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Scotty's Contracting and Stone, LLC v. Ashley Graves

2026-08-28

Summary

Holding. The Kentucky Court of Appeals reversed the trial court's judgment and remanded with instructions to dismiss all claims. The court held that the indemnity provision in the construction contract was void under Kentucky law prohibiting contractors from indemnifying the government for its own negligence, the trial court conducted improper ex parte proceedings violating due process and the right to jury trial, the trial court failed to establish the necessary predicate facts regarding proximate causation, and the assignment of the engineers' indemnity claim to the workers transferred nothing of legal value and thus could not support liability against Scotty's.

In 2012, a concrete form collapsed at a Kentucky highway construction project, killing one worker and injuring three others. All injured parties received workers' compensation benefits, which are their exclusive remedy under Kentucky law against their employer, VanMeter Contracting. They then sued seven transportation cabinet engineers as third-party tortfeasors, claiming the engineers failed to inspect the forms and stop the project. The engineers in turn sought indemnification from Scotty's Contracting (the general contractor) under a standard specifications clause. After a non-adversarial bench trial where only the workers presented evidence, the trial court held the engineers liable to the workers for over $22 million in damages and ruled that Scotty's must indemnify the engineers for those damages. The court conducted this trial after the engineers and injured workers reached a settlement where the workers received an assignment of the engineers' claimed indemnity rights and agreed not to collect from the engineers themselves.

The appeals court reversed, finding multiple fatal legal errors. Most significantly, the court held that Kentucky law prohibits contractors from indemnifying government employees for the government's own negligence. The indemnity clause thus could not support liability against Scotty's. Additionally, the trial court improperly conducted an ex parte proceeding that violated Scotty's due process rights to participate and receive a jury trial. Most fundamentally, the trial court never established that VanMeter's employees actually caused the accident through negligence—a necessary predicate to any finding that the engineers' failure to inspect was a proximate cause of the injuries.

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

Key issues

  • Whether an indemnity clause in a construction contract can require a contractor to indemnify government employees for the government's own negligence
  • Whether workers' compensation exclusivity bars claims by employees against up-the-ladder employers even when funneled through third-party indemnity assignments
  • Whether a trial court must allow an employer to participate in damages proceedings when the employer may face indemnity liability
  • Whether proof of the actual proximate cause of an accident is required before imposing liability on a party whose alleged negligence was failing to discover or stop the accident
  • Whether an ex parte trial violates due process and constitutional jury trial rights

Procedural posture

Two consolidated appeals from the Barren Circuit Court's December 11, 2023 judgment (as amended February 1, 2024) following a bench trial at which only the injured workers and engineers presented evidence.

Authorities cited

Opinion

majority opinion

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

TO BE PUBLISHED

Commonwealth of Kentucky

Court of Appeals

NO. 2024-CA-0287-MR

SCOTTY’S CONTRACTING AND

STONE, LLC APPELLANT

APPEAL FROM BARREN CIRCUIT COURT

v. HONORABLE JOHN T. ALEXANDER, JUDGE

ACTION NO. 13-CI-00487

ASHLEY GRAVES; DARYL PRICE;

GREG MEREDITH; JAMIE GROCE;

JOHN MCINTOSH; JON LAM;

KENTUCKY ASSOCIATED

GENERAL CONTRACTORS SELF

INSURANCE FUND; KEVIN

GERALDS; MARK LOVE; STEVE

NELSON; STEVEN NELSON,

ADMINISTRATOR OF THE ESTATE

OF LINDA NELSON; TOM LAPHAM;

VANMETER CONTRACTING, INC.;

VELMA DECKER, EXECUTRIX OF

THE ESTATE OF KENNETH

DECKER; AND VELMA DECKER,

INDIVIDUALLY APPELLEES

AND

NO. 2024-CA-0352-MR

SCOTTY’S CONTRACTING AND

STONE, LLC APPELLANT

APPEAL FROM BARREN CIRCUIT COURT

v. HONORABLE JOHN T. ALEXANDER, JUDGE

ACTION NO. 13-CI-00487

ASHLEY GRAVES; DARYL PRICE;

GREG MEREDITH; JAMIE GROCE;

JOHN MCINTOSH; JON LAM;

KENTUCKY ASSOCIATED

GENERAL CONTRACTORS SELF

INSURANCE FUND; KEVIN

GERALDS; LINDA NELSON; MARK

LOVE; STEVE NELSON; STEVEN

NELSON, ADMINISTRATOR OF THE

ESTATE OF LINDA NELSON; TOM

LAPHAM; VANMETER

CONTRACTING, INC.; VELMA

DECKER, EXECUTRIX OF THE

ESTATE OF KENNETH DECKER;

AND VELMA DECKER,

INDIVIDUALLY APPELLEES

OPINION

REVERSING AND REMANDING WITH INSTRUCTIONS

** ** ** ** **

BEFORE: ACREE, MCNEILL, AND TAYLOR, JUDGES.

ACREE, JUDGE: Scotty’s Contracting and Stone, LLC (Scotty’s) appeals the

Barren Circuit Court’s December 11, 2023 judgment as amended by Order entered

February 1, 2024, and the interlocutory orders and judgments made final by the

-2-final judgment as amended.1 We reverse the judgment and remand with

instructions to dismiss all claims.

BACKGROUND AND PROCEDURE

In 2011, the Kentucky Transportation Cabinet (KTC) awarded a

contract to Scotty’s for a road construction project. Scotty’s subcontracted with

VanMeter Contracting, Inc. (VanMeter) to build retaining walls using large

premanufactured forms.

The workplace accident and pursuit of workers’ compensation

VanMeter employees successfully constructed several sections of

retaining wall before October 8, 2012. On that date, they were pouring concrete

into a form they placed for the next section when it raised, toppled, and collapsed,

killing VanMeter employee Kenneth Decker and injuring three of his co-workers2

(Plaintiffs/Appellees). Meredith v. Decker, No. 2016-CA-000721-MR, 2018 WL

4054940, at *1 (Ky. App. Aug. 24, 2018).

1

Included were: April 18, 2016 Order; May 13, 2016 Order; April 23, 2021 Order; April 30, 2021 Consent Judgment, Assignment, and Forbearance; October 14, 2022 Order; March 9, 2023 Calendar Order, all made final and appealable by the trial court’s December 11, 2023 Findings of Fact, Conclusions of Law, and Judgment. Both Scotty’s and Plaintiffs/Appellees filed motions to amend the December 11, 2023 Judgment. The trial court granted only the Plaintiffs/Appellees’ motion and amended the judgment by Order entered February 1, 2024. Scotty’s moved to amend the new judgment, and the trial court denied that motion by Order entered March 11, 2024. 2

Those injured were John McIntosh, Steve Nelson, and Jamie Groce. With the Estate of Kenneth Decker and the loss-of-consortium claimants Velma Decker and Linda Nelson (substituted by her estate), this group is referred to as Plaintiffs/Appellees when not identified individually.

-3-Scotty’s and VanMeter had “secure[d] payment of compensation as

required by” the Kentucky Workers’ Compensation Act, KRS3 342.0011 et seq.

(the Act). KRS 342.690(1). No Plaintiff/Appellee opted out of the Act’s coverage

and all of them pursued its benefits. The Act was thus Plaintiffs/Appellees’

“exclusive” remedy against their employer, “in place of all other liability of such

employer . . . at law or in admiralty on account of” the workplace accident. Id.

Each Plaintiff/Appellee received workers’ compensation from

VanMeter through its insurer. Plaintiff/Appellee Jamie Groce is an example.

As with all Plaintiffs/Appellees’ claims, there was never an issue

about work-relatedness, typically analyzed in the context of causation. See, e.g.,

Vacuum Depositing, Inc. v. Dever, 285 S.W.3d 730, 732 (Ky. 2009) (discussing

Workman presumption4). The Administrative Law Judge (ALJ) awarded Groce

benefits based on a 54% permanent total disability rating. Groce v. VanMeter

Contracting, Inc., 539 S.W.3d 677, 681 (Ky. 2018) (quoting KRS 342.165(1)).

But Groce placed the question of what actually caused the accident

(primary and efficient cause) directly before the ALJ by “assert[ing] a claim for the

30% benefit enhancement . . . for a workplace injury ‘caused in any degree by the

3

Kentucky Revised Statutes.

4

In Kentucky, there is “a presumption that an unexplained workplace fall arises out of the employment unless the employer presents substantial evidence to show otherwise.” Vacuum Depositing, 285 S.W.3d at 733 (citing Workman v. Wesley Manor Methodist Home, 462 S.W.2d 898, 900 (Ky. 1971)).

-4-intentional failure of the employer to comply with any specific statute or lawful

administrative regulation made thereunder, communicated to the employer and

relative to installation or maintenance of safety appliances or methods.’” Id.

