Stephen E. Diebold v. Mary Jane Diebold, Individually and as Administrator of the Estate of Thomas C. Diebold

CourtCourt of Appeals of Kentucky
DecidedNovember 21, 2025
Docket2024-CA-1449
StatusUnpublished

This text of Stephen E. Diebold v. Mary Jane Diebold, Individually and as Administrator of the Estate of Thomas C. Diebold (Stephen E. Diebold v. Mary Jane Diebold, Individually and as Administrator of the Estate of Thomas C. Diebold) 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
Stephen E. Diebold v. Mary Jane Diebold, Individually and as Administrator of the Estate of Thomas C. Diebold, (Ky. Ct. App. 2025).

Opinion

RENDERED: NOVEMBER 21, 2025; 10:00 A.M. NOT TO BE PUBLISHED

Commonwealth of Kentucky Court of Appeals

NO. 2024-CA-1449-MR

STEPHEN E. DIEBOLD APPELLANT

APPEAL FROM JEFFRSON CIRCUIT COURT v. HONORABLE ANNIE O’CONNELL, JUDGE ACTION NO. 18-CI-003303

MARY JANE DIEBOLD, INDIVIDUALLY AND AS SUCCESSOR AND ADMINISTRATRIX OF THE ESTATE OF THOMAS DIEBOLD APPELLEES

OPINION REVERSING AND REMANDING

** ** ** ** **

BEFORE: CETRULO, KAREM, AND MOYNAHAN, JUDGES.

KAREM, JUDGE: Stephen E. Diebold (“Stephen”) appeals from a Jefferson

Circuit Court order denying his motion for summary judgment and granting

judgment on the pleadings to Mary Jane Diebold, individually and in her capacity as successor administratrix of the Estate of Thomas C. Diebold, and the Estate of

Thomas C. Diebold (“Mary and the Estate” or “the appellees”). The case arose

from a dispute over the valuation and tax consequences of Stephen’s purchase of

Thomas’s shares, following Thomas’s death, in two limited liability companies. In

a previous appeal, a panel of this Court held that a release provision in the

purchase agreement barred Mary’s and the Estate’s claims against Stephen. See

Diebold v. Diebold, No. 2020-CA-0051-MR, 2022 WL 3129784 (Ky. App. Aug. 5,

2022). The sole issue in the present appeal is whether Stephen is entitled to

recover attorney’s fees and costs under the terms of that agreement.

FACTUAL AND PROCEDURAL BACKGROUND

Stephen and his late brother Thomas were members of two Kentucky

limited liability companies. Id. at *1. On March 22, 2005, they entered into a

Buy-Sell Agreement, which provided that upon the death of Stephen or Thomas,

the deceased member’s estate would be required to sell the deceased’s ownership

interests in both LLCs to the surviving member. Id. “The Buy-Sell Agreement

included a formula for valuing the deceased members’ ownership interests sold

thereunder.” Id.

Thomas died in 2014, and Stephen bought his shares in the LLCs in

2015, pursuant to an agreement (“the Purchase Agreement”) he signed with the

Mary and the Estate. The Purchase Agreement incorporated the formula in the

-2- Buy-Sell Agreement to value Thomas’s ownership interests in the LLCs. Id. The

Purchase Agreement contained a broad release of liability (“the Release”) between

the parties, as well as an indemnification provision.

After the Estate filed a tax return, it was audited by the IRS, which

determined that the price Stephen paid for the LLC shares was below fair market

value. Id. The Estate reached a settlement with the IRS, resulting in an additional

$1.4 million in taxes on the Estate. The Estate was able to use an estate tax

exemption to pay this amount, but it had the effect of reducing the total tax

exemption available to Mary. Id.

