Kenneth A. Downard v. Maynard Builders, Inc.

Court of Appeals of Kentucky·Decided July 24, 2026·No. 2025-CA-0706·Unpublished

Opinion

RENDERED: JULY 24, 2026; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2025-CA-0706-MR

KENNETH A. DOWNARD AND KATHY J. DOWNARD APPELLANTS

APPEAL FROM FAYETTE CIRCUIT COURT v. HONORABLE DIANE MINNIFIELD, JUDGE ACTION NO. 24-CI-01696

MAYNARD BUILDERS, INC.; CAROLINE L. MAYNARD; JOSHUA C. MAYNARD A/K/A JOSH CODY MAYNARD; AND LOIS ANN MAYNARD N/K/A LOIS ANN MAYNARD HARRIS APPELLEES

OPINION REVERSING AND REMANDING

** ** ** ** **

BEFORE: CALDWELL, ECKERLE, AND TAYLOR, JUDGES.

CALDWELL, JUDGE: Kenneth and Kathy Downard (“the Downards”) filed suit

against multiple defendants and successfully moved for judgment on the pleadings

on some of their claims. One defendant later successfully moved to set aside only that part of the partial judgment on the pleadings which granted judgment against

her due to mistake, inadvertence or excusable neglect. See CR1 60.02(a). For the

reasons stated herein, we reverse the granting of CR 60.02 relief and remand for

entry of an order denying the CR 60.02 motion and reinstating the partial judgment

on the pleadings in its entirety.

FACTS

In May 2024, the Downards filed suit against Maynard Builders, Inc.,

(“Maynard Builders”) and Joshua, Caroline, and Lois Maynard for claims relating

to a failure to complete the contracted-for building of a residence. The complaint

asserted some claims solely against Maynard Builders and Joshua Maynard

(“Joshua”)—specifically, Count 1 (breach of contract), Count 2 (fraudulent

misrepresentation/fraud in the inducement), and Count 3 (conversion). The

complaint also asserted some claims against all defendants—namely, Count 4

(unjust enrichment), and Count 5 (piercing the corporate veil).

In July 2024, the Downards filed a motion for default judgment.

Shortly thereafter, Attorney Robin C. Bennett (“Bennett”) filed a late answer on

behalf of the defendants. The answer included an assertion that Lois Maynard

(“Lois”) should be dismissed from the lawsuit because she was no longer an officer

1 Kentucky Rules of Civil Procedure.

-2- or shareholder of Maynard Builders. (However, Bennett never filed a motion to

dismiss on Lois’ behalf.)

After the answer was filed, the Downards filed a motion for partial

judgment on the pleadings. They contended that, due to admissions in the answer,

they were entitled to judgment on the pleadings on their claims for breach of

contract, conversion, and undue enrichment (Counts 1, 3, and 4). No written

response was filed before the circuit court held a hearing on the motion for partial

judgment on the pleadings.

The parties’ attorneys appeared at the hearing before the circuit court

on July 26, 2024. The judge stated that, since a late answer had been filed, the

motion for a default judgment would be denied. Next, the attorneys orally argued

the motion for partial judgment on the pleadings. Bennett orally argued that the

motion for partial judgment on the pleadings should be denied because some facts

were disputed. She also orally noted that the answer asserted Lois should be

dismissed for lack of standing since she was no longer an officer or shareholder of

Maynard Builders when the contract was executed. Counsel for the Downards

pointed out no motion to dismiss had been filed.

After hearing oral argument, the judge orally stated she would be

granting the motion for partial judgment on the pleadings and asked that an order

to this effect be tendered. Downards’ counsel tendered an order granting the

-3- motion for partial judgment on the pleadings. The tendered order stated that

judgment on Count 4 (unjust enrichment) was granted against Maynard Builders

and Joshua, Caroline, and Lois Maynard, jointly and severally. (The tendered

order also stated that judgment was entered on Counts 1 and 3 (for breach of

contract and conversion) against Maynard Builders and Joshua, jointly and

severally.) The judge electronically signed the tendered order on August 1, and the

order granting the motion for partial judgment on the pleadings was entered on

August 5, 2024.

In October 2024, the Downards filed a motion to voluntarily dismiss

their remaining claims (for fraudulent misrepresentation/fraud in the inducement

and for piercing the corporate veil). The circuit court granted this motion in an

order entered on October 16, 2024.

Both the August 2024 order granting the Downards partial judgment

on the pleadings and the October 2024 order voluntarily dismissing the Downards’

remaining claims contained statements indicating these orders were final and

appealable with no just cause for delay.

In March 2025, Bennett filed on behalf of Lois, now known as Lois

Harris following her remarriage, a motion to release a judgment lien on real estate.

The motion stated: “On August 5, 2024, the Plaintiffs were granted a partial

summary judgment against defendants Maynard Builders, Inc., Joshua Maynard,

-4- and Caroline Maynard but NOT against defendant Lois Harris.” (Record on

Appeal, “R”, p. 89) (emphasis in original).

The motion further noted the Downards had voluntarily dismissed

their remaining claims of fraudulent misrepresentation and piercing the corporate

veil in October 2024. The motion asserted this voluntary dismissal “should have

acted as a release for any and all liability for the Plaintiffs’ claims against Ms.

Harris in this action.” (R, p. 89.)

The motion asserted the Downards had filed a judgment lien against

all property owned by Lois in Fayette County on February 5, 2025. It also argued

that the lien should be released because there was no judgment against Lois.

The Downards filed a response objecting to the motion to release the

lien. The response accurately noted the court’s August 2024 order granting partial

judgment on the pleadings specifically named Lois as being jointly and severally

liable, and stated that the order was final and appealable with no just cause for

delay. The response asserted, inter alia, that the August 2024 order granting

partial judgment on the pleadings was clearly a judgment entered against Lois,

jointly and severally. The response also noted that no appeal had been filed from

the August 2024 order and asserted the time for filing a timely appeal had passed.

See generally RAP2 3.

2 Kentucky Rules of Appellate Procedure.

-5- Next, Bennett filed on Lois’ behalf a Reply and Countermotion Under

CR 60.02(a). Bennett asserted therein that she had never received a copy of the

tendered order granting the motion for partial judgment on the pleadings. She

explained that she had previously been employed by the Suhre & Associates law

firm and formerly used an email address associated with that firm, but she had left

the firm in August 2024. Bennett stated she had not received opposing counsel’s

email with the tendered order, which had been sent to her Suhre law firm email

address which she could no longer access.

The reply/countermotion also stated that Lois was served with a copy

of the judgment lien entered against Lois’ property at a Hart Road address in

Lexington on February 5, 20253—which prompted Lois to immediately contact

Bennett to see if an error occurred.

The reply/countermotion further stated Bennett reviewed the answer

and her notes from the late July 2024 hearing on the motion for partial judgment on

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