Phyllis Roach v. Kentucky Parole Board

CourtKentucky Supreme Court
DecidedAugust 16, 2018
Docket2017-SC-0250
StatusUnpublished

This text of Phyllis Roach v. Kentucky Parole Board (Phyllis Roach v. Kentucky Parole Board) 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
Phyllis Roach v. Kentucky Parole Board, (Ky. 2018).

Opinion

RENDERED: AUGUST 16, 2018 TO BE PUBLISHED

of 2017-SC-000250-DG

DC PHYLLIS ROACH APPELLANT

ON REVIEW FROM COURT OF APPEALS V. CASE NOS. 2015-CA-001595-MR AND 2015-CA-001994-MR FRANKLIN CIRCUIT COURT NO. 15-CI-00067

KENTUCKY PAROLE BOARD APPELLEES and JUSTICE 86 PUBLIC SAFETY.CABINET, DEPARTMENT OF CORRECTIONS, COMMONWEALTH OF KENTUCKY

OPINION OF THE COURT BY JUSTICE CUNNINGHAM

AFFIRMING

On January 14, 2002, facing indictments for eighteen (18) charges of sex

crimes that allegedly occurred between 1987 and 1991, Appellant, Phyllis

Roach, pled guilty to one count of sodomy in the second degree. On February

27, 2002, Roach was sentenced to ten years’ imprisonment by the Meade

Circuit Court, with a three-year conditional discharge period following her

release pursuant to Kentucky Revised Statutes (KRS) 532.043. Roach was

released on or about March 30, 2011 and began postincarceration supervision

pursuant to KRS 532.043. On July 19, 2011, Roach was charged with violating the terms of her

postincarceration supervision. At her preliminary parole revocation hearing.

Roach argued that the supervision statute did not apply to her because KRS

532.043 did not exist until July 15, 1998, at least seven years after she

committed sodomy. Despite defense counsel’s argument, the Administrative

Law Judge (“ALJ”) found that KRS 532.043 applied to Roach and found

probable cause that Roach violated the terms of her supervision. The Parole

Board adopted the ALJ’s recommended order and sentenced Roach to serve the

remainder of her conditional discharge period, fourteen months, incarcerated

in the Kentucky Correctional Institution for Women in Shelby County.

After nine months of incarceration. Roach petitioned the Shelby Circuit

Court for writ of habeas corpus. The Shelby Circuit found that the conditional

discharge part of Roach’s original sentence imposed by the Meade Circuit was

void ab initio, as it was an ex post facto application of KRS 532.043 to Roach’s

crime. Accordingly, the court granted Roach’s petition and ordered her release.

Thereafter, Roach filed a civil lawsuit against the Kentucky Parole Board

in Franklin Circuit Court, seeking compensatory and punitive damages for her

“wrongful incarceration.” However, the Franklin Circuit Court found that the

Kentucky Board of Claims had jurisdiction for civil claims against the

Commonwealth, not the Franklin Circuit. So, the court dismissed Roach’s

claims and suggested she refile before the Board of Claims.

Roach then filed a complaint with the Board of Claims, which rejected

her claims, asserting: (1) the Board of Claims does not have subject-matter jurisdiction over intentional torts like “false imprisonment”; (2) the Parole

Board did not have a duty to question and disobey the Meade Circuit and the

ALJ’s facially valid orders; and (3) if the Parole Board did have the duty to

analyze the legality of such court orders, then that would be a discretionary act

of the Parole Board, rather than ministerial.

Roach appealed the dismissal to the Franklin Circuit, which reversed the

Board of Claims and found that the Parole Board was grossly negligent in

applying an unconstitutional sentence. The Parole Board appealed to the

Court of Appeals. The Court of Appeals reversed the Franklin Circuit, holding

that the Parole Board’s revocation hearing—a quasi-judicial function—was a

discretionary act allotting the Parole Board absolute immunity from liability for

its decisions whether to grant, deny, or revoke parole. The Court of Appeals

held that the Board of Claims only has jurisdiction to award damages for “the

negligent performance of ministerial acts,” KRS 49.070(2) (formerly KRS

44.073(2)), rather than discretionary acts. It therefore held that the Board of

Claims had properly dismissed Roach’s suit. Roach appealed to this Court and

we granted discretionary review.

Analysis

“[U]pon judicial review, deference extends to agency fact-finding.

However, matters of law, including the interpretation and construction of

statutes[,] are . . . within the province of the judicial branch of government.”

Board of Educ. of Fayette Cnty. v. Hurley-Richards, 396 S.W.3d 879, 882 (Ky.

2013). However, a reviewing court may reverse and remand the Parole Board’s order as to determinations of fact, in whole or in part, if it finds that the Parole

Board’s final order is: “(a) In violation of constitutional or statutory provisions; .

. . (c) Without support of substantial evidence on the whole record; [or] (d)

Arbitrary, capricious, or characterized by abuse of discretion . . . KRS

13B. 150(2). Courts review agency determinations of law de novo. Kentucky

Occupational Safety and Health Review Comm’n v. Estill Cnty. Fiscal Court, 503

S.W.3d 924, 927 (Ky. 2016).

KRS 532.043

The parties agree that Roach was improperly subjected to three years of

sex offender conditional discharge requirements under KRS 532.043 by the

Meade Circuit Court’s order, because that statute was not in effect until July

15, 1998, which was at least seven years after her offense. Although former

KRS 532.043(6) stated that it applied to those who plead or were convicted

after July 15, 1998, such a rule is an unconstitutional ex post facto application

under both the federal constitution and this Commonwealth’s constitution,

which “aggravates or increases the punishment for a crime as compared to the

punishment when the crime was committed . . . .” Buck v. Commonwealth, 308

S.W.3d 661, 664 (Ky. 2010) (citing Purvis v. Commonwealth, 14 S.W.3d 21, 23

(Ky. 2000)); U.S. Const, art. I, § 10, cl. 1; Ky. Const. § 19(1). Thus, it was

improper for the Meade Circuit Court to subject Roach to the postincarceration

supervision requirements of KRS 532.043 and to require the Parole Board to

punish Roach for violation of said requirements pursuant to KRS 439.330(l)(e).

Therefore, the Shelby Circuit Court properly granted Roach’s habeas petition. because the Meade Circuit Court’s order had erroneously imposed KRS

532.043 postincarceration requirements upon Roach.

Discretionary or Ministerial Act?

“Whether fault can be apportioned against someone with absolute

immunity from liability is determined by construing the [applicable] statute.”

Jefferson Cnty. Com. Attorney's Office v.

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