Joi Denise Roby v. Churchill Downs, Inc.

CourtKentucky Supreme Court
DecidedJune 13, 2024
Docket2022-SC-0523
StatusPublished

This text of Joi Denise Roby v. Churchill Downs, Inc. (Joi Denise Roby v. Churchill Downs, Inc.) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joi Denise Roby v. Churchill Downs, Inc., (Ky. 2024).

Opinion

RENDERED: JUNE 13, 2024 TO BE PUBLISHED

Supreme Court of Kentucky 2022-SC-0508-DG

BRADLEY RACING STABLES, LLC; APPELLANTS AND WILLIAM BUFF BRADLEY

ON REVIEW FROM COURT OF APPEALS V. NO. 2021-CA-0766 JEFFERSON CIRCUIT COURT NO. 19-CI-001372

JOI DENISE ROBY; BLUE CROSS APPELLEES BLUE SHIELD OF TEXAS; CHURCHILL DOWNS, INC.; AND KYLE MCGINTY

AND

2022-SC-0516-DG

CHURCHILL DOWNS, INC. APPELLANT

ON REVIEW FROM COURT OF APPEALS V. NO. 2021-CA-0766 JEFFERSON CIRCUIT COURT NO. 19-CI-001372

JOI DENISE ROBY; BLUE CROSS APPELLEES BLUE SHIELD OF TEXAS; BRADLEY RACING STABLES, LLC; WILLIAM BUFF BRADLEY; AND KYLE MCGINTY

2022-SC-0523-DG

JOI DENISE ROBY AND APPELLANTS BLUE CROSS BLUE SHIELD OF TEXAS ON REVIEW FROM COURT OF APPEALS V. NO. 2021-CA-0766 JEFFERSON CIRCUIT COURT NO. 19-CI-001372

CHURCHILL DOWNS, INC.; APPELLEES BRADLEY RACING STABLES, LLC; WILLIAM BUFF BRADLEY; AND KYLE MCGINTY

OPINION OF THE COURT BY CHIEF JUSTICE VANMETER

REVERSING

The Farm Animals Activity Act (“FAAA”), KRS 1 247.401–.4029, “provides

limited liability for those engaged in farm animal activities.” Keeneland Ass’n,

Inc. v. Prather, 627 S.W.3d 878, 883 (Ky. 2021). However, limited liability

“shall not apply to farm animal activity sponsors, farm animal activity

professionals, persons, or participants when engaged in horse racing activities.”

KRS 247.4025(1) (emphasis added). This case presents another opportunity for

us to clarify the parameters of engaging in horse racing activities. Specifically,

we address whether a horse stabled in the backside of Churchill Downs during

a race meet, in this instance the Kentucky Derby, but not actively engaged in

any activities related to the races, was engaged in horse racing activities for the

purposes of the FAAA exemption. We hold that an animal not actively engaged

in activities directly related to the running of a horse race is not exempted

1 Kentucky Revised Statutes

2 under KRS 247.4025(1), regardless of the fact that the horse was stabled in a

location actively involved in horse racing.

I. FACTUAL AND PROCEDURAL BACKGROUND

During the 2018 Kentucky Derby, Kyle McGinty invited Joi Denise Roby

and her husband to the backside stable area of Churchill Downs. This area

was not open to the public and individuals needed credentials to gain access to

the area. As a Kentucky Horse Racing Commission (“KHRC”) license holder,

McGinty was credentialed to access the area and was allowed to admit two

personal guests. Roby and her husband did not purchase tickets to enter the

Churchill Downs racetrack but were permitted as McGinty’s personal guests.

At the gate entrance where Roby and her husband met with McGinty, a

warning sign was posted. The warning sign, as required by KRS 247.4027(3)

stated:

WARNING. Under Kentucky law, a farm animal activity sponsor, farm animal professional, or other person does not have the duty to eliminate all risks of injury of participation in farm animal activities. There are inherent risks of injury that you voluntarily accept if you participate in farm animal activities.

As McGinty’s personal guests, Roby and her husband walked through

the backside passing several horses stabled in the area. Roby was familiar

with and comfortable around horses. She owned a quarter horse, had ridden

horses for most of her life, and was aware of the inherent risks of being around

them, including the unpredictable nature to bite. Those inherent risks did not

stop her from interacting with the horses in their stalls. She was petting

horses, giving them peppermints, and taking photographs with them. One of

3 the horses Roby approached was a stable pony named Henry. 2 Henry was

owned by Bradley and was used to escort racehorses to and from the track,

although not on the day in question. As Roby approached Henry in his stall,

he lunged and bit her.

Roby sued Bradley and Churchill Downs in Jefferson Circuit Court for

breaching its duty to maintain and keep the premises safe for the use of its

patrons, failing to exercise reasonable care for the safety of Roby, and failing to

eliminate or warn of dangerous conditions on the premises. 3 Bradley and

Churchill Downs moved for summary judgment.

The trial court granted summary judgment, holding that the FAAA

exemption contained in KRS 247.4025(1) did not apply to Churchill Downs

because the stabling of a horse was a farm animal activity, not a horse racing

activity. As for Bradley, the court held the FAAA horse racing exemption did

not apply because Roby was engaged in a farm animal activity when she was

bit by the horse. The court also ruled that Roby was a licensee because she

conferred no benefit to Churchill Downs and no evidence in the record

supported a breach of duty. As to the application of LMCO 4 § 91.028(A), the

2 “Stable ponies” are non-racing horses that tend to be older and friendlier than

thoroughbred racehorses. These stable ponies act as a calming presence for the racehorses to better control them as they go to and from the track. 3 Blue Cross Blue Shield of Texas filed an intervening complaint against

Churchill Downs and Bradley. The Jefferson Circuit Court through an agreed order permitted Blue Cross Blue Shield to intervene as subrogee of Roby. 4 Louisville Metro Code of Ordinances.

4 court held it did not impose strict liability for injuries caused by horses. Roby

appealed.

The Court of Appeals agreed with the Jefferson Circuit Court holding on

LMCO § 91.028(A) but reversed the trial court orders granting summary

judgment for Bradley and Churchill Downs. The Court of Appeals found that

the horse racing exemption applied because: 1) live racing was occurring; 2)

Roby was injured after being bitten by a horse located on the premises; and 3)

the horse was used to escort racehorses to and from the track. The court then

found that Roby was an invitee under the analysis in Bramlett v. Ryan, 635

S.W.3d 831 (Ky. 2021).

Bradley, Churchill Downs, and Roby all sought discretionary review from

this Court, which we granted. Bradley and Churchill Downs sought

discretionary review of the Court of Appeals’ ruling as to the applicability of the

FAAA horse racing exemption and Roby’s status as an invitee. Roby sought

discretionary review on the Court of Appeals’ application of LMCO § 91.028(A).

II. STANDARD OF REVIEW

Summary judgment is proper when the record shows “no genuine issue

as to any material fact and that the moving party is entitled to a judgment as a

matter of law.” CR 5 56.03. As a matter of law, we review issues relative to

statutory construction de novo. We owe no deference to the construction of

5 Kentucky Rules of Civil Procedure.

5 statutes by the trial court or Court of Appeals. Cumberland Valley Contractors,

Inc. v. Bell Cnty. Coal Corp., 238 S.W.3d 644, 647 (Ky. 2007).

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