Kyle Thompson v. Administrative Office of the Courts

CourtCourt of Appeals of Kentucky
DecidedDecember 13, 2024
Docket2023-CA-1253
StatusUnpublished

This text of Kyle Thompson v. Administrative Office of the Courts (Kyle Thompson v. Administrative Office of the Courts) 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
Kyle Thompson v. Administrative Office of the Courts, (Ky. Ct. App. 2024).

Opinion

RENDERED: DECEMBER 13, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-1253-MR

KYLE THOMPSON APPELLANT

APPEAL FROM FRANKLIN CIRCUIT COURT v. HONORABLE SHEILA R. ISAAC, SPECIAL JUDGE ACTION NO. 21-CI-00033

ADMINISTRATIVE OFFICE OF THE COURTS APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: ECKERLE, GOODWINE, AND MCNEILL, JUDGES.

MCNEILL, JUDGE: The issue here involves CourtNet, Kentucky’s electronic

court filing system and database. Appellant is attorney, Kyle Thompson

(Thompson). Appellee is the Kentucky Administrative Office of the Courts

(AOC). AOC administers CourtNet and grants access to attorneys who agree to

the terms and conditions associated with CourtNet. Thompson signed AOC’s

CourtNet terms and conditions of usage (User Agreement). Thompson owns and operates Capital Court Authority, LLC (CCA).

CCA provides probation monitoring services to Franklin, Shelby, and Scott

District Courts. AOC suspended Thompson’s CourtNet account upon discovery

that he was using his account for CCA business, thus violating the terms of the

User Agreement. More precisely, AOC determined that Thompson had used his

CourtNet account for commercial purposes on behalf of CCA and by sharing his

log-in credentials with others at CCA. AOC reactivated Thompson’s KYeCourts

login to eFile only status.

Thompson filed a declaration of rights suit in Franklin County Circuit

Court seeking redress pursuant to contractual and constitutional claims. The court

dismissed Thompson’s substantive and procedural due process claims, and ordered

the case proceed as a contract claim. The parties subsequently filed cross motions

for summary judgment on that remaining issue. The court entered judgment in

favor of AOC. For the following reasons, we affirm.

STANDARD OF REVIEW

“Since a motion to dismiss for failure to state a claim upon which

relief may be granted is a pure question of law, a reviewing court owes no

deference to a trial court's determination; instead, an appellate court reviews the

issue de novo.” Fox v. Grayson, 317 S.W.3d 1, 7 (Ky. 2010) (citation omitted).

Accordingly, “the pleadings should be liberally construed in the light most

-2- favorable to the plaintiff, all allegations being taken as true.” Id. “Because

summary judgment involves only legal questions and the existence of any disputed

material issues of fact, an appellate court need not defer to the trial court’s decision

and will review the issue de novo.” Lewis v. B&R Corp., 56 S.W.3d 432, 436 (Ky.

App. 2001) (citation omitted). With these standards in mind, we return to the

present issues.

ANALYSIS

Thompson argues that the circuit court erred in dismissing: 1) his

breach of contract claim; and 2) his substantive due process claim. We will

address these in reverse order.

Due Process

Thompson relies primarily on the rights conferred under Section 2 of

the Kentucky Constitution.

Section 2 of the Kentucky Constitution provides the Commonwealth shall be free of arbitrary action. With respect to adjudications, whether judicial or administrative, this guarantee is generally understood as a due process provision whereby Kentucky citizens may be assured of fundamentally fair and unbiased procedures.

Commonwealth Nat. Res. & Env’t Prot. Cabinet v. Kentec Coal Co., 177 S.W.3d

718, 726 (Ky. 2005). See also TECO Mech. Contractor, Inc. v. Com., 366 S.W.3d

386, 393 (Ky. 2012), as corrected (Jun. 27, 2012) (“Both the United States and

-3- Kentucky Constitutions prohibit the Commonwealth from depriving individuals of

liberty or property without due process of law.”). Furthermore,

Section 2 of our Bill of Rights is unique, only the Constitution in Wyoming having a like declaration . . . . Section 2 of our Constitution reads: ‘absolute and arbitrary power over the lives, liberty and property of freemen exists nowhere in a republic, not even in the largest majority . . . .’ So it may be said that whatever is contrary to democratic ideas, customs and maxims is arbitrary. Likewise, whatever is essentially unjust and unequal or exceeds the reasonable and legitimate interests of the people is arbitrary.

