Ledbetter Water District v. Crittenden-Livingston Water District

CourtKentucky Supreme Court
DecidedFebruary 20, 2020
Docket2018-SC-0494
StatusUnpublished

This text of Ledbetter Water District v. Crittenden-Livingston Water District (Ledbetter Water District v. Crittenden-Livingston Water District) 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
Ledbetter Water District v. Crittenden-Livingston Water District, (Ky. 2020).

Opinion

IMPORTANT NOTICE NOT TO BE PUBLISHED OPINION

THIS OPINION IS DESIGNATED "NOT TO BE PUBLISHED." PURSUANT TO THE RULES OF CIVIL PROCEDURE PROMULGATED BY THE SUPREME COURT, CR 76.28(4)(C), THIS OPINION IS NOT TO BE PUBLISHED AND SHALL NOT BE CITED OR USED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE; HOWEVER, UNPUBLISHED KENTUCKY APPELLATE DECISIONS, RENDERED AFTER JANUARY 1, 2003, MAY BE CITED FOR CONSIDERATION BY THE COURT IF THERE IS NO PUBLISHED OPINION THAT WOULD ADEQUATELY ADDRESS THE ISSUE BEFORE THE COURT. OPINIONS CITED FOR CONSIDERATION BY THE COURT SHALL BE SET OUT AS AN UNPUBLISHED DECISION IN THE FILED DOCUMENT AND A COPY OF THE ENTIRE DECISION SHALL BE TENDERED ALONG WITH THE DOCUMENT TO THE COURT AND ALL PARTIES TO THE ACTION. RENDERED: FEBRUARY 20, 2020 NOT TO BE PUBLISHED

2018-SC-000494-DG

LEDBETTER WATER DISTRICT APPELLANT

ON APPEAL FROM COURT OF APPEALS V. CASE NO. 2017-CA-000578 LIVINGSTON CIRCUIT COURT NO. 15-CI-00079 HON. CLARENCE A. WOODALL, III

CRITTENDEN-LIVINGSTON WATER DISTRICT APPELLEE

MEMORANDUM OPINION OF THE COURT

REVERSING

The Kentucky Court of Appeals reversed a summary judgment entered by

the Livingston Circuit Court which found that a contract entered into between

Ledbetter Water District (“Ledbetter”) and the Crittenden-Livingston Water

District (“Crittenden-Livingston”) was void because it violated Kentucky

Constitution § 164. After review, we now reverse the Court of Appeals and

reinstate the trial court judgment in favor of Ledbetter.

I. BACKGROUND

Ledbetter and Crittenden-Livingston are both non-profit water districts

organized under Kentucky Revised Statutes (“KRS”) Chapter 74. Ledbetter is an

unincorporated community located in Livingston County. Crittenden County

and Livingston County formed a water company together. In 1988, Ledbetter

entered into a four-year agreement with the city of Grand Rivers for Grand

Rivers to become Ledbetter’s new source of water supply. Ledbetter and Grand Rivers entered into multiple water purchase agreements between 1988 and

2000. Ledbetter learned that Grand Rivers planned to close their water plant

and could no longer supply Ledbetter the amount of water they needed moving

forward.

In 1996, the Crittenden-Livingston Board of Commissioners began

drawing up plans to expand the Crittenden-Livingston water plant. Crittenden-

Livingston marketed water to five local areas within Crittenden and Livingston

counties to help fund the expansion. Ledbetter was one of the communities to

which Crittenden-Livingston marketed a water supply contract.

In May 1996, the Crittenden-Livingston Superintendent attended a

Ledbetter Water Board meeting to present the new plan. Ledbetter then sent a

letter to Crittenden-Livingston stating that it wanted to purchase 3,000,000

gallons of water per month from Crittenden-Livingston, at a price of $1.68 per

thousand gallons, for an unspecified length of time.

Experiencing delays in the project, it was not until January 17, 2000

that Crittenden-Livingston faxed a proposed contract to the Ledbetter Board for

consideration. A week later, the Ledbetter Board approved the proposed

contract. Relevant to our review, Ledbetter did not advertise, publicly or

privately, for bids before voting to enter into this contract. Under this contract,

Ledbetter and Crittenden-Livingston agreed for Crittenden-Livingston to

provide and sell a minimum of three million gallons of water per month for a

period of forty years. Crittenden-Livingston was also granted the right to

install a master meter in a constructed meter housing building on Ledbetter

2 property and to install water line connections to the Ledbetter water system.

Crittenden-Livingston also reserved the right to enter Ledbetter property to

read the meter and provide maintenance.

Over the course of the contract, Crittenden-Livingston tried to persuade

Ledbetter to purchase more than the minimum 3,000,000 gallons. By 2010,

Ledbetter was able to produce some of their water supply at their own plant at

a substantially lower cost than the contracted price.