Groce bore the burden of proving KRS 342.165(1)’s elements, but she

failed to carry it. The ALJ “methodically examined the evidence supporting

Groce’s allegations of a safety violation and was unconvinced.” Id. at 684. But

the Supreme Court went further, affirming the ALJ’s factual finding that

VanMeter’s employees did properly secure the form. The Court said:

the ALJ did not merely conclude that Groce had failed to

meet her evidentiary burden of proving that VanMeter

violated 29 CFR[5] 1926.703(a)(1) [OSHA regulation

governing “General requirements for formwork”] by

failing to use the required push-pull pipe bracing and by

failing to properly space the anchor bolts on the concrete

forms; rather, the ALJ found from the evidence that

VanMeter had used push-pull pipe bracing and had

spaced its bolts within four-foot intervals. Thus, the ALJ

affirmatively found that these alleged violations did not

occur. Groce directs us to no evidence that compels a

finding in opposition to the ALJ’s determination.

The ALJ also expressly rejected the safety deficiencies

identified by Groce’s co-worker, Steve Nelson, relating to

the anchor bolt spacing and the use of tie-downs.[6]

5

Code of Federal Regulations. Kentucky incorporates this federal law. 803 Kentucky Administrative Regulations (KAR) 2:416.

6

Nelson did not testify in Groce’s workers’ compensation case. Support for Groce’s claim of VanMeter’s wrongdoing came from “the deposition testimony of Groce’s co-worker, Steve Nelson, taken from Nelson’s own worker[s’] compensation claim.” VanMeter Contracting, Inc. v. Groce, No. 2016-CA-000776-WC, 2017 WL 1369977, at *5 (Ky. App. Apr. 14, 2017), aff’d, 539 S.W.3d 677 (Ky. 2018).

-5-Id. at 683–84 (emphasis added) (double emphasis original).

In Groce, the Supreme Court affirmed this Court’s intermediate

appellate review in which we cited evidence the ALJ received identifying a

potential alternative cause of the accident—a product defect. VanMeter

Contracting, Inc. v. Groce, No. 2016-CA-000776-WC, 2017 WL 1369977, at *6

(Ky. App. Apr. 14, 2017), aff’d, 539 S.W.3d 677 (Ky. 2018).

VanMeter’s president testified at Groce’s hearing “that after the

incident, the manufacturer of the forms reviewed the incident and stated that

[VanMeter employees had used] even more anchor bolts than recommended. He

testified that the wall collapsed because the anchor bolts going into the footer

failed, but he did not know why this happened.” Id. In Groce, the Supreme Court

quoted the investigation report of the Kentucky Labor Cabinet, Office of

Occupational Safety and Health (KOSHA), which found, consistently with a failed

anchor bolt, that “[a]s the employees were topping off the fill, they heard a loud

pop and the entire form raised and toppled to the east toward the crane.” Groce,

539 S.W.3d at 680.7 The affirmative finding that VanMeter complied with the

7

In Groce, the Supreme Court identified this agency as the Kentucky Occupational Safety and Health Administration and using the acronym KOSHA. 539 S.W.3d at 680. Therefore, we use the same acronym.

-6-federal and state safety standards made it impossible for Groce to prove an

intentional disregard of those standards and the ALJ denied enhanced benefits.

Plaintiffs/Appellees sue KTC engineers as third-party tortfeasors

Before the ALJ ruled on Groce’s claim in December 2015, every

Plaintiff/Appellee sought additional compensation in civil court, invoking

jurisdiction pursuant to KRS 342.700(1) to sue the seven Kentucky Transportation

Cabinet (KTC) engineers (Engineers) associated with the project.8 The complaint

alleged generally that “a culture of neglect, complacency, and disregard for the

safety of the public has pervaded the Kentucky Department of Highways . . . .”

(Complaint ¶ 2). They said each one “negligently, carelessly, recklessly, and

maliciously allowed the hazardous and unsafe conditions at The Project to continue

. . . [and] should have shut the project down.” (Complaint ¶¶ 4–10). That sufficed

to state a negligence claim that: (1) the Engineers had a primary duty to inspect

VanMeter’s employees’ work and a second duty to shut down the project under

circumstances Plaintiffs/Appellees alleged were dangerous; (2) the Engineers’

failures of both duties were alleged to have been breached; and (3) but for those

breaches, Plaintiffs/Appellees would not have suffered their injuries.

8

Greg Meredith, Chief District Engineer; Kevin Geralds, Engineer Supervisor; Ashley Graves, Transportation Engineering Supervisor; Tom Lapham, Transportation Engineer; Mark Love, Tech. Transportation Engineer; Jon Lam, Staff Engineer; and Daryl Price, Project Engineer.

-7-Engineers claim qualified immunity

In addition to denying the allegations, the Engineers argued they were

entitled to qualified official immunity. The trial court ruled they were not. In

Meredith v. Decker, supra, this Court affirmed the trial court, stating the

Engineers’ primary “duty to inspect the concrete forms prior to the pouring of the

concrete” was ministerial. 2018 WL 4054940, at *3.

However, there was the secondary duty to “shut the construction

project down due to said unsafe work conditions[.]” Id., at *2. Such a duty was

conditioned on a predicate fact—that if the Engineers had satisfied their primary

duty to inspect, they would have discovered “a recognized danger . . . to be

imminent, . . . in the opinion of the SE [Section Engineer].” Id. (quoting trial court

order (quoting KTC Construction Guidance Manual (May 2009), p. 1 of 2)

(hereafter CGM)).

When the trial court ruled on the Engineers’ immunity claim on April

18, 2016, the predicate fact of VanMeter employees’ failure to secure the concrete

form was not established. Therefore, to determine whether the duty to shut down

the project was ministerial or discretionary, the trial court had to assume VanMeter

employees committed a discoverable violation of a CGM requirement that

established the duty. (Order, Apr. 18, 2016). As said in Meredith, this Court had

to indulge the same assumption to review the trial court’s order on appeal.

-8-Bound in Meredith by the narrow scope of interlocutory appeal

jurisdiction, this Court was appropriately circumspect. We did not decide, nor did

we need to decide, whether the assumed predicate fact actually existed as the

parties asked us to do. Meredith, 2018 WL 4054940, at *1 (“[W]e lack jurisdiction

to resolve most of the arguments presented” as summary judgment grounds.). “To

be clear,” we said, “whether the KTC Engineers failed to perform within the scope

of their duties, or proximately caused any legally cognizable damages cannot be

addressed at this point because doing so would determine the substantive claims of

negligence asserted in this litigation.” Id., at *3 (emphasis original).

The arguments we could not reach in the five appeals consolidated in

Meredith were returned to the trial court, resolved, appealed, and are now properly

before us. Hence, we need to set out the background to those arguments here.

Engineers pursue third-party claims against Scotty’s and VanMeter

Soon after the Engineers filed their answer denying the allegations of

Plaintiffs/Appellees’ complaint, the trial court allowed them to bring third-party

claims against Scotty’s and VanMeter for contractual and common law indemnity.

As motion practice proceeded, they based the contractual indemnity claim on their

interpretation of Kentucky’s Standard Specifications for Road and Bridge

Construction, section 107.13.9 Section 107.13 reads in its entirety:

9

The trial court dismissed KTC Engineers’ claim for common law indemnity against Scotty’s.

-9-107.13 RESPONSIBILITY FOR DAMAGE CLAIMS.

The Contractor shall indemnify and save harmless the

Commonwealth, the Department [of Highways], and all its

officers, agents, and employees from all suits, actions, or

claims of any character brought on account of any of the

following:

1) injuries or damages sustained by any person or

property resulting from the Contractor’s act;

2) neglecting safeguarding the work;

3) acts, omissions, neglect, or misconduct;

4) claims or amounts recovered from any infringement

of patent, trademark, or copyright; and

5) claims or amounts arising or recovered under

Workers Compensation Act, or any other law,

ordinance, order, or decree.

The Department will retain money due the

Contractor in amounts sufficient to cover the cost of such

suits, actions, or claims for the use of the Commonwealth.

By executing this Contract, the parties do not intend

to create for the public or any of its members a third party

beneficiary, or to authorize anyone not a party to the

Contract, a suit for personal injuries or property

damage.[10]

VanMeter answered the third-party complaint. Scotty’s answered and

filed a cross-claim against VanMeter for indemnity. Motion practice then ensued.

10

None of the briefs quote section 107.13 in full. They all exclude the last two unnumbered paragraphs.

-10-In the same April 18, 2016 order we reviewed, in part, in Meredith,

the trial court addressed summary judgment motions filed by the parties to the

third-party claims. The court denied the Engineers’ motion for summary judgment

on Plaintiffs/Appellees’ claim after seeing “evidence that could lead a reasonable

juror to find that the failure of the [Engineers] to comply with the Construction

Guidance Manual and the Kentucky Standard Specifications for Road and Bridge

[Construction11] was a proximate cause of [their] injuries.” (Order, Apr. 18, 2016).

