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Darryl Shields v. Mt. Lebanon Kentucky, LLC

2026-08-28

Summary

Holding. The Jefferson Circuit Court erred in holding that district courts have exclusive jurisdiction over all Uniform Residential Landlord and Tenant Act claims; because Shields' complaint sought injunctive relief (which is equitable in nature and outside district court jurisdiction) and alleged damages exceeding $5,000, the circuit court had subject-matter jurisdiction. The decision is reversed and remanded.

Darryl Shields, a tenant receiving federal housing assistance, filed a complaint against his landlord Mt. Lebanon Kentucky, LLC and its property manager alleging retaliation under Kentucky's Uniform Residential Landlord and Tenant Act. After Shields began organizing a tenants' union, the landlord sent him multiple notices threatening eviction over alleged rent delinquencies and utility issues. Shields also sought injunctive relief, including temporary and permanent injunctions. The circuit court dismissed the complaint for lack of subject-matter jurisdiction, concluding that district courts have exclusive jurisdiction over all URLTA claims.

The court of appeals reversed, holding that the circuit court erred in its blanket jurisdictional ruling. The court reasoned that Kentucky circuit courts are courts of general jurisdiction over all cases not specifically vested elsewhere. Because URLTA explicitly permits courts to grant injunctive relief in certain circumstances, and district courts lack authority over equitable matters like injunctions, circuit courts retain concurrent jurisdiction over URLTA claims that seek injunctive relief. The court also determined that Shields' damages claim exceeded the $5,000 threshold that would give district courts exclusive jurisdiction. The amount in controversy was calculated to include the full monthly rent ($747) paid by both Shields and HUD combined, multiplied by three months per retaliatory instance and by the four alleged instances.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether circuit courts have exclusive or concurrent jurisdiction over Uniform Residential Landlord and Tenant Act claims
  • Whether district courts' jurisdiction over URLTA claims is exclusive or permissive given statutory language and equity jurisdiction limitations
  • Whether rent for damages-calculation purposes includes payments made by third parties like HUD on the tenant's behalf
  • Whether a tenant may recover treble rent separately for each distinct act of retaliation or only once per claim

Procedural posture

Darryl Shields appealed the Jefferson Circuit Court's dismissal of his URLTA retaliation complaint for lack of subject-matter jurisdiction.

Authorities cited

Opinion

majority opinion

RENDERED: AUGUST 28, 2026; 10:00 A.M.

TO BE PUBLISHED

Commonwealth of Kentucky

Court of Appeals

NO. 2025-CA-1110-MR

DARRYL SHIELDS APPELLANT

APPEAL FROM JEFFERSON CIRCUIT COURT

v. HONORABLE SARAH E. CLAY, JUDGE

ACTION NO. 25-CI-004044

MT. LEBANON KENTUCKY, LLC

AND HAYES GIBSON PROPERTY

SERVICES, LLC APPELLEES

OPINION

REVERSING AND REMANDING

** ** ** ** **

BEFORE: CALDWELL, L. JONES, AND KAREM, JUDGES.

CALDWELL, JUDGE: Darryl Shields (“Shields”) appeals from the Jefferson

Circuit Court’s dismissal of his claims against his landlord, Mt. Lebanon

Kentucky, LLC, and his landlord’s property manager, Hayes Gibson Property

Services, LLC (collectively, “Mt. Lebanon”). Shields brought his claims under the

Uniform Residential Landlord and Tenant Act (“URLTA”), which is codified at KRS1 383.505 to 383.715. The circuit court concluded that district courts have

exclusive jurisdiction over claims brought under URLTA. We reverse and remand.

FACTUAL AND PROCEDURAL HISTORY

The only issue Shields raises is whether the circuit court properly

dismissed his complaint on jurisdictional grounds.

Shields has resided at an apartment owned by Mt. Lebanon since

2023. Shields receives housing assistance from the United States Department of

Housing and Urban Development (“HUD”). Specifically, Shields pays $185 per

month in rent to Mt. Lebanon and HUD pays the remainder, $562 monthly.

Beginning in April 2024, Shields began organizing a tenants’ union.

