Mid South Capital Partners, Lp v. Bryan Adkins

CourtCourt of Appeals of Kentucky
DecidedDecember 17, 2020
Docket2019 CA 001764
StatusUnknown

This text of Mid South Capital Partners, Lp v. Bryan Adkins (Mid South Capital Partners, Lp v. Bryan Adkins) 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
Mid South Capital Partners, Lp v. Bryan Adkins, (Ky. Ct. App. 2020).

Opinion

RENDERED: DECEMBER 18, 2020; 10:00 A.M. TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2019-CA-1764-MR

MID SOUTH CAPITAL PARTNERS, LP APPELLANT

APPEAL FROM BOYD CIRCUIT COURT v. HONORABLE JOHN F. VINCENT, JUDGE ACTION NO. 17-CI-00162

BRYAN ADKINS; UNKNOWN SPOUSE, IF ANY, OF BRYAN ADKINS; CAPITAL ONE BANK; AND COMMONWEALTH OF KENTUCKY, COUNTY OF BOYD APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: ACREE, DIXON, AND K. THOMPSON, JUDGES.

DIXON, JUDGE: Mid South Capital Partners, LP (“Mid South”) appeals from the

final judgment and order of sale entered on October 25, 2019, by the Boyd Circuit

Court. Following a careful review of the brief, record, and law, we affirm. FACTS AND PROCEDURAL BACKGROUND

Mid South purchased two certificates of delinquency (“COD”)

encumbering the real property of Bryan Adkins for unpaid ad valorem taxes for the

2011 and 2012 tax years. The face value of the COD for the 2011 tax year was

$269.76; the face value of the COD for the 2012 tax year was $261.15. After

unsuccessful prelitigation debt collection efforts, Mid South filed the underlying

complaint. Its litigation efforts culminated in the final judgment and order of sale

awarding it certain fees and costs. Although the court granted judgment for the full

amounts of the CODs, it did not award all attorney’s fees and costs presented. Mid

South requested prelitigation attorney’s fees of $391.50, litigation attorney’s fees

of $2,804.12, and litigation costs of $704.79. Finding these amounts to be

unreasonable in relation to the amount of the CODs, the trial court only allowed

prelitigation attorney’s fees of $200.00, litigation attorney’s fees of $400.00, and

litigation costs of $415.97. This appeal followed.

STANDARD OF REVIEW

Unless otherwise directed by statute, the amount of an award of

attorney’s fees is within the trial court’s discretion. King v. Grecco, 111 S.W.3d

877, 883 (Ky. App. 2002), superseded by statute on other grounds as stated in

Meece v. Feldman Lumber Co., 290 S.W.3d 631 (Ky. 2009). “The test for abuse

of discretion is whether the trial judge’s decision was arbitrary, unreasonable,

-2- unfair, or unsupported by sound legal principles.” Goodyear Tire and Rubber Co.

v. Thompson, 11 S.W.3d 575, 581 (Ky. 2000) (citation omitted). “When a trial

court is considering whether to award attorney fees and costs and/or how much to

award, the trial court’s decision should be guided by the purpose and the intent of

providing an award of attorney fees and costs[.]” Alexander v. S & M Motors, Inc.,

28 S.W.3d 303, 305 (Ky. 2000).

ATTORNEY’S FEES AND COSTS

On appeal, Mid South argues the trial court abused its discretion by

awarding reduced attorney’s fees and costs contrary to the legislative intent and

mandates of KRS1 134.452. This statute clearly distinguishes three types of

attorney’s fees which may be awarded for collection efforts on a COD. The first

type of attorney’s fee is a prelitigation fee related to a graduated percentage of the

tax bill. KRS 134.452(1)(c)2.a. The second type of attorney’s fee concerns

prelitigation fees for a third-party purchaser owning more than one COD relating

to a single taxpayer and is limited to one-and-a-half times the maximum permitted

by KRS 134.452(1)(c)2.a. KRS 134.452(1)(c)2.b. The third type is an award for

enforcement or protection of a COD through litigation. KRS 134.452(3). Unlike

prelitigation fees, however, the litigation fees are not expressly linked to the

amount of the underlying tax bill, and there is no precise formula for determining

1 Kentucky Revised Statutes.

-3- the amount. KRS 134.452(3) only states that the fees must be actual and

reasonable.2 All three types of attorney’s fees are at issue in the case herein.

As there is no dispute that Mid South is entitled to an award of

attorney’s fees, the question is whether the trial court erred when it did not award

the entire amount requested. Mid South directs us to KRS 134.452(5), which

provides:

The General Assembly recognizes that third-party purchasers play an important role in the delinquent tax collection system, allowing taxing districts to receive needed funds on a timely basis. The General Assembly has carefully considered the fees and charges authorized by this section, and has determined that the amounts established are reasonable based on the costs of collection and fees and charges incurred in litigation.

2 KRS 134.452(3)(b) states:

For purposes of this subsection:

1. Actual attorneys’ litigation fees up to two thousand dollars ($2,000) may be reasonable if the fees are based upon documented work performed at a rate commensurate with hourly rates customarily charged by private attorneys in that jurisdiction for similar services. . . .

2. Any attorneys’ litigation fee in excess of two thousand dollars ($2,000) shall be allowed if authorized by the court upon a finding that the third-party purchaser incurred actual attorneys’ litigation fees in excess of two thousand dollars ($2,000) and that those attorneys’ litigation fees were warranted based upon the complexity of the issues presented in the litigation.

(Emphasis added.) This language indicates an award of attorney’s fees is permitted if the amount is reasonable and warranted. Contrary to Mid South’s assertions, this language does not create a presumption of reasonableness of charges for attorney’s fees up to two thousand dollars.

-4- (Emphasis added.) Mid South argues this provision creates a presumption of

entitlement to attorney’s fees presented in connection with collection efforts under

this statute. We disagree with Mid South’s contention that the trial court was

mandated by this subsection and/or statute to approve the full amount of the

attorney’s fees and costs presented so long as they do not exceed the maximum

amounts contained in this statute. Rather, it appears from the text of this

subsection that its purpose is to declare that the legislature found its own calculated

amounts detailed in this statute to be reasonable ceilings for recovery.

There is a dearth of published case law interpreting the effect of KRS

134.452 upon the determination of appropriate awards of attorney’s fees and costs

in association with collection efforts on a COD. Nevertheless, we hold that the

proper method for determining actual and reasonable attorney’s fees pursuant to

KRS 134.452

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Related

Meyers v. Chapman Printing Co., Inc.
840 S.W.2d 814 (Kentucky Supreme Court, 1992)
Alexander v. S & M MOTORS, INC.
28 S.W.3d 303 (Kentucky Supreme Court, 2000)
King v. Grecco
111 S.W.3d 877 (Court of Appeals of Kentucky, 2002)
Goodyear Tire and Rubber Co. v. Thompson
11 S.W.3d 575 (Kentucky Supreme Court, 2000)
Meece v. Feldman Lumber Co.
290 S.W.3d 631 (Kentucky Supreme Court, 2009)
Bryan v. Harvin
550 S.W.2d 569 (Court of Appeals of Kentucky, 1977)
Axton v. Vance
269 S.W. 534 (Court of Appeals of Kentucky, 1925)

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