When the Engineers suggested section 107.13 (incorporated by

reference in both Scotty’s contract and VanMeter’s subcontract) required Scotty’s

and VanMeter to indemnify the Engineers for the Engineers’ own negligence, both

responded with summary judgment motions.

When VanMeter disputed that interpretation, the Engineers changed

their approach, stating “Standard Specification 107.13” grants the Engineers a right

“to be reimbursed in amounts sufficient to cover the costs of such suits, actions, or

claims” brought against them by reason of Scotty’s or VanMeter’s actions (or of

their respective employees) and “that these expenses should be recovered from

VanMeter through a claim of indemnity at the end of this action.” (Id.)

11

The trial court cited Kentucky Standard Specification 601.03.12(A) that prohibits “deposit[ing] concrete in forms until . . . the Engineer has inspected forms and materials.” See Meredith, 2018 WL 4054940, at *3 (“KTC employees had a duty to inspect the concrete forms prior to the pouring of the concrete.”).

-11-In ruling on VanMeter’s summary judgment motion, the trial court

rejected the Engineers’ argument that section 107.13 requires VanMeter to

indemnify them for their own breaches of duty when sued in their individual

capacity. It said, “when there is a doubt as to the meaning of an indemnity clause

the construction should be against the contention that the contract was meant to

indemnify against an indemnitee’s own negligence.” (Order, Apr. 18, 2016)

(citing Fosson v. Ashland Oil and Refining Co., 309 S.W.2d 176, 178 (Ky. 1957)).

The trial court dismissed the Engineers’ contractual indemnity claim against

VanMeter. VanMeter remained in the case to defend Scotty’s pending cross-claim.

Scotty’s too moved for summary judgment on the same ground as

VanMeter. This time, the trial court interpreted section 107.13 differently. The

trial court cited subsection (2) of section 107.13 which says the “Contractor shall

indemnify and save harmless the Commonwealth, the Department [of Highways],

and all its officers, agents, and employees from all suits, actions, or claims of any

character brought on account of . . . (2) neglecting safeguarding the work . . . .”

(Order, May 13, 2016). Attempting to clarify, the trial court said Scotty’s “is not

being asked to indemnify” the Engineers for their negligence but “with respect to

loss caused by its own alleged negligence.” (Id.) It only ruled it was not

impossible for Scotty’s to be found liable. (Order, Apr. 23, 2021). The trial court

said, “the duty to ‘safeguard the work’ would appear to encompass a responsibility

-12-to see that safety standards were met[,]” but expressly questioned “[i]f there is such

a duty[.]” (Id.) Still, it denied Scotty’s summary judgment motion.

This is the point at which the Engineers claimed qualified immunity in

Meredith v. Decker. Upon that opinion’s remand of the case, the parties

commenced a new round of motion practice.

Amid this second round, and outside the proceedings, counsel for the

Engineers and Plaintiffs/Appellees negotiated an assignment of claims, a consent

judgment, and a forbearance and indemnity agreement.

Assignment of claims and consent judgment

The Assignment of Rights of Claims identifies the Engineers as

“Assignors” and the Plaintiffs/Appellees as “Assignees” and, in pertinent part,

states as follows:

• “Assignors may possess certain claims, including, but not limited to,

indemnity against Scotty’s . . . and VanMeter . . . [and] desire to convey,

transfer, and assign to Assignees all of Assignors’ whatever rights . . . .”

• “. . . for good and valuable consideration, . . . Assignors and Assignees

hereby agree as follows:

o Assignors hereby assign to Assignees whatever claims, rights, title,

and interest in, to, and arising from their claims[;]

o “Assignees further agree . . . to further indemnify and forever hold

harmless all Assignors . . . [against all claims relating to the subject

legal action] but not specifically limited to any claim attempting to be

asserted by Scotty’s . . . or VanMeter[.]”

-13-(Assignment of Rights of Claims, tendered Aug. 26, 2020).

In addition to the assignment of claims, Plaintiffs/Appellees and the

Engineers also tendered a consent judgment. It says, in pertinent part:

• “While [Engineers] deny liability . . . [they] recognize that they may be

subject to liability, . . . may be uninsured and have insufficient assets to

satisfy a potential judgment . . . [and] have some risk of being

bankrupted[;]”

• “In determining the extent of Plaintiffs’ compensatory damages, evidence

may be submitted by affidavits or reports[;]”

• “In consideration of the Assignment of Claims, . . . [Plaintiffs/Appellees]

agree to forbear any and all attempts to collect from [Engineers] any

judgment or award on any claims asserted against [Engineers] in this action

. . . and to forbear any and all attempts to collect from or proceed against

[Engineers] for any damages awarded[;]”

• “. . . [Engineers] make no promises, assurances, or representations as to any

claims or rights they may have against said parties and their insureds.”

• “[Plaintiffs/Appellees] agree to forbear execution against the [Engineers],

on any and all claims or awards[;]”

• “[Plaintiffs/Appellees] shall dismiss, without prejudice, their claims against

[Engineers], subject to the Assignment of Rights of Claims[;]”

• “If it is ultimately determined that [Engineers’] claims against Scotty’s . . .

and/or VanMeter . . . are not valid or [Plaintiffs/Appellees] cannot recover

thereon for any reason, this Order and the forbearance contained therein are

still to be given its full force and effect, and [Plaintiffs/Appellees] shall

have no further cause of action against [Engineers].”

-14-(Consent Judgment, Assignment, and Forbearance, tendered Aug. 26, 2020).

Scotty’s and VanMeter objected and filed new motions for summary

judgment. Plaintiffs/Appellees responded with their own motions to modify

previous orders and to enter the assignment and the consent judgment.

Trial court rules on flurry of motions

The trial court’s April 23, 2021 order began by deciding Scotty’s

summary judgment motion. Contrary to the trial court’s prior ruling that section

107.13 does not indemnify the Engineers for their own negligence, the Engineers

were again making that very argument. In response, Scotty’s cited KRS 371.180

which prohibits provisions in construction services contracts indemnifying the

party letting the contract or its employees and agents for their own negligence.

The trial court denied Scotty’s motion, reiterating its previous holding

that the Engineers “have a viable contractual indemnification claim under §

107.13(1) and (2) . . . based on Scotty’s alleged negligence, not that of the KTC

[Engineers] themselves.” (Order, Apr. 23, 2021) (emphasis added). The trial court

then cited subsection (3) of section 107.13 and ruled in a completely contradictory

way.

The Engineers persuaded the trial court that section 107.13(3) does

authorize what KRS 371.180 prohibits. Disregarding the statute and its own

immediately preceding ruling, the trial court said:

-15-For subsection (3) to have meaning, it must provide for

indemnity by Scotty’s to the KTC [Engineers] for their

own negligence, as it refers to “all . . . claims of any

character brought on account of . . . [a]cts, omissions,

neglect, or misconduct.” While this type of provision is

disfavored, it is not against public policy.

(Order, Apr. 23, 2021) (citing Speedway Superamerica, LLC v. Erwin, 250 S.W.3d

339, 342 (Ky. App. 2008)) (emphasis added).

The trial court attempted to explain that its ruling did not conflict with

KRS 317.180 by citing the Engineers’ follow-up argument “that they are not

properly considered contractors within the meaning of KRS 371.180(1)(b)

[because] . . . [t]he Transportation Cabinet is the contractor in this instance[,]” not

its employees. (Id.) “Accordingly,” the order continues, “the Court grants the

motion to modify the May 13, 2016 order to clarify that Scotty’s has a contractual

obligation to indemnify the [Engineers] for . . . negligence on the part of the

[Engineers] themselves.” (Id.) (emphasis added).

Finally, the order addressed Plaintiffs/Appellees’ and the Engineers’

motion to enter the consent judgment. Scotty’s and VanMeter opposed its entry on

collusion grounds. The trial court did not perceive the risk of collusion “to be so

great as to automatically invalidate an otherwise valid assignment of claims.” (Id.)

(quoting Associated Ins. Serv., Inc. v. Garcia, 307 S.W.3d 58, 69 (Ky. 2010)).

The trial court found that Kentucky law favors “claim assignments

coupled with a consent judgment or other settlement arrangement and a covenant

-16-not to execute, subject to some assessment that the settlement reflects a reasonable

calculation of damages.” (Id.) (quoting Garcia, 307 S.W.3d at 68). The trial court

said, “Presumably [the trial court itself] could ensure . . . a reasonable damages

determination . . . [or] a better way . . . would be to review a damages award

arising from arbitration.” (Id.) Therefore, Scotty’s and VanMeter’s “assertion that

a calculation of damages is or would be unreasonable is not a basis to deny entry of

a proposed judgment.” (Id.)