Within the next year or so, Mt. Lebanon sent Shields four written notices of

deficiencies. Three notices alleged Shields owed additional rent and the fourth

alleged Shields had not kept his utility services current. The rent-based notices

stated that Mt. Lebanon “shall immediately take legal action to evict” Shields if he

did not rectify the deficiencies. See, e.g., Trial Court Record (“R.”) at 40. The

utility-based notice stated that Shields’ failure to correct the utility issue “may

force” Mt. Lebanon “to take further action and terminate your [Shields’] lease and

file [for his] eviction.” R. at 41.

1

Kentucky Revised Statutes.

-2-Shields alleges he did not owe additional rent, and the three rent-based

notices were issued in retaliation for his union activities. See KRS 383.705.2

However, Shields admitted in his complaint that he contacted the utility company

“to switch the utility services for the unit where he resides into his name” soon

after he received the utility-based notice. R. at 6.

In May 2025, Shields filed the two-count complaint at issue. Count

one alleges improper retaliation by Mt. Lebanon. Count two nonspecifically

alleges Mt. Lebanon “willfully diminished services” to Shields. R. at 8. In

addition to damages, Shields also requested injunctive relief.

Shields also filed a motion for a temporary restraining order. The

circuit court quickly issued an order denying the motion for restraining order.3 In

2

KRS 383.705 provides in relevant part:

(1) Except as provided in this section, a landlord may not retaliate by increasing

rent or decreasing services or by bringing or threatening to bring an action for

possession after:

(c) The tenant has organized or become a member of a tenant’s

union or similar organization.

(2) If the landlord acts in violation of subsection (1) of this section, the tenant is

entitled to the remedies provided in KRS 383.655 and has a defense in any

retaliatory action against him for possession. In an action by or against the tenant,

evidence of a complaint within one (1) year before the alleged act of retaliation

creates a presumption that the landlord's conduct was in retaliation . . . . 3

Shields does not contest the denial of his motion for a restraining order. We express no opinion on that decision beyond noting that Shields’ requests in his complaint for a temporary and a permanent injunction have not been resolved.

-3-that order, the court also stated it believed “circuit courts do not have subject

matter jurisdiction over . . . actions asserting violations of the URLTA, except

when they are acting in their appellate capacity.” R. at 80. The court ordered

Shields to show cause why his complaint should not be dismissed for lack of

jurisdiction.4 Unpersuaded by Shields’ response, the circuit court dismissed

Shields’ complaint for lack of jurisdiction. Shields then filed this appeal.

ANALYSIS

The sole issue before us is whether the circuit court lacked subject

matter jurisdiction over Shields’ complaint. We have examined the parties’ briefs

but have concluded that any arguments raised therein which we do not discuss in

this Opinion are irrelevant or are otherwise unnecessary for us to resolve the

narrow jurisdictional issue before us.

Determining whether the Jefferson Circuit Court has jurisdiction over

Shields’ complaint largely rests on statutory interpretation. We review issues of

statutory interpretation and jurisdiction de novo. Davis v. Davis, 563 S.W.3d 105,

108 (Ky. App. 2018).

As our Supreme Court has succinctly explained:

4

The court’s denial on the merits of Shields’ motion for a temporary restraining order is at odds with its conclusion that it lacked subject matter jurisdiction since “[t]he determination by any court that it lacks authority to decide the controversy constitutes an express declaration that it is without power to decide any other issue.” Commonwealth ex rel. Cowan v. Telcom Directories, Inc., 806 S.W.2d 638, 642 (Ky. 1991).

-4-In Kentucky, circuit courts are courts of general

jurisdiction, which means that circuit courts shall have

original jurisdiction of all justiciable causes not vested in

some other court. Jurisdiction, when used here, refers to

subject-matter jurisdiction: the authority not simply to

hear this case[,] but this kind of case. Narrowing these

broad concepts, constitutional provisions and statutes

[may] assign[ ] to the courts specific types of claims and

causes of action[.] A court acts outside its jurisdiction,

accordingly, only where [it] has not been given, by

constitutional provision or statute, the power to do

anything at all.

Davis v. Wingate, 437 S.W.3d 720, 725 (Ky. 2014) (internal quotation marks,

footnotes, and citations omitted). And, though the circuit court here seemed to

view jurisdiction as a binary, “all or nothing at all” matter, our Supreme Court has

noted that “there are times when more than one court may have subject matter

jurisdiction[.]” Nordike v. Nordike, 231 S.W.3d 733, 738 (Ky. 2007).

