Patton v. Timbrook

Summary

The Kentucky Supreme Court held that the 1990 Budget Bill did not repeal the 1988 Probation and Parole Career Ladder Program. Instead, it authorized probation and parole officers to receive the greater of the Career Ladder benefits or the Salary Equity Fund benefits, including only partial Salary Equity Fund benefits when necessary to reach that level. The court affirmed in part, reversed in part, and remanded for entry of judgments consistent with its opinion.

Holdings

1. The 1990 Budget Bill did not repeal the Career Ladder Program; it continued the program while limiting Salary Equity Fund benefits for probation and parole officers to supplemental amounts necessary to provide the greater of the two authorized salary adjustments.
2. Probation and parole officers were entitled to Career Ladder benefits plus only partial Salary Equity Fund benefits when necessary to bring their total salary adjustment up to the full Salary Equity Fund level; they were not entitled to both Career Ladder benefits and full Salary Equity Fund benefits.

Questions Presented

1. Whether the 1990 Budget Bill repealed the 1988 Probation and Parole Career Ladder Program.
2. Whether probation and parole officers were entitled to receive both the full Career Ladder Program increase and the full Salary Equity Fund increase.
3. Whether the court needed to reach the claimants' alleged violations of Section 51 of the Kentucky Constitution, KRS 446.085, and KRS 446.145.

Disposition

reversed_and_remanded