The trial court next rejected Scotty’s argument that “the effect of the

proposed consent judgment is to permit [VanMeter’s] employees to circumvent the

exclusive-remedy policy of the Workers’ Compensation Act as reflected in KRS

342.690(1).” (Id.) Scotty’s expressly pleaded the Act as an affirmative defense to

the third-party complaint. “[U]nder the facts of the instant case,” said the trial

court, “neither an employer nor its insurer is liable to a covered employee if the

consent judgment is entered. Scotty’s would, at most, be liable to the KTC

[Engineers] to whom they theoretically owe a duty of indemnity.” The trial court

found the Act “was not a bar to entry of the [consent judgment].” (Id.)

Scotty’s was concerned the Engineers would be ill-motivated to

mount a defense because Plaintiffs/Appellees agreed to forbear all collection

efforts against them. Scotty’s filed a motion “to participate in further proceedings

regarding liability and damages.” (Order, Oct. 14, 2022). Plaintiffs/Appellees

-17-responded that “Scotty’s is only involved in this case to the extent that it owes a

contractual duty to indemnify the KTC [Engineers]; that contract does not provide

Scotty’s a right to be involved in the tort claim between [Plaintiffs/Appellees] and

the KTC [Engineers].” (Id.) The trial court said it found no authority “that a party

without a duty to defend has a right to do so, particularly when the indemnitees (in

this action, the KTC [Engineers]) are already represented . . . .” (Id.)

Scotty’s further pressed its argument that comparative fault and

apportionment issues must still be considered. The Engineers themselves

demanded apportionment in their answer to Plaintiffs/Appellees’ complaint,

obviously to lessen their share of damages in any judgment that might be obtained

against them. They repeated that demand in the consent judgment.

Still, the trial court rejected the demands and arguments for

apportionment, saying, “The arguments about comparative negligence and

apportionment are not compelling because, as [Plaintiffs/Appellees] note, Scotty’s

has no direct liability due to the exclusive-remedy effect of the Workers’

Compensation Act.” (Id.) The trial court further said, “Scotty’s motion to

participate in the determination of damages is denied to the extent Scotty’s seeks to

put on evidence or cross-examine witnesses.” (Id.)

Scotty’s fears were confirmed when the Engineers “gave notice . . .

[they] would no longer be actively participating and/or defending against

-18-[Plaintiffs/Appellees’] claims as a result of the Court’s Order of April 23, 2021,”

approving the consent judgment that included Plaintiffs/Appellees’ agreement to

forbear from collecting the judgment against the Engineers from the Engineers.

(Engineers’ Notice of Non-Participation, Nov. 16, 2022).

At the hearing to set trial, the court disregarded Scotty’s demand for a

jury trial,12 stating it would conduct a bench trial “[u]nder the procedure

contemplated by Garcia, [supra,] [to] determine the existence and amount of

compensatory damages for each [of the Plaintiffs/Appellees], and to ascertain

whether punitive damages are warranted.” (Judgment, Dec. 11, 2023). Over

Scotty’s objections, the court scheduled the bench trial. (Order, Nov. 17, 2022).

Trial court conducts trial with only Plaintiffs/Appellees’ participation

Trial commenced on March 8, 2023, as scheduled and is generally

noteworthy for its non-adversarial nature. Only Plaintiffs/Appellees participated.

Most sat in the gallery with relatives who would testify. Plaintiffs/Appellees’

counsel discussed with the trial court the rule regarding separation of witnesses,

12

Plaintiffs/Appellees also demanded a trial by jury in their complaint. The Engineers too demanded a trial by jury in their third-party complaint. As far as our review reveals, no party waived their jury trial demand. Failure to object to a bench trial does not constitute a waiver of the right to a jury trial, even after also participating in the bench trial to its conclusion. Hazard Coal Corporation v. Knight, 325 S.W.3d 290 (Ky. 2010).

-19-KRE13 615, but did not invoke it. The judge said it was his practice not to invoke

the rule sua sponte, and he did not. Witnesses heard one another’s testimony.

After an opening statement, counsel for Plaintiffs/Appellees presented

evidence of duty, breach, and causation by calling an expert never disclosed to any

other party, engineer Harold Deatherage.14 Plaintiffs/Appellees and their families

were the only other witnesses to testify. No one cross-examined any witness. No

one presented countervailing evidence responsive to Plaintiffs/Appellees’

evidence. After the trial, the court reviewed several exhibits and depositions

before making its findings of fact as set out in the following paragraphs.

Recognizing the duties the Engineers owed during trial

According to Mr. Deatherage, Greg Meredith, as Chief District

Engineer, and his subordinate Engineers “had safety responsibilities with respect

to, inter alia, the project at the heart of this case . . . [and were] obligated to

comply with the applicable construction standards.”15 That duty to inspect was not

13

Kentucky Rules of Evidence.

14

We viewed the trial video transcript and do not question or have reservations about Mr. Deatherage’s qualifications as an expert or the veracity of his testimony. As explained in our analysis, however, his opinions are based on the assumption, not a proven fact that VanMeter failed to comply with federal and state safety regulations.

15

The trial court identified these as “OSHA [federal Occupational Safety and Health Administration] regulations, the Kentucky Standard Specifications for Road and Bridge Construction (the Standard Specifications), and the Kentucky Construction Guidance Manual (CGM).”

-20-conditioned upon any fact other than that VanMeter employees were proceeding

with their work. However, the trial court found the secondary duty—the duty to

stop work—was conditioned upon certain facts.

The trial court said the Engineers “had the ability to shut down the

project if standards were not being followed” by VanMeter’s employees. (Id.)

(emphasis added). They only owed a duty “to stop work on the project if they

observed unsafe conditions.” (Judgment, Dec. 11, 2023). Thus, the existence,

danger, and observability of such predicate conditions needed to be proved. But

the court received no evidence to establish those necessary predicate facts that

would have given rise to the Engineers’ duty to shut down the project. That is,

there was no evidence that VanMeter employees failed to comply with standards

which an inspection would have revealed as “a recognized danger” that was

“imminent, . . . in the opinion of the SE [Section Engineer].” (KTC Construction

Guidance Manual (May 2009), p. 1 of 2).

To find a breach of duty to shut down the project and the duty itself,

Mr. Deatherage assumed the cause of the accident was VanMeter’s employees’

violation of safety standards, just as the trial court did before him.

Finding breach

The court held the Engineers breached the duty to inspect as follows:

13. The proof identified five primary failures on this

project:

-21-a. Failure to enforce strict compliance with applicable

safety procedures . . . ;

b. Failure to require certified engineering plans before

allowing work to proceed on the retaining wall . . . ;

c. Failure to enforce OSHA regulations regarding the

shoring of retaining walls . . . ;

d. Failure to inspect anchoring before allowing the wall to

be poured . . . ; and

e. Failure to ensure that VanMeter had competent

personnel on site to make certain that the retaining wall

was being safely constructed according to standards.

(Id.) The finding of breach here was not because the Engineers tried and

negligently failed, but because they did not try at all. They did not inspect.

Assumption rather than determination of facts was the basis of finding

a duty to shut down the project. All that was factually established was that the

Engineers did not shut down the project before the accident occurred. As we

discuss in the analysis, there was insufficient evidence either to prove the fact that

VanMeter employees improperly anchored the form or to deem the testimony in

depositions to constitute a judicial admission to that effect.

Finding causation

The trial court concluded the seven Engineers’ “failure to enforce

strict compliance with safety laws, rules, and regulations was a substantial

contributing factor to the collapse of the wall.” (Id.) But the trial court found no

-22-party at fault other than the Engineers. The court apportioned 100% of the fault

among the Engineers only, effectively finding their breach of duty to inspect to be

the sole proximate cause. See KRS 411.182. The trial court determined

VanMeter, its employees including Plaintiffs/Appellees, and Scotty’s bore no

responsibility or fault for the collapse at all. (Judgment, Dec. 11, 2023).

Findings of damages

The trial court’s judgment then turned to proof of damages reiterating

the consent judgment’s ruling “that [Plaintiffs/Appellees] could submit written

reports to prove damages.” (Judgment, Dec. 11, 2023). Scotty’s and VanMeter

were prohibited from submitting such reports and so the trial court considered only

the reports submitted by Plaintiffs/Appellees.

The court accepted the written reports of an economics professor, an

orthopedist, and an individual with a master’s degree in Rehabilitation Counseling.

They did not testify and only submitted reports, but the trial court found “[t]hese

witnesses qualify as experts in their respective fields.” (Id.). After summarizing

the Plaintiffs/Appellees’ current circumstances, the trial court awarded each one

significant compensatory damages.

The trial court then moved on to address why the Engineers’ conduct

justified making an example of them with an award of punitive damages, stating:

-23-This case presents clear and convincing evidence of gross

negligence, which makes an award of punitive damages

appropriate . . . .

