Owen Nation v. John A.G. Paddock

CourtCourt of Appeals of Kentucky
DecidedFebruary 29, 2024
Docket2023 CA 000211
StatusUnknown

This text of Owen Nation v. John A.G. Paddock (Owen Nation v. John A.G. Paddock) 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
Owen Nation v. John A.G. Paddock, (Ky. Ct. App. 2024).

Opinion

RENDERED: MARCH 1, 2024; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2023-CA-0211-MR

OWEN NATION AND CAROL NATION APPELLANTS

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE ANNIE O’CONNELL, JUDGE ACTION NO. 18-CI-006007

JOHN A.G. PADDOCK APPELLEE

OPINION AFFIRMING

** ** ** ** **

BEFORE: THOMPSON, CHIEF JUDGE; EASTON AND GOODWINE, JUDGES.

EASTON, JUDGE: The Appellants (the “Nations”) ask us to reverse the summary

judgment granted to their former attorney, the Appellee (“Paddock”). Because the

circuit court correctly concluded that the applicable one-year statute of limitations

barred the Nations’ claims, we affirm. FACTUAL AND PROCEDURAL BACKGROUND

Paddock was an attorney for the Nations for over thirty years. Issues

arose about his services between 2010 and 2015. The Nations believed Paddock

had not handled various matters properly. There was a claim about insurance

proceeds paid with respect to a property the Nations were buying. When another

property was sold, Paddock retained a large sum, supposedly without explanation.

There was another case involving title to a property, which Paddock had settled,

supposedly without approval by the Nations. The Nations had also paid a fee of

$5,000 to Paddock for filing a patent on a gaming invention, but the Nations never

saw Paddock do anything on this, and they hired another attorney to complete the

work.

On July 31, 2015, new counsel (who still represents the Nations in this

matter) sent a letter to Paddock terminating his services and requesting return of

client files. The Nations filed a bar compliant on November 13, 2015. Part of the

purpose of the bar complaint was to obtain the Nations’ files. The bar complaint

would eventually be summarily dismissed without any findings on January 8,

2018.

As the bar complaint proceeded, the Nations filed a circuit court case1

for replevin. Replevin is an ancient common law action to obtain an order from a

1 Jefferson Circuit Court Civil Action No. 16-CI-005528.

-2- court for the return of personal property. Replevin included the ability to seek

damages for any wrongful detention of the property. See Halcomb v. Phipps, 240

S.W. 363 (Ky. 1922). This common law action has been largely displaced by

codification of the right to obtain possession. See, e.g., KRS2 425.011 et seq.

(statutes governing writs of possession).

The replevin case was filed on November 7, 2016. While these

overlapping matters proceeded, documents were provided by Paddock. A hearing

on a motion to dismiss the replevin action took place on June 8, 2017. Before that

hearing, on May 22, 2017, the Nations’ counsel received the documents sought,

and he acknowledged reviewing them on June 7, 2017, the day before the hearing.

The circuit court dismissed the replevin action by Order3 entered on June 20, 2017.

The Nations did not appeal that dismissal.

This present case was not filed until October 15, 2018, more than one

year and almost four months later. The Complaint mirrors the allegations of

2 Kentucky Revised Statutes. 3 The circuit court concluded that it did not have subject matter jurisdiction of the replevin claim because the simultaneous bar complaint proceeding addressed Paddock’s retention of the same documents. The circuit court had subject matter jurisdiction over the replevin claim. A cited case does not suggest otherwise. In Rose v. Winters, Yonkers & Rousselle, P.S.C., 391 S.W.3d 871 (Ky. 2012), the Kentucky Supreme Court simply held that a violation of an ethical rule by itself cannot be the basis for a civil suit against an attorney, although such a violation may serve as evidence in such a civil suit. This does not mean the circuit court could not order an attorney to return property of a client, which does not require a proven violation of an ethical rule. Of course, the circuit court certainly could have chosen to defer to the bar proceedings as a matter of comity or for judicial economy before acting simultaneously. The reason for the dismissal of the replevin action is not germane to this case, although the timing of the dismissal may be relevant.

