Robert Arnold v. University Medical Center, Inc. D/B/A U of L Health

CourtCourt of Appeals of Kentucky
DecidedFebruary 6, 2026
Docket2024-CA-1189
StatusUnpublished

This text of Robert Arnold v. University Medical Center, Inc. D/B/A U of L Health (Robert Arnold v. University Medical Center, Inc. D/B/A U of L Health) 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
Robert Arnold v. University Medical Center, Inc. D/B/A U of L Health, (Ky. Ct. App. 2026).

Opinion

RENDERED: FEBRUARY 6, 2026; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals NO. 2024-CA-1189-MR

ROBERT ARNOLD APPELLANT

APPEAL FROM JEFFERSON CIRCUIT COURT v. HONORABLE ANN BAILEY SMITH, JUDGE ACTION NO. 23-CI-007723

UNIVERSITY MEDICAL CENTER, INC. D/B/A U OF L HEALTH; EC OPCO MOUNT WASHINGTON, LLC, D/B/A INSPIRATION OF MOUNT WASHINGTON, A/K/A ELMCROFT OF MOUNT WASHINGTON; JEFFREY A. BAKER, MD; LOUISVILLE ALZHEIMER’S INVESTORS, LLC, D/B/A THE LANTERN AT MORNING POINTE OF LOUISVILLE; TARYN MORAN, RN, SANE; TYLER BAYERS, MD; AND UNKNOWN DEFENDANTS WHO ARE AGENTS/EMPLOYEES OF ELMCROFT APPELLEES

OPINION AFFIRMING

** ** ** ** **

BEFORE: CALDWELL, MCNEILL, AND TAYLOR, JUDGES. CALDWELL, JUDGE: Robert Arnold (“Dr. Arnold”) appeals from the dismissal

of his claims against the Appellees on grounds including the statute of limitations.

We affirm.

FACTS

On December 14, 2023, Dr. Arnold filed a lawsuit against Appellees:

1) EC Opco Mount Washington, LLC, d/b/a Inspirations of Mount Washington,

a/k/a Elmcroft of Mount Washington (“Elmcroft”), 2) Louisville Alzheimer’s

Investors, LLC d/b/a The Lantern at Morning Pointe of Louisville (“The Lantern”),

and 3) University Medical Center, d/b/a UofL Health—University of Louisville

Hospital and Jeffrey A. Baker, MD; Tyler Bayers, MD; and Taryn Moran, RN,

SANE (collectively, “the U of L Defendants”).

Dr. Arnold’s complaint1 asserted claims relating to investigations of

allegations that Dr. Arnold had abused or assaulted his wife, Betty Arnold (“Mrs.

Arnold”), while she resided at Elmcroft and then The Lantern. He alleged that

Mrs. Arnold was diagnosed with dementia in early to mid-2021 and was placed at

Elmcroft. He further alleged the Cabinet for Health and Family Services

(“Cabinet”) had investigated allegations of abuse made while he was visiting his

wife at Elmcroft, but the Cabinet determined that these allegations were

1 Dr. Arnold amended his complaint twice. Like the parties and the trial court, we focus our attention on the allegations in the Second Amended Complaint, which we refer to simply as “the complaint” in this Opinion.

-2- unsubstantiated. The complaint provided no specific dates regarding the Cabinet’s

investigation.

Dr. Arnold also alleged that in late March 2022, Mrs. Arnold had been

transferred to The Lantern and she was seen at the University Hospital emergency

room due to suspicions that she had been physically or sexually assaulted by her

husband. He further alleged that following Mrs. Arnold’s late March 2022

emergency room visit, the Arnolds’ adult daughters had reported their suspicions

of abuse to Louisville police. He stated that the criminal investigation concluded,

with no charges filed against Dr. Arnold, on December 16, 2022.

Elmcroft, The Lantern, and the U of L Defendants (collectively, “the

Appellees”) all filed motions to dismiss based on the statute of limitations and

other grounds.