Given the roles of these [Engineers] as the supervisors of

highway construction in southern Kentucky, it is relevant

to consider the elements of both punishment and

deterrence when determining punitive damages in this

matter. . . . A punitive damages award would be

appropriate to deter the type of gross negligence in

evidence here. The hope would be to deter gross

negligence on the part of these named [Engineers], those

similarly situated, as well as others performing ministerial

duties on behalf of the public.

(Id.) The trial court set exemplary damages at $10,000,000.00.

The court knew its prior order approved of Plaintiffs/Appellees’

agreement to forbear collecting any damages from the Engineers. The court was

aware of its other order that Scotty’s must indemnify the Engineers for those same

damages—compensatory and punitive damages alike.16 On February 1, 2024, the

court entered its final judgment against Scotty’s, as follows:

1. The Estate of Kenneth Decker shall recover of Scotty’s the sum of

$437,587.00;

2. Velma Decker shall recover of Scotty’s the sum of $2,000,000.00 for loss of

consortium;

3. John McIntosh shall recover of Scotty’s the sum of $1,684,234.92;

4. Jamie Groce shall recover of Scotty’s the sum of $4,730,084.98;

5. Steve Nelson shall recover of Scotty’s the sum of $2,731,823.00;

16

The December 11, 2023 Judgment “incorporates all conclusions of law set out in prior orders[.]”

-24-6. Linda Nelson shall recover of Scotty’s the sum of $1,000,000.00 for loss of

consortium;

7. Plaintiffs shall recover punitive damage from Scotty’s in the amount of

$10,000,000.00 to be prorated among Plaintiffs in the same proportion as

each Plaintiff’s share of the total compensatory damages awarded[.]

Following entry of that order, Scotty’s brought this timely appeal.

STANDARD OF REVIEW

When reviewing a judgment after a bench trial, “[f]indings of fact,

shall not be set aside unless clearly erroneous, and due regard shall be given to the

opportunity of the trial court to judge the credibility of the witnesses.” CR17 52.01.

“[R]eview of legal determinations and conclusions from a bench trial is de novo.”

Kentucky Properties Holding LLC v. Sproul, 507 S.W.3d 563, 569 (Ky. 2016).

Statutory interpretation is a legal question reviewed de novo. Estate

of Benton v. Currin, 615 S.W.3d 34, 36 (Ky. 2021). The same is so regarding

regulations. Wonderfoil, Inc. v. Russell, 630 S.W.3d 706, 709 (Ky. 2021).

“[I]nterpretation and legal effect of a contract is a matter of law” and is likewise

subject to de novo review. Speedway, 250 S.W.3d at 341.

Proximate cause becomes a question of law when no facts are

disputed “and but one conclusion may reasonably be drawn from the evidence.”

17

Kentucky Rules of Civil Procedure.

-25-Patton v. Bickford, 529 S.W.3d 717, 731 (Ky. 2016) (quoting McCoy v. Carter,

323 S.W.2d 210, 215 (Ky. 1959)).

ANALYSIS

Scotty’s Prehearing Statement identifies thirty-two issues. We

address those issues argued in the briefs and those that otherwise are essential to

our review, starting with the issue of subject matter jurisdiction. Understanding

the proper role of subject matter jurisdiction pursuant to which this case was or

should have been adjudicated provides a roadmap of sorts to our review.

Subject matter jurisdiction

“Kentucky’s Workers’ Compensation Board is vested with exclusive

jurisdiction to decide matters within the purview of the Workers’ Compensation

Act.” Hardin v. Action Graphics, Inc., 57 S.W.3d 844, 845 (Ky. App. 2001)

(citing Shamrock Coal Co., Inc. v. Maricle, 5 S.W.3d 130 (Ky. 1999)). The Act’s

purview is administering claims resulting from “a risk peculiar to the

employment[.]” Smith v. Klarer Co., 405 S.W.2d 736, 738 (Ky. 1966). See

Warrior Coal Co., LLC v. Stroud, 151 S.W.3d 29, 31 (Ky. 2004) (claims “aris[ing]

from a peril that is related to the employment[.]”). Where the Act applies, as it

does here, “[t]rial courts . . . are deprived of jurisdiction by the explicit language of

KRS 342.690(1), the exclusive liability provision of the Workers’ Compensation

Act.” Hardin, 57 S.W.3d at 845.

-26-That explicit language does more than limit an employer’s liability to

its employee. It also limits an employer’s liability to third parties. Specifically,

another part of KRS 342.690(1) says:

The liability of an employer to another person who may

be liable for or who has paid damages on account of injury

or death of an employee of such employer arising out of

and in the course of employment and caused by a breach

of any duty or obligation owed by such employer to such

other shall be limited to the amount of compensation and

other benefits for which such employer is liable under this

chapter on account of such injury or death, unless such

other and the employer by written contract have agreed to

share liability in a different manner.

KRS 342.690(1) (third sentence) (emphasis added).

Given this liability limiting provision and the Board’s exclusive

subject matter jurisdiction over workplace accidents, we must ask the question—

“what is the source of the trial court’s subject matter jurisdiction over: (1)

Plaintiffs/Appellees’ tort claim against the Engineers, and (2) the Engineers’

indemnity claims against Scotty’s and VanMeter?” We start with what is typical.

Typically, personal injury actions are the “kind of case that comes

within a circuit court’s subject matter jurisdiction.” General Elec. Co. v. Cain, 236

S.W.3d 579, 589 (Ky. 2007). The Act, however, abrogated Kentucky common law

when the subject matter is a claim or claims arising out of a workplace accident.

When a party’s injuries result from a risk peculiar to his employment, “that

-27-jurisdictional fact would deprive the circuit court of subject matter jurisdiction by

operation of KRS 342.690(1).” Id. That deprivation of jurisdiction is broad.

When our legislature adopted the Act, it had a choice from among

“the three general types of ‘exclusive liability’ clauses prevalent in workers’

compensation statutes[.]” Hardin, 57 S.W.3d at 845 n.1 (citing ARTHUR LARSON,

LARSON’S WORKERS’ COMPENSATION—DESK EDITION § 66.10 (2000)).

Kentucky’s choice was “the broadest, excluding the widest array of actions” that

are typically pursued in civil courts. Id. at 845.

Liability under the Act “shall be exclusive . . . of all other liability of

such employer to the employee . . . and anyone otherwise entitled to recover

damages from such employer at law or in admiralty” stemming from a workplace

injury. KRS 342.690(1) (emphasis added). If the Act stopped there, the trial court

here would have been stripped of all subject matter jurisdiction to address

Plaintiffs/Appellees’ tort claim against the Engineers and the Engineers’ indemnity

claims against Scotty’s and VanMeter. The Board would have had exclusive

jurisdiction to address those claims. But there is further legislation.

Immediately after KRS 342.690 is another statute that says, when a

workplace injury “has been sustained under circumstances creating in some other

person than the employer a legal liability to pay damages, the injured employee

may . . . proceed at law by civil action against the other person to recover damages

-28-. . . .” KRS 342.700(1) (emphasis added). That statute, not KRS 23A.010(1),

grants the trial court subject matter jurisdiction to adjudicate such claims as

Plaintiffs/Appellees brought against the Engineers.

The same provision grants a trial court subject matter jurisdiction to

address an employer’s subrogation claim against a party referred to as “some other

person than the employer[.]” KRS 342.700(1) (“the employer . . . may recover . . .

from the other person”). However, the “subrogation claim depends entirely on the

plaintiff’s [employee’s] claims against the defendant [other person than the

employer].” Clarendon Nat. Ins. Co. v. Vetor, 165 S.W.3d 484, 490 (Ky. App.

2005). That is, an employer cannot bring a subrogation claim against a nonemployer tortfeasor independently of the employee’s claim. If the employee files a

claim in civil court, the employer (or his insurer) often intervenes against the

“other person.” See, e.g., Bowlin Group, LLC v. Rebennack, 626 S.W.3d 177, 183

(Ky. App. 2020).

Correspondingly, the Supreme Court acknowledged that the Act

grants trial courts subject matter jurisdiction over claims by “the other person” for

indemnity against the employer. Dix & Associates Pipeline Contractors, Inc. v.

Key, 799 S.W.2d 24, 25 (Ky. 1990) (employee’s tort claim defendants “filed a

third-party complaint naming [employer] as a third-party defendant”). See also id.

-29-at 30 (further addressing procedure “if the employer is made a third-party

defendant in the tort action” under KRS 342.700(1)).

The “other person’s” indemnity claim against the employer cannot

yield more than an offset against the employee’s judgment equal to the amount the

employer paid under the Act. Dix, 799 S.W.2d at 26. See also id. at 33 n.1

(Liebson, J., dissenting). That is so because in the employee’s action “against the

other person . . . he shall not collect from both” the other person and the employer.

KRS 342.700(1). But there is an exception to that limitation as noted above.

If the other person “and the employer by written contract have agreed

to share liability in a different manner” than the Act allows, the trial court can

exercise subject matter jurisdiction pursuant to the Act to make that determination.