-3- wrongdoing in the 2015 bar complaint as can be seen from comparison of the prior

bar complaint and Paragraphs 13-25 of the Complaint. This includes explanation

of the damages sustained (with amounts) because of Paddock’s alleged actions.

The circuit court entered summary judgment because the one-year statute of

limitations barred the Compliant. This appeal follows.

STANDARD OF REVIEW

“The standard of review on appeal of a summary judgment is whether

the circuit judge correctly found that there were no issues as to any material fact

and that the moving party was entitled to a judgment as a matter of law.” Pearson

ex rel. Trent v. Nat’l Feeding Systems, Inc., 90 S.W.3d 46, 49 (Ky. 2002).

Summary judgment is only proper when “it would be impossible for the

respondent to produce evidence at the trial warranting a judgment in his favor.”

Steelvest, Inc. v. Scansteel Service Center, Inc., 807 S.W.2d 476, 480 (Ky. 1991).

In ruling on a motion for summary judgment, the court is required to construe the

record “in a light most favorable to the party opposing the motion . . . and all

doubts are to be resolved in his favor.” Id.

As summary judgment involves only legal questions if there are no

genuine issues of material fact, an appellate court does not defer to the trial court’s

decision and will review the legal issue de novo. Lewis v. B & R Corp., 56 S.W.3d

432, 436 (Ky. App. 2001). In this case, there were no disputed questions of fact as

-4- to when certain events occurred, and these undisputed facts must be applied to the

legal question of the application of a statute of limitations.

ANALYSIS

The sole issue for this appeal is the application of the statute of

limitations.4 KRS 413.245 states in relevant part:

Notwithstanding any other prescribed limitation of actions which might otherwise appear applicable, . . . a civil action, whether brought in tort or contract, arising out of any act or omission in rendering, or failing to render, professional services for others shall be brought within one (1) year from the date of the occurrence or from the date when the cause of action was, or reasonably should have been, discovered by the party injured.

We first see that, regardless of what the action against the attorney is called, this

one-year limitation period applies. For example, a claim that the attorney acted

fraudulently is within the one-year limitation period, not the five-year period for

4 We decline to address at length the alternate argument advanced by Paddock of res judicata as it is not necessary to affirm the circuit court. The bar complaint proceedings addressed violation of ethical rules. The bar association could not adjudicate damages to be recovered by clients for malpractice, which does not require violation of a specific ethical rule. In this case, the bar association summarily dismissed the bar complaint without substantial explanation and made no findings.

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Related

Doe v. Golden & Walters, PLLC
173 S.W.3d 260 (Court of Appeals of Kentucky, 2005)
Lewis v. B & R CORPORATION
56 S.W.3d 432 (Court of Appeals of Kentucky, 2001)
Pearson Ex Rel. Trent v. National Feeding Systems, Inc.
90 S.W.3d 46 (Kentucky Supreme Court, 2002)
Steelvest, Inc. v. Scansteel Service Center, Inc.
807 S.W.2d 476 (Kentucky Supreme Court, 1991)
Yeoman v. Com., Health Policy Bd.
983 S.W.2d 459 (Kentucky Supreme Court, 1998)
Adams v. Ison
249 S.W.2d 791 (Court of Appeals of Kentucky (pre-1976), 1952)
Michels v. Sklavos
869 S.W.2d 728 (Kentucky Supreme Court, 1994)
Kentucky Bar Ass'n v. Greene
386 S.W.3d 717 (Kentucky Supreme Court, 2012)
Rose v. Winters, Yonker & Rousselle, P.S.C.
391 S.W.3d 871 (Court of Appeals of Kentucky, 2012)
Abel v. Austin
411 S.W.3d 728 (Kentucky Supreme Court, 2013)
Saalwaechter v. Carroll
525 S.W.3d 100 (Court of Appeals of Kentucky, 2017)
Halcomb v. Phipps
240 S.W. 363 (Court of Appeals of Kentucky, 1922)

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Bluebook (online)
Owen Nation v. John A.G. Paddock, Counsel Stack Legal Research, https://law.counselstack.com/opinion/owen-nation-v-john-ag-paddock-kyctapp-2024.