Joanna Smith v. City of Newport

CourtCourt of Appeals of Kentucky
DecidedDecember 6, 2024
Docket2024-CA-0013
StatusUnpublished

This text of Joanna Smith v. City of Newport (Joanna Smith v. City of Newport) 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
Joanna Smith v. City of Newport, (Ky. Ct. App. 2024).

Opinion

RENDERED: DECEMBER 6, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2024-CA-0013-MR

JOANNA SMITH APPELLANT

APPEAL FROM CAMPBELL CIRCUIT COURT v. HONORABLE JULIE REINHARDT WARD, JUDGE ACTION NO. 22-CI-00626

CITY OF NEWPORT AND RAY EBERT APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: COMBS, A. JONES, AND KAREM, JUDGES.

JONES, A., JUDGE: On September 7, 2021, Joanna Smith tripped, fell, and

sustained consequent injuries while walking along the roadway, and a short

distance from the adjacent sidewalk, of James Alley in Newport, Kentucky. She

later filed suit in Campbell Circuit Court against the City of Newport and against

Ray Ebert, who is the Director of the City of Newport Public Works Division (which is responsible for road and sidewalk maintenance). She alleged a defective

condition of the roadway had caused her fall; and that because Newport and Ebert

knew or should have known about the condition beforehand and had failed to

remedy or warn her about it, Newport and Ebert were either negligent or negligent

per se and thus liable for her injuries.

Following a period of discovery, Newport and Ebert moved for

summary judgment, arguing they owed no duty to Smith actionable in negligence

because Smith was a trespasser where she fell. Ebert also argued Smith’s claims

against him were otherwise barred by qualified immunity stemming from the

Claims Against Local Governments Act (CALGA), Kentucky Revised Statutes

(KRS) 65.2001 et seq. The circuit court ultimately granted their motion. This

appeal followed. Upon review, we affirm. Additional facts relevant to our

disposition will be set forth in our analysis.

STANDARD OF REVIEW

Summary judgment should be cautiously applied and not used as a

substitute for trial. Steelvest, Inc. v. Scansteel Serv. Ctr., Inc., 807 S.W.2d 476

(Ky. 1991). It shall be rendered only where “the pleadings, depositions, answers to

interrogatories, stipulations, and admissions on file, together with the affidavits, if

any, show that there is no genuine issue as to any material fact and that the moving

party is entitled to a judgment as a matter of law.” Kentucky Rule of Civil

-2- Procedure (CR) 56.03. In considering a motion for summary judgment, a court is

required to construe the record “in a light most favorable to the party opposing the

motion . . . and all doubts are to be resolved in his favor.” Steelvest, 807 S.W.2d at

480.

On appeal, we must consider whether the trial court correctly determined that

Smith could not have presented evidence at trial warranting a judgment in her

favor. Because summary judgment involves only questions of law and not the

resolution of disputed material facts, we need not defer to the trial court’s decision.

Goldsmith v. Allied Bldg. Components. Inc., 833 S.W.2d 378 (Ky. 1992). Our

review is de novo. Id.

ANALYSIS

1. The appellees owed no actionable duty to Smith under the evidence presented.

Smith’s claims of premises liability negligence required her to

demonstrate the appellees owed her a duty of care, that the duty was breached, and

that consequent injury followed. See Shelton v. Kentucky Easter Seals Soc’y, Inc.,

413 S.W.3d 901, 906 (Ky. 2013). Because it is dispositive of this appeal, we begin

with the circuit court’s conclusion that the appellees owed no actionable duty to

Smith because Smith was a trespasser where she fell. In Shelton, the Supreme

Court of Kentucky set out the following guidance on how a court is to determine

whether a duty exists in premises liability negligence cases:

-3- The determination of whether a duty exists is a legal question for the court. In determining whether a duty exists, the court makes a policy decision. This policy decision is often not a “sophisticated weighing of probabilities” but “a conclusion of whether a plaintiff’s interests are entitled to legal protection against the defendant’s conduct.”

...

Kentucky law remains steadfast in its adherence to the traditional notion that duty is associated with the status of the injured party as an invitee, licensee, or trespasser.

Id. at 908-09 (internal quotation marks, citations, and footnotes omitted).

As a matter of public policy, “[t]he owner of real estate shall not be

liable to any trespasser for injuries sustained by the trespasser on the real estate of

the owner, except for injuries which are intentionally inflicted by the owner or

someone acting for the owner.” KRS 381.232; see also Giuliani v. Guiler, 951

S.W.2d 318, 321 (Ky. 1997) (“It is beyond challenge that public policy is

determined by the constitution and the legislature through the enactment of

statutes.”). A “trespasser” is “any person who enters or goes upon the real estate of

another without any right, lawful authority or invitation, either expressed or

implied[.]” KRS 381.231(1).

By walking along the roadway of James Alley, Smith went “upon the

real estate of another[.]” Id. Individual members of the public do not hold any kind

of ownership interest in public ways; rather, “[t]he authorities of a municipal

-4- corporation hold the public ways of the city in trust for the use of the public[.]”

Labry v. Gilmour, 121 Ky. 367, 89 S.W. 231, 232 (1905). But, Smith argues she

was not a trespasser per KRS 381.231(1) because she had a “right, lawful authority

or invitation” to be where she injured herself. In support, she maintains that her

status as a member of the public entitled her to use the roadway of James Alley,

which has at all relevant times been a dedicated public way.1 Building from that

premise, Smith reasons she was entitled to legal protection against the appellees’

allegedly negligent conduct, i.e., their alleged failure to make James Alley safe for

pedestrian travel. She therefore faults Newport and Ebert for failing to ensure the

James Alley roadway conformed to Newport Code of Ordinances § 93.25, and

ASTM2/ANSI3 consensus safety standard F-1637-95 – two standards that explicitly

apply to walkway surfaces for pedestrians. She also bases her negligence claims

upon KRS 411.110, KRS 178.020, and KRS 411.182(2).

However, relative to any negligence claim, the plaintiff is required to

demonstrate he or she was within the class of persons protected by the operative

1 In her brief, Smith appears to make much of the fact that she was injured in James Alley, and that alleys are often different from streets. However, there is no legal difference between a public street and a public alley.

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Steelvest, Inc. v. Scansteel Service Center, Inc.
807 S.W.2d 476 (Kentucky Supreme Court, 1991)
Miller v. Commonwealth
283 S.W.3d 690 (Kentucky Supreme Court, 2009)
Hargis v. Baize
168 S.W.3d 36 (Kentucky Supreme Court, 2005)
COM., TRANSP. CABINET, DEPT. HWYS v. Sexton
256 S.W.3d 29 (Kentucky Supreme Court, 2008)
Goldsmith v. Allied Building Components, Inc.
833 S.W.2d 378 (Kentucky Supreme Court, 1992)
Giuliani v. Guiler
951 S.W.2d 318 (Kentucky Supreme Court, 1997)
Hopkins v. Ratliff
957 S.W.2d 300 (Court of Appeals of Kentucky, 1997)
Fiechter v. City of Corbin
71 S.W.2d 423 (Court of Appeals of Kentucky (pre-1976), 1934)
Shelton v. Kentucky Easter Seals Society, Inc.
413 S.W.3d 901 (Kentucky Supreme Court, 2013)
Kirby v. Lexington Theological Seminary
426 S.W.3d 597 (Kentucky Supreme Court, 2014)
Walker v. Commonwealth
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Labry v. Gilmour
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Joanna Smith v. City of Newport, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joanna-smith-v-city-of-newport-kyctapp-2024.