KRS 342.690(1). Its enforcement would be an exception to the offset limitation of

KRS 342.700(1). The Engineers believed they had such an agreement, even if they

failed to understand the trial court’s basis of subject matter jurisdiction to rule.

Plaintiffs/Appellees sought to do indirectly what the Act directly prohibits

There is an ancient legal maxim the Supreme Court of the United

States calls, “the maxim of common sense and good morals, that what the law will

not allow you to do directly, you shall not attempt to do indirectly.” Kendall v.

United States ex rel. Stokes, 37 U.S. 524, 605, 9 L. Ed. 1181 (1838). See Allen v.

Canal Ins. Co., Greenville, S.C., 433 S.W.2d 352, 354 (Ky. 1968) (not allowing

-30-insurer to “accomplish indirectly what the law does not permit to be done directly”

(internal quotation marks and citation omitted)).

Plaintiffs/Appellees and the trial court ignored this maxim and

accomplished indirectly what the legislature directly prohibited—a judgment

finding Scotty’s liable for Plaintiffs/Appellees’ workplace injuries in contravention

of the exclusiveness and limitations of liability the legislature established in KRS

342.690(1). That resulted in exactly what the Act forbids—recovery of twice the

medical costs and lost earnings the Act allows, plus pain and suffering and punitive

damages the Act prohibits. See, e.g., Stacy v. Noble, 361 S.W.2d 285, 287 (Ky.

1962) (“there is no allowance for pain and suffering under the . . . Act”).

Exclusiveness of employers’ liability under the Act is clear

We read the Act’s exclusiveness of liability provision as quite clear

and comprehensive. “[T]he liability of such employer under this chapter shall be

exclusive and in place of all other liability of such employer to the employee . . .

and anyone otherwise entitled to recover damages from such employer at law or in

admiralty . . . .” KRS 342.690(1) (emphasis added). There is no ambiguity. The

statute limits the recovery of anyone to what is allowed by the Act.18 For the

18

As previously noted, that includes a third party’s pursuit of a contract claim pursuant to KRS 342.690(1) (third sentence).

-31-actual employer and any qualifying up-the-ladder employer like Scotty’s,19 there is

no further employer liability for the workplace accident.

Regardless of how circuitously they prosecuted their claim against

Scotty’s, Plaintiffs/Appellees should not have been permitted to succeed on a claim

against Scotty’s, an up-the-ladder employer whose liability to them is limited to the

benefits of the Act and whose immunity from further claims is secured by the same

law. KRS 342.690(1).

However, the trial court properly allowed Plaintiffs/Appellees to

pursue the Engineers as non-employer third-party tortfeasors.

19

The Supreme Court explained:

In Kentucky, “up-the-ladder immunity” refers to a contractor’s immunity from tort

lawsuits where the plaintiff was injured at work and workers’ compensation

benefits are the plaintiff’s exclusive remedy under Kentucky Revised Statutes

(KRS) 342.690. See General Elec. Co. v. Cain, 236 S.W.3d 579, 585 (Ky. 2007)

(“If premises owners are ‘contractors’ as defined in KRS 342.610(2)(b), they are

deemed to be the statutory, or ‘up-the-ladder,’ employers of individuals who are

injured while working on their premises and are liable for workers’ compensation

benefits unless the individuals’ immediate employers . . . have provided workers’

compensation coverage. If deemed to be ‘contractors,’ the owners, like any other

employers, are immune from tort liability [exclusive remedy immunity] with

respect to work-related injuries whether or not the immediate employer actually

provided workers’ compensation coverage.”).

Beaver v. Oakley, 279 S.W.3d 527, 528 n.1 (Ky. 2009). Hereafter, because of Scotty’s status as an up-the-ladder employer entitled to the Act’s protection, we are referring to Scotty’s when we use the term “employer.”

-32-Plaintiffs/Appellees properly pursued claim against the Engineers

KRS 342.700(1) tells the employee that exhausting the limits of his

employer’s liability under the Act need not end his pursuit of compensation. He

can sue a non-employer tortfeasor he believes was at fault. The statute is designed

to benefit both the employee and the employer.

For over a hundred years since its prior iteration became part of our

Workers’ Compensation Act, KRS 342.700(1) has been interpreted as:

defin[ing] the respective rights of the injured employee

and the employer/insurer when the employee’s injuries

were caused by the negligence of a third party. The

employer/insurer “owns” a subrogation right to the

amount of compensation it paid to the injured employee,

and the employee “owns” the right to any other damages

for which the third-party tortfeasor is legally liable.

Krahwinkel v. Commonwealth Aluminum Corp., 183 S.W.3d 154, 158 (Ky. 2006),

abrogated on other grounds by Dowell v. Matthews Contracting, 627 S.W.3d 890

(Ky. 2021) (decrying Krahwinkel’s reference to the Act as a voluntary contract

between employer and employee rather a voluntary election to participate in a

statutory alternative to tort litigation). In such a civil action against non-employer

third parties, the employer whose obligation to the employee has been fixed by the

Board “occupie[s] the same position as a settling tortfeasor[.]” Owens Corning

Fiberglas Corp. v. Parrish, 58 S.W.3d 467, 481 (Ky. 2001). Fortunately, the

apportionment statute, “KRS 411.182(4)[,] covers the workers’ compensation

-33-situation[.]” Ingersoll-Rand Co. v. Rice, 775 S.W.2d 924, 930 (Ky. App. 1989),

abrogated on other grounds as recognized in Cont’l Marine, Inc. v. Bayliner

Marine Corp., 929 S.W.2d 206 (Ky. App. 1996).

“KRS 411.182 does not require as a prerequisite for apportionment

that the settling person be joined as a party to the action. In fact, it implies that the

settling person will not be named a party to the action.” Parrish, 58 S.W.3d at

480. This case might have proceeded with Plaintiffs/Appellees, the Engineers, and

two “empty-chair” defendants. CertainTeed Corp. v. Dexter, 330 S.W.3d 64, 68

(Ky. 2010). That did not happen. Faced with potential liability, the Engineers

pursued their third-party claim for indemnity against Scotty’s and VanMeter.

Legal error from failing to enforce KRS 371.180

Once the Engineers argued that Standard Specifications section

107.13 required Scotty’s to indemnify them for their own negligence, Scotty’s

responded that such an interpretation violates KRS 371.180. We agree.20 The trial

court committed reversible error by denying Scotty’s motion for summary

judgment based on KRS 371.180.

20

We are not persuaded by Plaintiffs/Appellees’ argument that KRS 371.180 constitutes an affirmative defense that Scotty waived by not asserting in its answer. The third-party complaint does not allege section 107.13 requires Scotty’s to indemnify KTC for its or its employees’ own negligence. Affirmative defenses are assertions “constituting an avoidance” of an allegation. CR 8.03. Should we fault Scotty’s for not presuming the Engineers alleged a species of indemnification prohibited by law? When the Engineers finally argued section 107.13 indemnified them from their own rather than Scotty’s negligence, Scotty’s promptly raised the statute. Until then, KRS 371.180 did not “constitute an avoidance” of the claim of indemnification.

-34-KRS 371.180 is not difficult to understand. It declares “void and

wholly unenforceable” any provision in a “construction services contract

purporting to indemnify or hold harmless a contractor from that contractor’s own

negligence or from the negligence of his or her agents, or employees . . . .” KRS

371.180(2). The contract KTC let to Scotty’s is “[a] contract or agreement relating

to the construction . . . [of a] highway . . . or other structure, project, development,

or improvement attached to real estate . . . .” KRS 371.180(1)(a)1. As the statute’s

terms are defined, KTC is the “contractor.” KRS 371.180(1)(b) (“‘Contractor’

means the person offering a contract for services provided.”). Scotty’s was the

“contractee.” KRS 371.180(1)(c) (“‘Contractee’ means the person providing

services under a contract.”). The Engineers were KTC’s “agents, or employees[.]”

Plaintiffs/Appellees’ argument that KRS 371.180 does not apply to

the Commonwealth because “the Commonwealth is not a ‘person’” is simply

wrong. We have a definition in KRS 446.010 for “person” when that term is used

in a statute and not specifically defined in the relevant chapter, as here. The term

“person . . . may extend and be applied to bodies-politic . . . .” KRS 446.010(33).

That definition applies to the term “person” as used in KRS 371.180.

Additionally, consider KRS 371.180 itself. It expressly refers to

contracts for highway construction and improvement. KRS 371.180(1)(a)1.

Contracts between KTC and entities such as Scotty’s are essential to KTC’s

-35-“mission of providing a safe and reliable highway system . . . .” Ky. Exec. Order

No. 2008-529 (Jun. 16, 2008). KTC carries out that mission pursuant to

construction services contracts. It would be nonsensical to assume the statute does

not apply to contracts awarded by KTC to carry out its mission.