“In Kentucky, circuit courts are courts of general jurisdiction, which

means that circuit courts shall have original jurisdiction of all justiciable causes not

vested in some other court.” Wingate, 437 S.W.3d at 725 (italics in Wingate)

(internal quotation marks, footnotes, and citations omitted). Therefore, we must

determine whether the Jefferson Circuit Court had jurisdiction over Shields’

URLTA claims by ascertaining whether the General Assembly vested district

courts with exclusive jurisdiction over such claims.

KRS 24A.010(1) provides that a district court “is a court of limited

jurisdiction; it has original jurisdiction in all matters specified in KRS 24A.110 to

-5-24A.130.” KRS 24A.120(1) provides in relevant part that a district court has

“exclusive jurisdiction” over “[c]ivil cases in which the amount in controversy

does not exceed five thousand dollars ($5,000), exclusive of interest and costs,

except matters affecting title to real estate and matters of equity . . . .”

The General Assembly’s express statement that district courts lack

jurisdiction over “matters of equity” is in direct conflict with the circuit court’s

conclusion that district courts have exclusive jurisdiction over URLTA claims.

Shields requested injunctive relief (temporary and permanent). Various statutes

within URLTA explicitly allow a tenant (e.g., KRS 383.625(2)) or landlord (e.g.,

KRS 383.660(3)) to obtain injunctive relief. Injunctive relief is a matter of equity.

See, e.g., Bartman v. Shobe, 353 S.W.2d 550, 554 (Ky. 1962) (discussing

injunctive relief as being equitable in nature); 43A C.J.S. Injunctions § 306 (April

2026 Update) (“An injunction is an equitable remedy.”).

We have held that a party was “[o]bviously . . . correct in his assertion

that district courts are prohibited from entertaining ‘matters of equity.’” Kelley v.

Nationwide Auto Restoration, LLC, 246 S.W.3d 470, 473 (Ky. App. 2007). In

addition, the Kentucky Rules of Civil Procedure (“CR”) generally only allow

circuit courts to grant injunctions. See CR 65.01 (“A party may obtain injunctive

relief in the circuit court by (a) restraining order, (b) temporary injunction, or (c)

-6-permanent injunction in a final judgment.”) (emphasis added).5 The General

Assembly’s statement that a district court “may” exercise jurisdiction over URLTA

claims does not expressly override its statement in KRS 24A.120(1) that a district

court lacks the jurisdiction to resolve matters of equity. The language providing

that a district court “may” exercise jurisdiction over URLTA claims also does not

explicitly override the plain language of CR 65.01 providing that “[i]njunctive

relief shall not be granted in any action in the district court except as specifically

authorized by statute.” URLTA does not unambiguously and “specifically” allow

a district court to grant injunctive relief. A request for injunctive relief in an

URLTA complaint invokes the circuit court’s jurisdiction.

The circuit court relied on the principle that “[w]here the statute both

declares the unlawful act and specifies the civil remedies available to the aggrieved

party, the aggrieved party is limited to the remedy provided by the statute.” Hill v.

Kentucky Lottery Corp., 327 S.W.3d 412, 421 (Ky. 2010) (internal quotation marks

and citations omitted). That principle is sound. And the specific URLTA statutes

cited as avenues for relief by Shields in his complaint do not expressly provide for

5

The extremely narrow exception in CR 65.03(2) allowing a district judge to issue a restraining order “if no judge of that circuit court is present in the county” is clearly inapplicable here. Moreover, Shields’ complaint also requested a temporary and a permanent injunction, and such requests do not fall within the narrow, rare exception in CR 65.03(2) allowing a district court to issue a restraining order.

-7-the issuance of injunctive relief. But that general principle does not deprive circuit

courts of jurisdiction over all URLTA claims.

The circuit court did not meaningfully address the fact that URLTA

specifically envisions a tenant and a landlord being able to obtain injunctive relief,

at least for certain URLTA violations. Arguably, the lack of a specific mention of

injunctive relief in the statutes Shields relies upon in his complaint means he is not

entitled to such relief.6 However, that does not mean that circuit courts are always

deprived of jurisdiction over URLTA claims.

