patterson’s estate and against Sutcliffe, the current owner of the residence

associated with the mailbox.1 As to Sutcliffe, Lhotsky claimed negligence for

maintaining a stone mailbox that was “unyielding upon impact” and alleging that it

was non-crashworthy. Discovery proceeded but did not establish who had built the

mailbox or when it was installed. Discovery revealed that the mailbox had two

compartments for mail. Sutcliffe testified it was present when he purchased the

1 Lhotsky later amended the complaint to also name the builder of the home located at 10606 Highway 42 (where the accident occurred) and the first owner of that home. Those parties were dismissed by an earlier summary judgment, and no appeal was taken from that ruling.

-2- property in 1997 and that he used the mailbox along with his next-door neighbor,

Robert Schwartz. Mr. Schwartz was never sued or deposed. Discovery also

confirmed that the mailbox was not actually located on Sutcliffe’s land but just

beyond his property’s boundary, although the Patterson vehicle ultimately ended

up on Sutcliffe’s property.

In 2024, Sutcliffe moved for summary judgment, arguing that: 1) he

owed no duty to Lhotsky under negligence per se nor common law theories; and 2)

the mailbox was not the proximate cause of the accident. The circuit court

considered the parties’ briefs, conducted oral arguments, and granted Sutcliffe’s

motion, resulting in this appeal.

Further facts will be provided as we address the arguments on appeal.

STANDARD OF REVIEW

Appellate review of a summary judgment addresses only questions of

law, thus our review is de novo. Culp v. SI Select Basketball, 663 S.W.3d 451, 453

(Ky. App. 2023) (citing Brown v. Griffin, 505 S.W.3d 777, 781 (Ky. App. 2016)).

The standard of review upon appeal of an order granting summary judgment is

“whether the trial court correctly found that there were no genuine issues as to any

material fact and that the moving party was entitled to judgment as a matter of

law.” Scifres v. Kraft, 916 S.W.2d 779, 781 (Ky. App. 1996) (citing Kentucky

Rule of Civil Procedure (“CR”) 56.03). The circuit court “must examine the

-3- evidence, not to decide any issue of fact, but to discover if a real issue exists.”

Steelvest, Inc. v. Scansteel Serv. Ctr., Inc., 807 S.W.2d 476, 480 (Ky. 1991).

ANALYSIS

Lhotsky argues that Sutcliffe owed a duty, under both statutory and

common law. We begin the discussion with the statutory or negligence per se

claims, which are premised upon Kentucky Revised Statutes (“KRS”) 177.106 and

179.240.

a) Negligence Per Se

A negligence per se claim “is merely a negligence claim with a

statutory standard of care substituted for the common law standard of care.” Lewis

v. B&R Corp., 56 S.W.3d 432, 438 (Ky. App. 2001) (citation omitted); see also

Young v. Carran, 289 S.W.3d 586, 588-89 (Ky. App. 2008) (citation omitted).

However, the party claiming negligence per se must be a member of the class of

persons intended to be protected by the statute, and the injury must be an event

that the statute was designed to prevent. Alderman v. Bradley, 957 S.W.2d 264,

267 (Ky. App. 1997). Only when both requirements are affirmatively

demonstrated is negligence per se established with the applicable regulation or

statute defining the relevant standard of care. Id.

Not only must the statute “have been specifically intended to prevent

the type of occurrence that took place, [but also] the violation must have been a

-4- substantial factor in causing the result.” Hargis v. Baize, 168 S.W.3d 36, 46 (Ky.

2005) (citing Isaacs v. Smith, 5 S.W.3d 500, 502 (Ky. 1999)).

KRS 177.106

An “encroachment” is defined in KRS 177.106(1) as “any

improvement of land . . . or any change from the original contour of land, that: (a)

[i]s constructed, created, or implemented under, on, or over the right-of-way of a

state-maintained road; and (b) [m]ay hinder or prevent use or maintenance of a

road or right-of-way.” Subsection (2) of KRS 177.106 provides that “[a] person

shall not cause . . . or allow an encroachment to remain under, on, or over any part

of the right-of-way of a state-maintained road unless that person has first obtained

an encroachment permit from the Department of Highways.”

The evidence was undisputed that the mailbox here was “on the edge

of a paved pull-off with the near side of the mailbox located about 11 feet from the

edge line” of Highway 42.2 There was also evidence demonstrating ample room

on the pull-off to allow a mail truck to access the mailbox and have clearance from

the roadway. The circuit court agreed that the mailbox was situated on what might

be considered the right-of-way of Highway 42, although it was well off the

2 This measurement was provided by Lhotsky’s expert accident reconstructionist, Kenneth Agent.

-5- traveled portion of the road.3 However, the circuit court did not find that the

mailbox hindered or prevented use or maintenance of the road or right-of-way.

Stated another way, the court found it was not an encroachment as defined by KRS

177.106(1). The statute clearly requires that for an “improvement” or “change” to

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