District Court, W.D. Kentucky — appointed by Jimmy Carter
MacKins v. Astrue
District Court, W.D. Kentucky · 2009-07-31 · cited 11×
This case involved a claim for disability insurance and supplemental security income benefits by a claimant in her mid-thirties who alleged disability due to a work-related back injury and related physical and mental limitations. The ALJ denied benefits at step five of the sequential evaluation process after finding the claimant could perform a range of light work, relying on a vocational expert's testimony identifying jobs such as copy machine operator that she could still do. The court decided to remand the case to the Commissioner for a new decision and new vocational hypotheticals and testimony. The core reasoning was that the controlling hypothetical posed to the vocational expert failed to incorporate all of the claimant's vocationally significant limitations, including moderate limitations in maintaining attention and concentration for extended periods as assessed by state agency psychologists, and there were discrepancies between the RFC findings, medical opinions, and the hypothetical questions.
healthcareprocedurefederal power
Dennis v. Astrue
District Court, W.D. Kentucky · 2009-07-29 · cited 1×
This case involved a claim for Social Security disability insurance benefits in which the plaintiff alleged onset of disability on September 15, 1998, due to diffuse body pain, elevated liver enzymes, and related mental impairments, before her date last insured of December 31, 2001. The ALJ denied benefits, finding no severe physical impairments and rejecting the alleged onset date based on insufficient corroboration and other factors. The district court adopted the magistrate judge's report and recommendation, determining that the claimant's testimony, lay witness statements, and medical expert opinions provided substantial evidence supporting disability as of the alleged onset date under SSR 83-20, and that the ALJ's credibility assessment was inadequate. The case was remanded to the Commissioner for calculation and payment of past-due Title II benefits.
federal powerhealthcareprocedure
Gentry v. Deuth
District Court, W.D. Kentucky · 2005-07-22
This case concerns Carrie Gentry's federal habeas corpus petition after her state conviction for second-degree manslaughter and driving under the influence, which stemmed from a fatal car accident. Gentry had challenged the conviction on Sixth Amendment grounds because five prosecution witnesses testified via two-way closed-circuit television rather than in person. The district court previously issued a conditional writ of habeas corpus requiring the Commonwealth to retry her within ninety days or face an absolute writ vacating the conviction. Because the state neither retried Gentry nor pursued its appeal, the court now converts the writ to absolute and orders the state judgment of conviction vacated to eliminate ongoing collateral consequences such as loss of driving privileges and felony status. The decision rests on precedents recognizing federal habeas courts' authority to fashion relief that removes such burdens even after a sentence has been fully served.
criminal lawprocedure
Gentry v. Deuth
District Court, W.D. Kentucky · 2004-05-21
This case involves a federal habeas corpus petition by Gentry challenging her state convictions for second-degree manslaughter and driving under the influence arising from a fatal traffic accident. The court had previously found that admission of expert witness testimony via two-way closed-circuit television violated Gentry's confrontation rights under Maryland v. Craig but deemed the error harmless under Brecht v. Abrahamson because the testimony likely would not have changed if given in person. On a motion to alter or amend the judgment, the court reexamined the harmless-error analysis in light of Sixth Circuit precedent in Brumley v. Wingard and Stoner v. Sowders, which require evaluating whether the remaining evidence without the improperly admitted testimony would support the verdict. The court concluded that the expert testimony on blood alcohol, DNA, fiber identification, and occupant roles was essential to the prosecution's case, and without it the evidence was insufficient to sustain the convictions. Accordingly, the court vacated its prior judgment, denied summary judgment for the respondent, and conditionally granted habeas relief requiring retrial within ninety days.
criminal lawprocedurecivil rights
Gentry v. Deuth
District Court, W.D. Kentucky · 2004-03-18
This habeas corpus case involves petitioner Carrie Gentry's challenge to her Kentucky state convictions for second-degree manslaughter and DUI, arising from a fatal car accident. Gentry argued that allowing five prosecution expert witnesses to testify via two-way live video conferencing, rather than in person, violated her Sixth Amendment Confrontation Clause rights because the state offered no compelling interest or necessity finding to justify the remote testimony, contrary to Maryland v. Craig. The district court agreed that the Kentucky courts had unreasonably applied Craig and that the procedure infringed her confrontation rights, but concluded the error was harmless because it did not substantially affect the jury's verdict. Accordingly, the court granted the state's motion for summary judgment and dismissed the habeas petition.
criminal lawprocedure
Carpenter v. HEALTHSOUTH CORP.
District Court, W.D. Kentucky · 2003-10-28
This case involved a former employee's claims that her employer, HealthSouth, discriminated against her based on sex by not promoting her to Area Controller, retaliated against her for complaining about sex discrimination in a subordinate's pay, and constructively discharged her by creating intolerable working conditions, in violation of Kentucky law (KRS 344.040). The court granted the defendants' motion for summary judgment, holding that there was no genuine dispute of material fact. The court reasoned that the plaintiff could not establish a prima facie discrimination or retaliation case because she was offered an interview for the position but declined it, effectively withdrawing her application, and that the single disputed incident and other circumstances were not severe or pervasive enough to constitute an objectively intolerable work environment supporting a constructive discharge claim.
labor & employmentcivil rights