Andy Beshear, in His Official Capacity as Governor of the Commonwealth of Kentucky v. Ridgeway Properties, LLC d/b/a Beans Café & Bakery

Summary

The Supreme Court of Kentucky held that Ridgeway Properties, LLC d/b/a Beans Café & Bakery lacked constitutional standing because it had no actual or imminent injury arising from the 2021 COVID-19 legislation or executive-branch enforcement. The court also held that the Attorney General’s participation could not supply a justiciable controversy in the Boone Circuit Court because the constitutionality of the same legislation was already being litigated in the first-filed Franklin Circuit Court action. The court reversed and remanded for dismissal of the action in its entirety.

Holdings

1. Beans lacked standing because it suffered no concrete, particularized, actual, or imminent injury caused by the Governor or executive branch after the 2021 legislation became effective. A speculative fear of future enforcement was insufficient.
2. Because Beans lacked standing, the Boone Circuit Court lacked jurisdiction to adjudicate the Third Amended Complaint, declare the 2021 legislation constitutional, or issue injunctive relief.
3. The Attorney General could not supply the Boone Circuit Court with a justiciable cause because the Attorney General and Governor were already litigating the constitutionality of the 2021 legislation in the first-filed Franklin Circuit Court action.
4. The Boone Circuit Court lacked authority to issue a statewide injunction through Beans's Third Amended Complaint because the court lacked jurisdiction over the action and Beans had no standing.

Questions Presented

1. Whether Beans had constitutional standing to challenge the 2021 COVID-19 legislation and obtain declaratory and injunctive relief when it had suffered no actual or imminent post-legislation injury.
2. Whether the Boone Circuit Court had subject-matter jurisdiction to adjudicate the action and issue declaratory or injunctive relief without a plaintiff presenting a justiciable cause.
3. Whether the Attorney General's status as an intervening plaintiff could cure Beans's lack of standing when the Attorney General and Governor were already litigating the constitutionality of the same legislation in Franklin Circuit Court.
4. Whether the Boone Circuit Court could issue a statewide injunction through Beans's Third Amended Complaint.

Disposition

reversed_and_remanded