The fact that URLTA explicitly envisions the issuance of injunctive

relief (at least under some circumstances) greatly undercuts the trial court’s

conclusion that URLTA claims must always be decided in district courts since

district courts generally cannot grant injunctions. In short, Shields’ requests for

injunctive relief may prove to be without merit, but the circuit court erred by

holding that circuit courts always lack jurisdiction over URLTA claims. Indeed,

though involving distinguishable facts and issues from the case at hand, there are

published opinions resolving on non-lack-of subject-matter-jurisdiction grounds

URLTA claims which had been brought in circuit courts. See, e.g., Waugh v.

6

“As an appellate court, we review judgments; we do not make them.” Klein v. Flanery, 439 S.W.3d 107, 122 (Ky. 2014). The circuit court has not addressed the merits of Shields’ requests for a temporary and permanent injunction, and so we express no firm opinion on the merits of those requests.

-8-Parker, 584 S.W.3d 748 (Ky. 2019); Miller v. Cundiff, 245 S.W.3d 786 (Ky. App.

2007).

Our conclusion that circuit courts do not lack subject matter

jurisdiction over all URLTA claims is not changed by an analysis of KRS 24A.020

and KRS 383.540. KRS 24A.020 provides that “[w]hen jurisdiction over any

matter is granted to District Court by statute, such jurisdiction shall be deemed to

be exclusive unless the statute specifically states that the jurisdiction shall be

concurrent.” KRS 383.540(1) provides in relevant part that “[t]he District Courts

of this state may exercise jurisdiction over any landlord or tenant with respect to

any conduct in this state governed by KRS 383.505 to 383.715 or with respect to

any claim arising from a transaction subject to KRS 383.505 to 383.715.”

Of course, the word may in a statute is permissive, not mandatory.

See KRS 446.010(26). The General Assembly has used mandatory language to

vest jurisdiction exclusively in district courts in numerous other contexts. See, e.g.,

KRS 387.020(1); KRS 387.520(1); KRS 386B.7-100. But the General Assembly

consciously chose to not use similarly explicit language vesting sole jurisdiction

over URLTA claims in district courts. Instead, by its use of permissive

jurisdictional language while simultaneously explicitly providing that courts may

sometimes grant injunctions for URLTA violations, the General Assembly has

vested district courts with concurrent jurisdiction over URLTA claims not

-9-involving requests for injunctive relief. As our Supreme Court recognized,

sometimes two courts have subject matter jurisdiction over a claim. Nordike, 231

S.W.3d at 738.

The takeaway is that the trial court’s sweeping conclusion that circuit

courts never have jurisdiction over URLTA claims is erroneous. Indeed, Mt.

Lebanon concedes as much in its brief. Instead, Mt. Lebanon makes a more

limited argument that the circuit court lacked jurisdiction over Shields’ specific

claims because his alleged damages were under $5,000. We disagree that the

circuit court lacked jurisdiction over Shields’ specific complaint due to an

insufficient amount in controversy.

KRS 24A.120(1) provides that, with exceptions for “matters affecting

title to real estate and matters of equity[,]” a district court has exclusive jurisdiction

over civil claims when “the amount in controversy does not exceed five thousand

dollars ($5,000) . . . .” KRS 383.705(2) entitles a tenant to the remedies found in

KRS 383.655 if a landlord engages in illegal retaliatory conduct; KRS 383.655

allows a tenant to “recover an amount not more than three (3) months periodic rent

and a reasonable attorney’s fee.” Rent is defined within URLTA as “all payments

except a security deposit as defined in this section to be made to the landlord under

the rental agreement.” KRS 383.545(10). There is no statutory exclusion from the

definition of rent for payments made by someone besides the tenant (e.g., HUD).

-10-Instead, the definition of rent broadly includes “all payments” made to

a landlord. We may not judicially graft language onto the statutory definition of

rent to make it read “all payments made directly by a tenant” to a landlord.7 “We

are not permitted to add words to a statute, and a legislature making no exceptions

to the positive terms of a statute is presumed to have intended to make none.”

Louisville/Jefferson Cnty. Metropolitan Government v. Moore, 701 S.W.3d 335,

345 (Ky. 2024) (internal quotation marks and citations omitted).

