Kamryn Baker v. Lynn Fields

CourtKentucky Supreme Court
DecidedMarch 22, 2018
Docket2017-SC-0144
StatusPublished

This text of Kamryn Baker v. Lynn Fields (Kamryn Baker v. Lynn Fields) 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
Kamryn Baker v. Lynn Fields, (Ky. 2018).

Opinion

RENDERED: MARCH 22, 2018 TO BE PUBLISHED

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KAMRYN .BAKER APPELLANT

ON REVIEW FROM COURT OF APPEALS V. CASE NO. 2015-CA-001673 LAUREL CIRCUIT COURT NO. 13-CI-01000

LYNN FIELDS AND BO RAINS APPELLEES

. OPINION OF THE COURT BY CHIEF JUSTICE MINTON

REVERSING AND REMANDING

In Breathitt County Bd. of Educ. v. Prater, this court announced a new rule

of law allowing an interlocutory appeal of a trial court's ruling on an immunity

defense. 1 We ·granted discretionary review of this case to determine if the Court · ...

of Appeals exceeded the scope of appellate review 'in this interlocutory appeal

when it not only agreed with the trial court that the defendants were not

entitled to qualified immunity but went further and conclusively determined

that these defendants were not negligent as a matter of law. We hold that the ' '

scope of appellate review of an interlocutory appeal of the trial court's

determination of qualified official immunity is limited to the specific ·issue of '' whether immunity was properly denied. So we must reverse the Court of

1 29~ S.W.3d 883, 886 (Ky. 2009). Appeals and remand this case to. the t~ial court for further proceedings

consistent with this opinion.

I. BACKGROUND. Kamryn Baker, a student at North Lau.rel High School, brought suit

against various school officials, in their individual and official capacities, after

slipping on a patch of black ice in the school's parking lot. The trial court

dismfssed the suit against all but two defendants, Lynn Fields and Bo Rains,

. who are two grounds crew members allegedly responsible for removing snow

and ice from the school's parking lot.

After some discovery took plaGe, Fields and Rains moved for summary

judgment, claiming protection under the qualified official immunity doctrine.2

The trial court denied their motion, concluding that snow and ice removal

duties are ministerial in nature. Fields and Rains filed a motion to alter,

· amend, or vacate the trial court's order denying immunity, which the trial court

denied, as well.

Fields and Rains timely appealed to the Court of Appeals. In their Notice

of ,Appeal, Fields and Rains indicated they were appealing the trial court's

denial of their motion for summary judgment regarding their protection under

the qualified official immunity doctrine. In their Prehearing Statements, Fields

and Rains listed as issues to be raised in the appeal, "Qualified Official

Immunity" and the discretionary nature of the duties of Fields and Rains ..

Finally, both parties only briefed the qualified immunity issue.

2Fields and Rains also clairiied protection under the open and obvious doctrine, which the trial court also rejected. However, no appeal was filed on this basis. 2 The Court of Appeals agreed with the trial court that snow and ice

removal is a ministerial duty not affording qualifi~d immunity protection. But

·the Cm.:irt of Appeals further decided that Fields and Rains were entitl~d to . I summary judgment as a matter of law based on the facts of the case-

specifically, that Fields and Rains did not have a duty to remove the snow and

.ice. Baker then appealed .to this Court, arguing that the Court of Appeals

exceeded the scope of appellate review in deciding the substantive issue of

negligence. We granted discretionary review.

II. ANALYSIS. I , The sole issue we must address is whether the Court of Appeals exceeded '. its scope of appellate review when it addressed the substantive claim of

negligence on an interlocutory appeal o.f a decision about qualified official

immunity. We find that the Court of Appeals did excee~ its ~uthority by.

addressing the claim of negligence. Because determining the proper scope of

appellate review of an interlocutory .appeal is a question_of law, we review ' ~ . the·'

Court of Appeals' decision de novo.

Procedurally, Fields and Rains' appeal to the Court of Appeals

constituted an interlocutory appeal. When the trial court denied Fields and ''',

Rains' summary judgment motion, it only concluded that Fields and Rains

were not entitled qualified official immunity protection. This did not constitute

a final judgment under Kentucky Civil Rule ("CR") 54.01 because the

' 3 substantive claim of negligence still needed to be decided."3 Generally, appeals

may only be made from firn!ljudgments, per the plain language of CR 54.01.

But in rare cases, Kentucky affords a party the 9pportunity to appeal certain

issues in ~ case before fin~ judgment has been issued, termed an interlocutory

appeal. 4

This Court in Prater specified that a ruling on an immunity defense is an

appealable issue by interlocutory appeal.s We explained that the purpose of

allowing an immunity issue to be raised by interlocutory appeal is "to address

substantial claims of right which would be rendered moot by litigation and

tpus are not subject to meanin,gful review in the ordinary course following a

finaljudgment."6 We then "agree[d] ... that orders denying claims of immunity

raise this same concern andlikeWise should be subject to prompt appellate

review."7

But the Court of Appeals in Commonwealth v. Samaritan Alliance

correctly recognized that the scope of interlocutory appellate review should be

limited to the issue of immunity, ~d no substantive issue~.s We agree with the

Court of Appeals' limitation on the scope of review of an interlocutory appeal. A

3 "A final or appealable judgment is a final order adjudicating all the rights of all the parties in an action or proceeding, or ajudgment made fin~ uµder Rule 54.02." CR 54.01. . . 4 See generally, Ratliffv. Fiscal Court of Caldwell County, 617 S.W.2d 36 (Ky. 1981). Various other Kentucky statutes, civil rules, and cases describe other situations providing for interlocutory appeals, but the enumeration of them her~ is unnecessary. s 292 S.W.3d 883, 886 (Ky. 2009). 6 Id. 1 Id.

s 439 S.W.3d 757, 760 (Ky. App. 2014). 4 court can only address the issues presented in the interlocutory appeal itself,

nothing more. Otherwise, interlocutory appeals would be used as vehicles for

bypassing the structured appellate process. Specifically, this means, and we

hold, that an appellate court reviewing an interlocutory appeal of a trial court's

determination of a defendant's immunity from suit is limited to the specific

issue of whether immunity was properly denied, nothing more. We note that

this decisi.on is in line with federal courts' review of interlocutory appeals.9

In this case, the Court of Appeals, in addition to finding the act of snow

and ice remova.I as ministerial, conclusively determined that Fields and Rains r'

did not have a duty to remove the snow and ice and therefore could not be

found negligent. Conclusively determining the claim of negligence in this case

was outsid,e the scope of interlocutory appellate review. Determining whether

the act of snow and ice removal is a discretionary or ministerial function is

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Related

Owensby v. City of Cincinnati
414 F.3d 596 (Sixth Circuit, 2005)
Ratliff v. Fiscal Court of Caldwell Cty., Ky.
617 S.W.2d 36 (Kentucky Supreme Court, 1981)
Laurie Range v. Kenneth Douglas
763 F.3d 573 (Sixth Circuit, 2014)
Tucker v. Cty Richmond, KY
388 F.3d 216 (Sixth Circuit, 2004)
Breathitt County Board of Education v. Prater
292 S.W.3d 883 (Kentucky Supreme Court, 2009)
Commonwealth v. Samaritan Alliance, LLC
439 S.W.3d 757 (Court of Appeals of Kentucky, 2014)

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Kamryn Baker v. Lynn Fields, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kamryn-baker-v-lynn-fields-ky-2018.