Mark Handy v. louisville/jefferson County Metro Government

CourtKentucky Supreme Court
DecidedMarch 13, 2024
Docket2023 SC 0044
StatusUnknown

This text of Mark Handy v. louisville/jefferson County Metro Government (Mark Handy v. louisville/jefferson County Metro Government) 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
Mark Handy v. louisville/jefferson County Metro Government, (Ky. 2024).

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IMPORTANT NOTICE NOT TO BE PUBLISHED OPINION

THIS OPINION IS DESIGNATED “NOT TO BE PUBLISHED.” PURSUANT TO THE RULES OF CIVIL PROCEDURE PROMULGATED BY THE SUPREME COURT, RAP 40(D), THIS OPINION IS NOT TO BE PUBLISHED AND SHALL NOT BE CITED OR USED AS BINDING PRECEDENT IN ANY OTHER CASE IN ANY COURT OF THIS STATE; HOWEVER, UNPUBLISHED KENTUCKY APPELLATE DECISIONS, RENDERED AFTER JANUARY 1, 2003, MAY BE CITED FOR CONSIDERATION BY THE COURT IF THERE IS NO PUBLISHED OPINION THAT WOULD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 OPINIONS CITED FOR CONSIDERATION BY THE COURT SHALL BE SET OUT AS AN UNPUBLISHED DECISION IN THE FILED DOCUMENT AND A COPY OF THE ENTIRE DECISION SHALL BE TENDERED ALONG WITH THE DOCUMENT TO THE COURT AND ALL PARTIES TO THE ACTION. RENDERED: MARCH 14, 2024 NOT TO BE PUBLISHED

Supreme Court of Kentucky 2023-SC-0044-DG

MARK HANDY APPELLANT

ON REVIEW FROM COURT OF APPEALS V. NO. 2021-CA-0664 JEFFERSON CIRCUIT COURT NO. 20-CI-004304

LOUISVILLE/JEFFERSON APPELLEE COUNTY METRO GOVERNMENT

MEMORANDUM OPINION OF THE COURT

REVERSING AND REINSTATING

Subject to certain exceptions, the Claims Against Local Governments

Act 1 (CALGA) mandates that a local government provide for the defense of its

employees in any tort action arising out of an act or omission that occurs

within the scope of that employee’s employment, and further mandates that the

local government must pay any judgment or settlement arising therefrom. KRS

65.2005(1). However, a local government may seek indemnification from an

employee for those expenses under CALGA if “[t]he employee acted or failed to

act because of fraud, malice, or corruption[.]” KRS 65.2005(3)(a). In Kentucky,

those indemnity claims are subject to a five-year statute of limitations

1 Kentucky Revised Statutes (KRS) 65.200 to KRS 65.2006. pursuant to KRS 413.120. Norohna v. Zolkiewicz, 583 S.W.3d 42, 46 (Ky. App.

2018) (citing Affholder, Inc. v. Preston Carroll Co., Inc., 27 F.3d 232, 234 (6th

Cir. 1994)).

In this case, Louisville/Jefferson County Metro Government (Metro) filed

a CALGA indemnity claim against Mark Handy (Handy), a former Louisville

Metro Police Department (LMPD) detective. Handy’s numerous acts of

misconduct during the course of his employment led to Edwin Chandler

(Chandler) being convicted and sentenced to thirty years’ imprisonment for

crimes he did not commit. After Chandler was exonerated, he filed a 42

U.S.C.A. § 1983 claim against Metro, Handy, and others alleging numerous

violations of his civil rights. Metro paid Handy’s legal fees, and it reached an

8.5-million-dollar settlement with Chandler on Handy’s behalf which it paid.

Six years after the Chandler settlement agreement was reached, Handy

was indicted for perjury in relation to Chandler’s case. Two years after that,

Handy pled guilty to the charge. One month later, Metro filed a CALGA

indemnity claim against Handy on the basis that he acted or failed to act

because of fraud, malice, or corruption during the Chandler investigation and

trial. Handy filed a motion to dismiss the claim and asserted that the statute

of limitations on Metro’s indemnity claim began running when Chandler filed

his § 1983 claim or, at the latest, it began when Metro agreed to pay Chandler

an 8.5-million-dollar settlement. Metro argued in response that it had

absolutely no knowledge of Handy’s “malice, fraud, or corruption” until he pled

2 guilty or, at the earliest, until he was indicted, and its claim was therefore

timely.

The Jefferson Circuit Court found that the statute of limitations began to

run on Metro’s indemnity claim, at the latest, when it reached its settlement

agreement with Chandler, and it dismissed the claim as untimely. The Court

of Appeals reversed the circuit court because it did not make a finding as to

when Metro knew or reasonably should have known of Handy’s malice, fraud,

or corruption. Louisville/Jefferson Cnty. Metro Gov’t v. Handy, 2021-CA-0664-

MR, 2022 WL 12138037, at *3 (Ky. App. Oct. 21, 2022). It remanded to the

circuit court for it to make that finding and proceed accordingly. Id. After

review, we reverse the Court of Appeals and reinstate the circuit court’s order

dismissing Metro’s indemnity claim against Handy as untimely.

I. FACTS AND PROCEDURAL BACKGROUND

Chandler filed his § 1983 complaint in July 2010. The complaint listed

several LMPD police officers as defendants, but in February 2012 Chandler

voluntarily dismissed his claims against all individually named officers save for

Handy and Sargent Jay Pierce (Pierce).

Chandler’s complaint alleged the following facts. On September 28,

1993, Percy Phillips (Phillips) murdered Brenda Whitfield (Whitfield) while she

was working as a clerk at a Chevron gas station in Louisville. Phillips entered

the gas station at approximately 10:15 pm and waited for the only other

individual in the store to leave. Phillips then went to the cooler, grabbed a

bottle of malt liquor, and placed it on the checkout counter. When Whitfield

3 opened the cash register to give Phillips change, he shot her in the face and

stole the paltry amount of money in the register. When Phillips fled the scene,

he left the malt liquor bottle, which had his fingerprint on it, and his hat

containing a least one hair in it. In addition, the station’s video surveillance

captured the entire incident, and two eyewitnesses saw Phillips at the scene:

the individual who left the store just before the shooting and an individual who

saw Phillips flee the scene while pumping gas.

Handy was assigned as the lead detective in Whitfield’s murder case and

was responsible for the investigation. Handy committed unconscionable and

egregious misconduct during the investigation which ultimately led to

Chandler’s wrongful conviction. That misconduct included: recording over the

surveillance footage depicting the robbery and murder; mischaracterizing

and/or omitting information provided by witnesses; disregarding the fact that a

fingerprint analyst determined that none of the latent fingerprints found on the

bottle of malt liquor matched Chandler’s fingerprints; disregarding the fact that

a forensic examiner determined Chandler’s hair did not match the hair found

in the cap left by the shooter at the scene; coercing Chandler’s alibi witnesses

into changing their statements; and using improper photographic lineups.

Handy also improperly coerced Chandler into providing a false

confession. Chandler discovered he was wanted by police after seeing his

photograph on the news several days after the shooting and voluntarily went to

the police station without counsel to clear his name. Chandler was subjected

to an improper polygraph examination after his initial interrogation and was

4 falsely told he had failed it. He was then subjected to an “aggressive” two-hour

interrogation by Handy and Pierce during which they confronted him with

several pieces of “evidence” they had proving his guilt, each of which were lies.

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Mark Handy v. louisville/jefferson County Metro Government, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mark-handy-v-louisvillejefferson-county-metro-government-ky-2024.