Thus, we reject Mt. Lebanon’s argument that Shields may recover

only treble the portion of his rent which he personally paid monthly. Accepting

Mt. Lebanon’s argument would mean that a destitute tenant whose entire rent, or

nearly so, is paid by HUD would be unable to recover any meaningful damages

based on a landlord’s misconduct. For URLTA purposes, Shields’ rent includes

both the monthly payments he makes, and the monthly payments HUD makes on

his behalf.

Therefore, Shields may recover $2,241 for each instance of retaliation

upon which he prevails ($747 monthly rent X 3 = $2,241). Shields alleges four

instances of retaliation, so he could potentially receive $8,964 ($2,241 X 4 =

$8,964), as well as any potentially appropriate attorney fees. “[F]or jurisdictional

7

Because rent is broadly, plainly defined by a Kentucky statute, we decline to address the extraterritorial authority cited by Mt. Lebanon involving whether rent includes payments made by another entity on a tenant’s behalf.

-11-purposes, the amount in controversy is determined based on the allegations in the

complaint, not what a party is entitled to.” Hernandez v. Cnty. Investments, LLC,

696 S.W.3d 832, 836 (Ky. App. 2024). As per Shields’ complaint, for

jurisdictional purposes, the amount in controversy exceeds $5,000, and so the

district court did not have exclusive jurisdiction over Shields’ claims.

We also reject Mt. Lebanon’s argument that Shields may only recover

a maximum of $2,241 (three times his monthly rent) even if he prevails on multiple

retaliation claims. Mt. Lebanon points to no statutory language or precedent which

explicitly allows an URLTA tenant to only recover one lump sum representing

three times the tenant’s monthly rent even if the tenant prevails on multiple claims

against a landlord. We refuse to provide a perverse incentive to landlords to

commit second or subsequent acts of misconduct with financial impunity. See,

e.g., Brown v. Funk, 697 S.W.3d 739, 748 (Ky. App. 2024) (noting the ancient

principle of Kentucky law that “for every injury, there should be a compensation

. . . .”) (internal quotation marks and citation omitted).

We respectfully decline to address Mt. Lebanon’s argument that

Shields lacks standing. Mt. Lebanon did not present that argument to the circuit

court. Kentucky precedent plainly holds that an appellee may raise alternate

grounds for affirming a trial court “provided only that the alternative ground

was brought to the trial court’s attention and is otherwise supported by the

-12-record.” Klein, 439 S.W.3d at 122 (emphasis added). Cases with a similar

statement of the law include, for example, Brown v. Barkley, 628 S.W.2d 616, 619

(Ky. 1982); Carrico v. City of Owensboro, 511 S.W.2d 677, 679 (Ky. 1974); and

Commonwealth, Corrections Cabinet v. Vester, 956 S.W.2d 204, 205-06 (Ky.

1997). We decline to be the initial decisionmaker regarding Mt. Lebanon’s

argument that Shields lacks standing, especially given the extremely limited record

adduced thus far in the circuit court. Klein, 439 S.W.3d at 122. On remand, Mt.

Lebanon may raise whatever defenses it deems proper, including an assertion that

Shields lacks standing.

In conclusion, the circuit court erred by broadly holding that district

courts have exclusive jurisdiction over all URLTA claims. Shields’ complaint also

facially satisfied the amount in controversy requirement necessary for a claim to be

heard in circuit court. We decline to address any hypothetical scenarios created by

the permissive jurisdictional language in URLTA involving potential factual

scenarios under which URLTA claims may only be heard by district courts or any

potential factual scenarios under which both district and circuit courts may have

jurisdiction. Instead, we limit our holding to the facts at hand, and those facts, and

the applicable law, show that the circuit court had jurisdiction over Shields’

complaint. We express no opinion on the merits of any of Shields’ claims or any

potential defenses thereto.

-13-CONCLUSION

For the foregoing reasons, the Jefferson Circuit Court is reversed, and

this case is remanded with instructions to reinstate Shields’ complaint.

ALL CONCUR.

BRIEFS FOR APPELLANT: BRIEF FOR APPELLEES:

Andrew Chandler Jaron P. Blandford

Melissa Weinstein Emily D. Penn

Louisville, Kentucky Lexington, Kentucky

-14-