According to Stephen, Mary and the Estate demanded that he

compensate them for the difference between what he paid for the LLC shares and

their fair market value and/or for the additional taxes paid by the Estate. On June

8, 2018, Stephen filed a petition for declaratory judgment, arguing that (1) any

claims of this type were barred by the Release contained in the Purchase

Agreement; and (2) if the Estate or Mary asserted any claims against him, it would

constitute a breach of the Release and would entitle him to indemnification for his

attorney’s fees and costs under the indemnification provision, Section 9.2, of the

Agreement. Id. Count IV of his petition stated:

If MJ Diebold or the Estate asserts any claim against Petitioner, it would constitute a breach of the Release provision of the Purchase Agreement. As a result, Petitioner would be entitled to indemnification under

-3- Section 9 of the Purchase Agreement by MJ Diebold and the Estate for any expenses, including without limitation, taxes and attorneys’ fees, incurred in defense of the claims.

Petitioner requests a declaration by this Court that (i) if MJ Diebold or the Estate asserts any claim or action against Petitioner, it would constitute a breach of the Purchase Agreement; and (ii) in such case, Petitioner is entitled to indemnification, including its attorneys’ fees incurred in defending such actions, pursuant to Section 9 of the Purchase Agreement.

Mary and the Estate filed a response and several counterclaims. The

counterclaims sought reformation and/or rescission of the Purchase Agreement

based upon mutual or unilateral mistake and reimbursement in full by Stephen for

the difference between the amount he paid for the shares and their value as

determined by the IRS, as well as the additional taxes; rescission of the Purchase

Agreement based on constructive fraud committed by Stephen; and

indemnification from Stephen for the tax impact of the purchase.

Stephen filed a motion for judgment on the pleadings. On December

20, 2019, the circuit court entered an opinion and order granting Stephen’s motion

and dismissing the Estate and Mary’s counterclaims. The circuit court determined

that Stephen owed no fiduciary duty to Mary and that the Release in the Purchase

Agreement barred the Estate and Mary’s other counterclaims against Stephen. Id.

On January 2, 2020, Stephen filed a motion for an award of attorney’s

fees and costs, arguing that “the Estate and Mary breached the Purchase

-4- Agreement by bringing the counterclaims, thus entitling Stephen to attorney’s fees

and costs per Section 9.2 [the indemnification provision] of the Purchase

Agreement.” Id. at *4.

A few days later, the Estate and Mary filed a notice of appeal from the

December 20, 2019, opinion and order. Stephen moved to dismiss the appeal,

arguing that it was interlocutory because the court had not yet decided his claim for

indemnification under Section 9.2. The circuit court entered an order holding the

case in abeyance until this Court ruled on the motion to dismiss the appeal. The

Court of Appeals denied the motion to dismiss in an order entered on May 20,

2020.

On September 9, 2020, the circuit court entered an order denying

Stephen’s motion for attorney’s fees and costs on the grounds that it no longer had

jurisdiction over the matter because the case was before the Court of Appeals.

On August 5, 2022, a panel of this Court held that the December 20,

2019 opinion and order granting judgment on the pleadings was not interlocutory

and had fully adjudicated the Estate and Mary’s claims against Stephen. It

affirmed the circuit court’s opinion and order, which it treated as a summary

judgment, on the grounds (1) that the claim that Stephen breached his fiduciary

duty to the Estate was unsupported by any material issue of fact and (2) the claims

of mutual mistake, unilateral mistake, and indemnification all came within the

-5- ambit of the Release. After resolving the substantive issues, the Court stated: “As

we have resolved the parties’ appeals, the circuit court may now reach the merits of

Stephen’s indemnification claim for attorney’s fees and costs under the Purchase

Agreement.” Id. at *8.

Accordingly, Stephen thereafter filed a motion for summary judgment

on his Count IV claim for attorney’s fees and costs. The circuit court entered an

order on November 27, 2024, denying the motion and granting judgment on the

pleadings to Mary and the Estate. Its order states in pertinent part:

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Stephen E. Diebold v. Mary Jane Diebold, Individually and as Administrator of the Estate of Thomas C. Diebold, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stephen-e-diebold-v-mary-jane-diebold-individually-and-as-administrator-kyctapp-2025.