Kevin Gibson v. Brown-Forman Corporation

Court of Appeals of Kentucky·Decided July 2, 2026·No. 2025-CA-1277·Unpublished

Opinion

RENDERED: JULY 2, 2026; 10:00 A.M.

NOT TO BE PUBLISHED

Commonwealth of Kentucky

Court of Appeals

NO. 2025-CA-1277-MR

KEVIN GIBSON APPELLANT

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE TRACY E. DAVIS, JUDGE ACTION NO. 23-CI-007296

BROWN-FORMAN CORPORATION APPELLEE

OPINION

AFFIRMING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; L. JONES AND TAYLOR, JUDGES. THOMPSON, CHIEF JUDGE: Kevin Gibson (Appellant) appeals from an order of the Jefferson Circuit Court granting summary judgment in favor of Brown- Forman Corporation (Appellee). Appellant argues that the circuit court erred applying “up the ladder” tort immunity in favor of Appellee, and that summary judgment in favor of Appellant was warranted. After careful review, we find no error and affirm the order on appeal.

FACTS AND PROCEDURAL HISTORY On January 10, 2023, Appellant was employed by Koetter Building Services, LLC (Koetter) as a construction foreman and carpenter. Appellee entered into a contract with Koetter under which Koetter agreed to construct a specialized piece of equipment similar to a crane called an alternative lift barrel apparatus or “ricker” to move barrels in Appellee’s warehouse.

For many years, Appellee used manual labor to move barrels of bourbon in its “rickhouse” or warehouse as part of the bourbon aging and production process. The record indicates that Appellee had an ongoing problem of losing barrels in remote locations of the rickhouse that were too difficult or dangerous for its workers to retrieve using its normal process of hoists and chains. Appellee engaged Koetter to develop and construct a safer and more efficient mechanism of moving barrels. In response, Koetter developed a ricker, consisting of a piece of machinery designed to replace the old system of using two manual laborers who would crawl into the barrel stack to use the hoist and chain technique.

As part of the ricker installation process, Appellant worked in warehouses K and L at Appellee’s facility on Dixie Highway in Louisville, Kentucky. The warehouses are one structure which share an elevator. While engaged in the installation process, Appellant and another employee loaded aluminum plates into Appellee’s freight elevator. The elevator had interior cage-

style doors which traveled with the elevator and exterior wooden doors which were affixed to each floor.

While in the stationary elevator, Appellant attempted to manually close the exterior doors. These doors are described in the record as moving up and down like a clamshell. There allegedly was no pull handle on the interior of the doors, so Appellant reached through the door opening and pulled a handle on the exterior door. As the exterior doors began to close, their mechanism caused their movement to accelerate. At about the same time, Appellant’s body moved slightly forward. Appellant’s hand was caught between the two doors as they closed, causing serious injury.

At the time of the injury, Koetter was covered by a workers’

compensation policy issued by American Casualty Company of Reading, Pennsylvania. Appellant filed a claim under this policy, which was paid by American Casualty.

On November 28, 2023, Appellant filed this action against Appellee in Jefferson Circuit Court. He alleged that Appellee improperly failed to provide safe working conditions, adequate safety warnings, and proper training. He also asserted that Appellee’s conduct was negligent or grossly negligent which proximately resulted in his injuries.

On June 30, 2025, Appellee filed a motion for summary judgment pursuant to Kentucky Rules of Civil Procedure (CR) 56. Citing General Electric Co. v. Cain, 236 S.W.3d 579 (Ky. 2007), it argued that it was entitled to “up the ladder” tort immunity for injuries sustained by Appellant because Appellant had availed himself of the exclusive remedy provision of the Workers’ Compensation Act found in Kentucky Revised Statutes (KRS) 342.690(1). This immunity, it argued, arose because the work being performed by Appellant—an employee of a third-party contractor—was part of the regular or recurrent work of Appellee in manufacturing, distilling, aging, and bottling bourbon.

Appellant filed a responsive brief and Appellee a reply. On September 9, 2025, the circuit court heard oral arguments on the motion. On September 12, 2025, the court entered an opinion and order granting Appellee’s motion for summary judgment. The court determined that the service provided by Koetter to Appellee, i.e., the development and installation of a new mechanism for moving barrels, was a regular or recurrent rather than a novel or non-regular part of Appellee’s business. Because the service was found to be a regular and recurrent part of Appellee’s business, the court determined that Appellee was Appellant’s statutory employer pursuant to KRS 342.610(2)(b) for purposes of KRS

342.690(1) immunity, and was therefore entitled to summary judgment. This appeal followed.1 STANDARD OF REVIEW

Summary judgment “shall be rendered forthwith if 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.” CR 56.03. “The record must be viewed in a light most favorable to the party opposing the motion for summary judgment and all doubts are to be resolved in his favor.” Steelvest, Inc. v. Scansteel Service Center, Inc., 807 S.W.2d 476, 480 (Ky. 1991). Summary judgment should be granted only if it appears impossible that the nonmoving party will be able to produce evidence at trial warranting a judgment in his favor. Id. “Even though a trial court may believe the party opposing the motion may not succeed at trial, it should not render a summary judgment if there is any issue of material fact.” Id. Finally, “[t]he standard of review on appeal of a 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

1 Appellant’s first appeal, styled No. 2025-CA-1236-MR, was dismissed as interlocutory by order of this Court on October 10, 2025.

judgment as a matter of law.” Scifres v. Kraft, 916 S.W.2d 779, 781 (Ky. App. 1996).

ARGUMENTS AND ANALYSIS

Appellant argues that the Jefferson Circuit Court erred in granting Appellee’s motion for summary judgment. The focus of his argument is his contention that the Jefferson Circuit Court improperly applied the doctrine of up the ladder immunity to bar his action against Appellee. Appellant asserts that up the ladder immunity is a narrow exception, in derogation of the common law, which must be strictly construed. He argues that he performed work for Koetter which was not a regular and recurrent part of Appellee’s business. As such, he maintains that he could not properly be characterized as Appellee’s employee for purposes of immunity under Kentucky’s workers’ compensation scheme.

As part of this argument, Appellant maintains that the circuit court erroneously extended the meaning of regular and recurrent work to include any work that may benefit the operations of a business. This, he argues, conflates the goal of barrel moving with the actual work of building new equipment. Appellant requests an opinion reversing the Jefferson Circuit Court’s order of summary judgment and remanding the matter for a jury trial.

KRS 342.690(1) states that if an employer provides workers’

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Related

Steelvest, Inc. v. Scansteel Service Center, Inc.
807 S.W.2d 476 (Kentucky Supreme Court, 1991)
General Electric Co. v. Cain
236 S.W.3d 579 (Kentucky Supreme Court, 2007)
Scifres v. Kraft
916 S.W.2d 779 (Court of Appeals of Kentucky, 1996)
Stephen Marchese v. Allison Aebersold
530 S.W.3d 441 (Kentucky Supreme Court, 2017)