Similarly, we are unpersuaded by the argument that the statute only

makes the provision void as to KTC and “not the KTC employees.” When the

legislature declared all such provisions void rather than voidable, the only rational

interpretation is that the provision was void from the moment it was created.

Being void ab initio, such a provision creates no rights in anyone, starting with

those identified in the statute—“the Commonwealth, the Department, and all its

officers, agents, and employees[,]” and by necessary implication, the Engineers.

Although Plaintiffs/Appellees occasionally argued the provision

required Scotty’s to indemnify KTC for Scotty’s employees’ negligent acts, that is

not how the trial court interpreted and enforced it against Scotty’s. Even if not a

tactic intentionally pursued, it was a bait-and-switch outcome the court allowed.

Plaintiffs/Appellees’ original complaint sought to hold the Engineers

individually liable for their own negligence. That was, in fact, the result of the

consent judgment and the result of the bench trial. If there is evidence in this

record of Scotty’s negligence, it was not brought to our attention. More

-36-importantly, Scotty’s negligence was never adjudicated, nor was VanMeter’s, nor

was Plaintiffs/Appellees. In fact, the trial court found them all to be faultless.

This Court cannot conclude other than that the trial court interpreted

the provision as indemnifying the Engineers for their own negligence. The trial

court thus committed legal error by enforcing a contract provision the legislature

prohibited by enacting KRS 371.180 declaring such a provision void.

Indemnity provision lacks required clarity to be enforced as it was in this case

Even without the clear prohibition of KRS 371.180, section 107.13

falls far short of clearing our jurisprudential hurdle for enforcing a provision

indemnifying the indemnitee against his own negligence. “[S]uch contracts are

disfavored and are strictly construed against the parties relying upon them.” Hargis

v. Baize, 168 S.W.3d 36, 47 (Ky. 2005).

If a party intends to hold another to such a contract provision, it “must

contain utmost clarity in order to be enforceable. Its wording must be ‘so clear and

understandable that an ordinarily prudent and knowledgeable party to it will know

what he or she is contracting away; it must be unmistakable.’” Speedway, 250

S.W.3d at 341 (quoting Hargis, 168 S.W.3d at 47). Even the trial court struggled

early to read section 107.13 the way the Engineers and the Plaintiffs/Appellees

wanted. The obvious lack of clarity makes section 107.13 unenforceable. The trial

court erred when it ruled Standard Specifications section 107.13 was sufficiently

-37-clear that the Engineers could enforce it and compel Scotty’s to indemnify them for

the damages they caused by their own breach of duty.

That brings us to the assignment. And that begs a question Justice

Noble once posed in Associated Insurance Service, Inc. v. Garcia, supra. “[M]y

first question[,]” she said, “was whether there was anything to assign to the

Appellees[.]” 307 S.W.3d at 70 (Noble, J., concurring).

Engineers possessed nothing assignable to Plaintiffs/Appellees

The assignment that accompanied the consent judgment was in the

nature of a “mere quitclaim[]” that transferred “such rights, title and interest as

belonged to the assignors at the time of the making of the several assignments and

no more[.]” Arnett v. Stephens, 251 S.W. 947, 950 (Ky. 1923). The Engineers

used language in the assignment and consent judgment, as set forth above,

indicating at least their suspicion that what they were assigning might be illusory.

See id. at 951 (quitclaim places “grantee upon notice . . . his grantor has doubts”).

Indeed, it was.

KTC had no indemnity claim to assign, statutorily prohibited and

judicially incognizable as it was. Claiming indemnity derivatively from KTC did

not spontaneously generate a right the Engineers could claim from the nothing

KTC possessed. Creatio ex nihilo does not apply in the law any more than it

applies in any other field but theology.

-38-Because the indemnity provision was void under KRS 371.180 and

voidable under Hargis, supra, the claim Engineers assigned to Plaintiffs/Appellees

never existed. Plaintiffs/Appellees, therefore, had no claim against Scotty’s for

indemnity and the trial court committed reversible error by holding Scotty’s liable

for the judgment Plaintiffs/Appellees obtained against the Engineers.

The irregularities of the trial constituted reversible error

Scotty’s politely characterizes the improper ex parte trial in this case

as the trial court’s “departure from the traditional adversarial process[.]” (Scotty’s

Br., p. i). Specific arguments that the process violated due process are less subtle.

Had the trial court not committed the legal errors already discussed, it

might not have proceeded as it did, erroneously, “[u]nder the procedure

contemplated by Garcia”—an opinion that had nothing to do with the Act and,

therefore, did not proceed within the scope of its subject matter.

Trial court conducted improper, non-adversarial, ex parte proceeding

The court in Garcia did not conduct an ex parte trial, nor can the

Supreme Court’s opinion be read as approving of such a trial.

True ex parte trials are not unheard of in our jurisprudence, being

defined as “[a] trial in which only one side of the case is heard, usu. because the

opposing party is not present.” Trial, BLACK’S LAW DICTIONARY (12th ed. 2024)

(defining “ex parte trial” within this definition). However, permissible ex parte

-39-trials are also defined as “trials in absentia,” meaning, “A trial held without the

accused being present. In the United States, a trial may be held in absentia only if

the accused has either voluntarily left after the trial has started or else so disrupted

the proceedings that the judge orders the accused’s removal as a last resort.” Id.

(defining “trial in absentia” within this definition).

This was not a trial in absentia. Scotty’s and VanMeter wanted to

participate, and the trial court refused to allow it despite their clear right to do so.

G & J Pepsi-Cola Bottlers, Inc. v. Fletcher, 229 S.W.3d 915, 918 (Ky. App. 2007)

(discussing “the law regarding an employer’s subrogation rights as set out in State

Farm [Mut. Ins. Co.] v. Fireman’s Fund [American Ins. Co., 550 S.W.2d 554 (Ky.

1977)]”). This general condemnation of the non-adversarial proceeding is

supported by the trial court’s specific due process violations. We do not address

all the due process violations but enough to compel reversal of the judgment.

Trial court violated Scotty’s due process by denying right to be heard

As discussed above in the section on subject matter jurisdiction, our

statutes and jurisprudence clearly entitle an employer to participate in trials

conducted pursuant to KRS 342.700(1). See Dix, 799 S.W.2d at 30. The trial

court erred when it prohibited Scotty’s and VanMeter’s trial participation because

it deprived them of their due process right to be heard. Ford Motor Company v.

-40-Duckworth, 615 S.W.3d 26, 33 (Ky. 2021) (“fundamental requirement of due

process is the opportunity to be heard”). That fundamental error justifies reversal.

Trial court erred by failing to conduct a jury trial

The trial court also refused Scotty’s demand for a jury trial. Our

Supreme Court, emphasizing the sanctity and inviolability of the right to trial by

jury in one of its most consequential opinions, declared: “Henceforth, legislation

and civil rules of practice shall be construed strictly and observed vigilantly in

favor of the right and is not to be abrogated arbitrarily by the courts. The

constitutional right to a jury trial cannot be annulled, obstructed, impaired, or

restricted by legislative or judicial action.” Steelvest, Inc. v. Scansteel Service

Center, Inc., 908 S.W.2d 104, 108 (Ky. 1995).

Scotty’s never waived its jury trial demand. For that matter, we do

not know that Plaintiffs/Appellees or the Engineers ever waived their jury demand.

The trial court erred in conducting a bench trial in violation of Scotty’s rights to a

jury trial guaranteed by the Seventh Amendment to the United States Constitution

and Section 7 of the Kentucky Constitution. That error justifies reversal.

Trial court erred by finding the Engineers’ negligence the sole proximate cause

Beyond procedural error and even the KRS 342.700(1) jurisprudence

that prohibits an employee from “recover[ing] all of his loss from a negligent third

party[,]” Dix, 799 S.W.2d at 30 (emphasis added), there is another reason

-41-apportioning all fault to the Engineers requires reversal of the judgment. It is

logically and legally impossible for the Engineers to be the sole proximate cause of

Plaintiffs/Appellees’ injuries.

The trial court failed to recognize the legal effect of finding the

Engineers’ breach of duty to inspect not merely a substantial cause of the accident,

but the only cause, by apportioning 100% of the fault to them. That made their

negligence the only possible, and therefore the sole, proximate cause.

As a simple matter of physics, the Engineers’ breach of their duty to

inspect, or even a breach of duty to stop work, could not have caused the form and

concrete to rise and fall on the workers. Therefore, as a matter of logic and law,

the Engineers’ negligence could not have been “the primary and efficient cause of

the injury[.]” Memorial Sports Complex, LLC v. McCormick, 499 S.W.3d 700,

703 (Ky. App. 2016) (citation omitted). See also id. at 705 (distinguishing conduct

that was “‘the primary and efficient cause of the injury’” from a third-party

defendant whose remote conduct was not).