Kentec Coal Co., 177 S.W.3d at 726.

Thompson cites cases for the general proposition that Section 2 is

broader than its federal counterpart. But Compare Blue Movies, Inc. v.

Louisville/Jefferson Cnty. Metro Gov’t, 317 S.W.3d 23, 29 (Ky. 2010) (“[S]tate

courts are free to expand individual rights beyond the federal floor . . . .”) with

Graham v. Sec’y of State Michael Adams, 684 S.W.3d 663, 699 (Ky. 2023)

(Nickell, J., concurring in part) (“Kentucky courts have long interpreted the scope

of Section 2 consistently with federal equal protection and due process

protections.”). Critically, none of the cases Thompson cites are factually like the

present. See, e.g., City of Lebanon v. Goodin, 436 S.W.3d 505, 518 (Ky. 2014)

(rejecting the plaintiff’s claim that the city acted arbitrarily by intentionally

manipulating the entire annexation process to guarantee its success); Thornton v.

Commonwealth, 421 S.W.3d 372, 380 (Ky. 2013) (finding that the appellant’s

-4- twenty-year sentence invoked no sense of fundamental unfairness and does not

constitute an exercise of absolute and arbitrary power as proscribed by Section 2);

and Miller v. Admin. Ofc. of the Cts., 361 S.W.3d 867 (Ky. 2011) (addressing state

due process claim in the context of whether Appellants’ position with AOC as

tenured or “at-will”).

AOC’s action here was certainly not arbitrary. The procedures and

discretion of AOC for granting, maintaining, and terminating an attorney’s access

to CourtNet are extensive and well-defined. See Administrative Procedures of the

Court of Justice Part XI (“AP Part XI”). Furthermore, Thompson has not

presented this Court with any persuasive legal or factual authority demonstrating a

constitutionally protected property interest in a CourtNet account, or that he

maintains a protected status. While the protections of Section 2 are significant,

they are not unlimited. Similarly, Thompson has not provided any binding or

persuasive authority that his alleged interest here is protected by the Fourteenth

Amendment of the United States Constitution. Therefore, we agree with the circuit

court that this is a contract case. We will proceed accordingly.

Contract

“The interpretation of a contract is a question of law.” Stowe v.

REALCO Ltd. Liab. Co., 551 S.W.3d 462, 465 (Ky. App. 2018). In interpreting a

contract, the “agreement must be construed as a whole, giving effect to all parts

-5- and every word in it if possible.” Big Sandy Co., L.P. v. EQT Gathering, LLC, 545

S.W.3d 842, 845 (Ky. 2018) (quoting City of Louisa v. Newland,

Related

Lewis v. B & R CORPORATION
56 S.W.3d 432 (Court of Appeals of Kentucky, 2001)
City of Louisa v. Newland
705 S.W.2d 916 (Kentucky Supreme Court, 1986)
Cantrell Supply, Inc. v. Liberty Mutual Insurance Co.
94 S.W.3d 381 (Court of Appeals of Kentucky, 2002)
Blue Movies, Inc. v. Louisville/Jefferson County Metro Government
317 S.W.3d 23 (Kentucky Supreme Court, 2010)
Fox v. Grayson
317 S.W.3d 1 (Kentucky Supreme Court, 2010)
TECO Mechanical Contractor, Inc. v. Commonwealth
366 S.W.3d 386 (Kentucky Supreme Court, 2012)
Miller v. Administrative Office of the Courts
361 S.W.3d 867 (Kentucky Supreme Court, 2011)
Thornton v. Commonwealth
421 S.W.3d 372 (Kentucky Supreme Court, 2013)
City of Lebanon v. Goodin ex rel. Goodin
436 S.W.3d 505 (Kentucky Supreme Court, 2014)
Stowe v. Realco Ltd. Liab. Co.
551 S.W.3d 462 (Court of Appeals of Kentucky, 2018)
Big Sandy Co. v. Eqt Gathering, LLC
545 S.W.3d 842 (Missouri Court of Appeals, 2018)

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