In 2013, Ledbetter sought an opinion from the Kentucky Attorney

General’s office regarding the legality of the contract between the two entities.

Assistant Attorney General Matt James rendered an advisory opinion that the

contract was void because it violated Kentucky Constitution § 164. The letter

addressed a savings clause within the contract, which would have shifted the

term of years from forty to twenty; however, the contract was still deemed void

as the contract was not put up for public bid. Ledbetter advised the Crittenden

Board of Commissioners of this opinion, which Crittenden-Livingston rejected.

Ledbetter then filed a declaratory judgment action with the Livingston

Circuit Court. The trial court determined that the contract was within

Ledbetter’s authority to make; however, because the contract granted a

franchise and was in excess of twenty years, it was void under the Kentucky

Constitution.

The Court of Appeals reversed the Livingston Circuit Court holding that

because the contract involved two public entities, the franchise provision and

3 the public bidding requirements of the Kentucky Constitution did not apply.

This appeal followed.

II. STANDARD OF REVIEW

Summary judgment is only proper “to terminate litigation when, as a

matter of law, it appears that it would be impossible for the respondent to

produce evidence at trial warranting a judgment in his favor and against the

movant.”1 Because the grant of summary judgment does not involve fact-

finding, our standard of review is de novo.2

III. ANALYSIS

First, we review how the Kentucky Constitution applies to the facts

before us. Ky. Const. § 162, states,

No county, city, town or other municipality shall ever be authorized or permitted to pay any claim created against it, under any agreement or contract made without express authority of law, and all such unauthorized agreements or contracts shall be null and void.

Ky. Const. § 164, Term of Franchises, states:

No county, city, town, taxing district or other municipality shall be authorized or permitted to grant any franchise or privilege, or make any contract in reference thereto, for a term exceeding twenty years. Before granting such franchise or privilege for a term of years, such municipality shall first, after due advertisement, receive bids therefor publicly, and award the same to the highest and best bidder; but it

1 Paintsville Hosp. Co. v. Rose, 683 S.W.2d 255, 256 (Ky. 1985) (quoting Roberson v. Lampton, 516 S.W.2d 838, 840 (Ky. App. 1974)). 2 Pinkston v. Audubon Area Community Services, Inc., 210 S.W.3d 188, 189 (Ky. App. 2006).

4 shall have the right to reject any or all bids. This section shall not apply to a trunk railway.

(emphasis added). Therefore, when examining the requirements set out in the

Kentucky Constitution, we review both § 162 and § 164.

We must also determine the meaning of a “franchise.” In E.M. Bailey

Distributing Co., Inc. v. Conagra, Inc.,3 the Lyon County Riverport Authority had

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Related

Paintsville Hospital Co. v. Rose
683 S.W.2d 255 (Kentucky Supreme Court, 1985)
Pinkston v. Audubon Area Community Services, Inc.
210 S.W.3d 188 (Court of Appeals of Kentucky, 2006)
Roberson v. Lampton
516 S.W.2d 838 (Court of Appeals of Kentucky (pre-1976), 1974)
Board of Councilmen v. Pattie
12 S.W.2d 1108 (Court of Appeals of Kentucky (pre-1976), 1928)
Louisville & Jefferson County Metropolitan Sewer Dist. v. Town of Strathmoor Village
211 S.W.2d 127 (Court of Appeals of Kentucky (pre-1976), 1948)
Inland Waterways Co. v. City of Louisville
13 S.W.2d 283 (Court of Appeals of Kentucky (pre-1976), 1929)
Louisville Extension Water Dist. v. Diehl Pump & Supply Co.
246 S.W.2d 585 (Court of Appeals of Kentucky, 1952)
City of Russell v. City of Flatwoods
394 S.W.2d 900 (Court of Appeals of Kentucky, 1965)
E.M. Bailey Distributing Co. v. Conagra, Inc.
676 S.W.2d 770 (Kentucky Supreme Court, 1984)
Public Service Commission v. Dewitt Water District
720 S.W.2d 725 (Kentucky Supreme Court, 1986)
Carrollton Furniture Manufacturing Co. v. City of Carrollton
47 S.W. 439 (Court of Appeals of Kentucky, 1898)
City of Princeton v. Princeton Electric Light & Power Co.
179 S.W. 1074 (Court of Appeals of Kentucky, 1915)
Young v. City of Morehead
233 S.W.2d 978 (Court of Appeals of Kentucky, 1950)

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Ledbetter Water District v. Crittenden-Livingston Water District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ledbetter-water-district-v-crittenden-livingston-water-district-ky-2020.