In prior cases where the injured party was alleged to have been

“negligent in inspection . . . it could not be said that the defendant’s negligence

was primarily the cause of the trouble.” Cumberland Tel. & Tel. Co. v. Mayfield

Water & Light Co., 179 S.W. 388, 389 (Ky. 1915). In Cumberland Telephone, the

court summarized several cases in which one party owed a duty to warn or inspect

-42-or discover a danger created by the negligence of another party that, left

uncorrected, resulted in the injuries of a claimant. Id. at 388–89. “In all of these

cases it will be observed that the primary and efficient cause of the injury was the

negligence of one party, and that the other party [who failed to inspect and

otherwise intercede] was held liable to the injured party for negligence of a lesser

degree and of a different character.” Id. at 389 (emphasis added).

The Engineers’ breach of duty to inspect cannot be, either rationally

or legally, the primary and efficient cause of the accident. But the trial court never

found any other party liable much less the actual primary and efficient cause of

Plaintiffs/Appellees’ injuries. Occasional reference to safety regulations was as far

as the quest for that cause went. The trial court relied solely on assumption.

In Meredith, this Court identified the basis for the trial court’s

assumption of VanMeter’s breach of duty. It was Plaintiffs/Appellees’

“alleg[ations] that Defendants [Engineers] were negligent, . . . as evidenced by the

[KOSHA] citations, even though the parties concur that the cited violations were

not directly related to the collapse of the concrete forms.” Meredith, 2018 WL

4054940, at *2 (quoting the trial court’s order). As the Supreme Court noted in

Groce, the safety citations and VanMeter’s settlement agreement after challenging

them “precludes the use of the [settlement] agreement as a conclusive judicial

admission of a safety violation.” Groce, 539 S.W.3d at 682.

-43-“Even without the express admission-disclaimer language, . . . an

adjudicative determination by an administrative tribunal does not preclude

relitigation in another tribunal . . . .” Id. (internal quotation marks and citations

omitted). Relitigation of the issue, which might have found the necessary facts in

this distinct tribunal, never occurred. No other evidence this Court has seen in its

review satisfies the standard for recognizing a judicial admission of VanMeter’s

employees’ negligence.21 Nevertheless, the trial court treated the allegations,

evidence, and the assumption of negligence as fact.

Adversarial adjudication and judicial determination of that predicate

fact was essential to finding the Engineers’ negligence was also a proximate cause

21

Inexplicably, VanMeter’s own counsel states in its brief, “VanMeter, in its filings and depositions below, admitted that the accident occurred because of its own failure to use appropriate anchoring [which] did not fall within the supervision or control of [KTC] or its Employees.” (VanMeter Br., p. 17 (citing R. 639–45)). The record reference to support that statement directs us to VanMeter’s Memorandum supporting its Motion for Partial Summary Judgment, filed July 21, 2014. In fact, it says nothing of the sort. In any event, that was eighteen months before VanMeter convinced the ALJ in Groce on December 3, 2015, that the complete opposite was true. Thereafter, VanMeter said in a subsequent Memorandum to the trial court, “There is no evidence in the record that these violations [relating to improper fall protection and inadequate trenching] contributed to the failure of the form.” (VanMeter Memorandum, Jan. 21, 2016). More importantly, nothing we saw in the record justifies treating the mere assumption as a judicial admission, i.e., a “formal act” having “the effect of waiving or dispensing with the necessity of producing evidence by the opponent . . . .” Reece v. Dixie Warehouse and Cartage Co., 188 S.W.3d 440, 448 (Ky. App. 2006). Nothing indicates the trial court deemed it so. Regardless, “[w]hether a statement is a judicial admission is a question of law, which is reviewed de novo, ‘without deference to the interpretation afforded by the circuit court.’” Id. (citation omitted). Applying the standard set forth in Reece, supra, there is no basis for finding a judicial admission that the accident occurred because of the failures of VanMeter’s employees.

-44-of Plaintiffs/Appellees’ injuries, albeit of a lesser degree and different character.

The trial court’s “ex parte” trial made finding that necessary fact impossible.

To this day, whether Plaintiffs/Appellees or other VanMeter

employees failed to properly secure the concrete form, thereby creating the

dangerous condition the Engineers allegedly failed to discover, has been

adjudicated in only one forum—in the hearing before the ALJ who heard Jamie

Groce’s workers’ compensation claim. In that forum, the only uncontradicted

evidence regarding causation was that the accident was caused by an

undiscoverable defective anchor bolt. See Memorial Sports, 499 S.W.3d at 704

(“[P]roviders of a defective product [are] primarily liable over other parties who

may have failed to inspect, warn or supervise.”).

No party suggests issue preclusion should be applied here, nor do we

decide—nor need decide—whether it does. What is determinative, however, is

that the trial court never adjudicated this question. Without it, no percentage of

fault could possibly be calculated against or attributed to the Engineers.

Determining the primary and efficient proximate cause is

indispensible. The Engineers’ confession of their own negligence is not enough.

To constitute a “proximate cause” of an injury, the

negligence complained of . . . must do more . . . than

merely furnish the condition or give rise to the occasion

by which the injury was made possible. If it is not the

immediate or direct cause . . . [it] requires the intervention

of an immediate or direct cause to bring about the

-45-result . . . .

Dixon v. Kentucky Utilities Co., 174 S.W.2d 19, 21 (Ky. 1943). The Engineers’

negligence may have given rise to the possibility of an injury but there was no

determination that Scotty’s, VanMeter, or the acts of either entities’ employees

intervened to bring about the result.

In sum, the trial court never found any person’s conduct was the

primary and efficient cause of Plaintiffs/Appellees’ injuries. Absent that finding,

we cannot, on this record, reach the legal conclusion that the Engineers’ breach

was a proximate cause of Plaintiffs/Appellees’ injuries for it is just as easy to

speculate that if the Engineers had inspected they would have found—as the ALJ

found and the Supreme Court affirmed—that VanMeter employees did properly

secure the form before pouring concrete and, therefore, breached no duty. There is

no basis for believing the Engineers owed a duty to discover product defects—such

as the purported defect in the anchor bolt—before they fail. The Engineers’ breach

of a duty to inspect cannot constitute a proximate cause or, perhaps, any cause at

all.

Therefore, having failed to establish the necessary direct, primary and

efficient cause of Plaintiffs/Appellees’ injuries, we must reverse the trial court’s

December 11, 2023 Findings of Fact, Conclusions of Law, and Judgment holding

the Engineers liable for damages in excess of $22.5M.

-46-CONCLUSION

Scotty’s seeks reversal of the judgment and dismissal of the claims

against it. In the alternative, Scotty’s asks for a new trial. If we grant the new

trial, we will be adding more years to the nearly fourteen that have transpired since

the accident, with no possibility that Plaintiffs/Appellees would be any better off,

and perhaps they would be worse off, perhaps having to satisfy a subrogation

obligation the Engineers might owe to VanMeter for the compensation paid to

Plaintiffs/Appellees.

Perhaps a new trial would allow the court to correct its errors and

perhaps the Plaintiffs/Appellees could prove the predicate fact of the VanMeter

employees’ negligence, but to what end? Plaintiffs/Appellees can recover no more

from VanMeter, no more from Scotty’s, and by their own agreement, they can

recover no more from the Engineers. Reversal of the judgment is the only just

solution.

For the foregoing reasons, we reverse the judgment and remand with

instructions to dismiss all claims without exception.

ALL CONCUR.

-47-BRIEFS FOR APPELLANT: BRIEF AND ORAL ARGUMENTS

FOR APPELLEE VANMETER

Frank Hampton Moore, Jr. CONTRACTING, INC.:

Bowling Green, Kentucky

Robert Jenkins

Douglas W. Langdon Meghan Goins

Griffin Terry Sumner Michael P. Casey

J. Kendrick Wells IV Patrick Schmeckpeper

Louisville, Kentucky Lexington, Kentucky

ORAL ARGUMENTS FOR BRIEF AND ORAL ARGUMENTS

APPELLANT: FOR APPELLEES MEREDITH,

GERALDS, GRAVES, LAPHAM,

Griffin Terry Sumner LAM, PRICE, AND ESTATE OF

J. Kendrick Wells IV MARK LOVE:

Louisville, Kentucky

Thomas N. Kerrick

AMICUS BRIEF ON BEHALF OF Shawn Rosso Alcott

KENTUCKY ASSOCIATION OF Laura M. Hagan

HIGHWAY CONTRACTORS: Bowling Green, Kentucky

Bethany Breetz BRIEF AND ORAL ARGUMENTS

Steven Henderson FOR APPELLEES DECKER,

Louisville, Kentucky ESTATE OF DECKER, GROCE,

MCINTOSH, AND NELSONS:

Jamie K. Neal

Kevin C. Burke

Louisville, Kentucky

Mike Breen

William J. Williford

Bowling Green, Kentucky

-48-