The circuit court granted the motions to dismiss in an opinion and

order. It concluded that a one-year statute of limitations applied to all of Dr.

Arnold’s claims against the Appellees—including claims for personal injury and

medical negligence as well as any defamation claims. It rejected Dr. Arnold’s

argument that his lawsuit was timely filed because he did not know the full extent

of his damages until the criminal investigation concluded.

Dr. Arnold filed a timely appeal. Further facts will be set forth as

needed in our analysis.

-3- First, we consider the effect of his appellant brief’s lack of compliance

with the Kentucky Rules of Appellate Procedure (“RAP”) in several respects.

ANALYSIS

Dr. Arnold’s Brief Fails to Fully Comply with Appellate Briefing Rules

As noted in the U of L Defendants’ appellee brief, Dr. Arnold’s

appellant brief does not fully comply with RAP. For instance, the appellant brief

provides no specific citations to pages of the written record or to any portion of a

hearing videorecording. See RAP 32(A)(3)-(4); RAP 31(E)(3)-(4). Also, the

opinion and order of dismissal from which the appeal stems was not placed

“immediately after the appendix list so that it is most readily available to the

court.” RAP 32(E)(1)(a). And the index to the appendix to appellant’s brief does

not state where the appended items may be found in the record. RAP 32(E)(1)(d).

Moreover, the appellant brief does not “contain at the beginning of the

argument a statement with reference to the record showing whether the issue was

properly preserved for review and, if so, in what manner.” RAP 32(A)(4). And

despite at least some RAP violations being pointed out in an appellee brief, Dr.

Arnold did not file a reply brief correcting the deficiencies of his appellant brief.

Failure to comply with appellate briefing rules can result in serious

consequences. For example, this Court has discretion to strike a brief and dismiss

the appeal for substantial failure to comply with appellate briefing rules. RAP

-4- 10(B); RAP 31(H); J.P.T. v. Cabinet for Health and Family Services, 689 S.W.3d

149, 153 (Ky. App. 2024).

Despite the failure to fully comply with our appellate briefing rules,

we decline to strike the appellant brief or to dismiss the appeal. However, to the

extent that Dr. Arnold’s brief fails to show if and how the issues he raises on

appeal were raised to the trial court and thus preserved for our review, we may

review such issues solely for palpable error resulting in manifest injustice. See id.

(citing Ford v. Commonwealth, 628 S.W.3d 147, 155 (Ky. 2021)).2

Standards of Review

We review de novo (without deference) the trial court’s granting

Appellees’ motions to dismiss based on failure to state a claim for which relief can

be granted, see CR3 12.02(f), and on failure to timely file suit within the statute of

limitations. Shaw v. Handy, 588 S.W.3d 459, 461 (Ky. App. 2019). Moreover, we

keep in mind that CR 12.02(f) motions may be properly granted only if, accepting

all of the plaintiff’s allegations as true and drawing all reasonable inferences in the

2 Based upon a Westlaw search, Kentucky appellate courts have not previously, explicitly found that Dr. Arnold’s counsel failed to substantially comply with appellate briefing rules. Nonetheless, though we leniently decline to formally impose sanctions for the lack of full compliance with appellate briefing rules in this instance, we remind counsel that we are not obligated to be so lenient in the future. We direct counsel’s attention to the Rules of Appellate Procedure and helpful resources, such as briefing checklists and a basic appellate handbook which may be accessed via our Court’s website, https://www.kycourts.gov/Courts/Court-of- Appeals (last viewed Sep. 19, 2025). 3 Kentucky Rules of Civil Procedure.

-5- plaintiff’s favor, “the pleading party would not be entitled to relief under any set of

facts which could be proved in support of his claim[.]” Id. (quoting James v.

Wilson, 95 S.W.3d 875, 883 (Ky. App. 2002)).

In other words, when ruling upon a CR 12.02(f) motion to dismiss for

failure to state a claim: “the circuit court is not required to make any factual

determination; rather, the question is purely a matter of law. Stated another way,

the court must ask if the facts alleged in the complaint can be proved, would the

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