Bradwell Scott Chaney v. Heather Fields
2020 CA 000254
| Ky. Ct. App. | Oct 28, 2021Background
- Heather Fields worked for Pikeville Foot Care Center, PLLC (managed by Bradwell Scott Chaney) from 2012–2018; employer withheld payroll deductions for taxes and benefits.
- Fields alleged Chaney converted withheld funds instead of paying required federal/state taxes and payroll obligations, causing financial harm and inaccurate tax filings.
- Fields sued both Chaney and the business; Chaney (not an attorney) improperly filed an answer on behalf of the PLLC. The court struck his pleadings and entered summary judgment for Fields after discovery noncompliance.
- At a damages hearing the court found Chaney had converted withheld monies and awarded $17,330.37 plus 6% interest.
- Defendants appealed, arguing (1) federal tax statutes (26 U.S.C. §3403 / Anti‑Injunction Act principles) bar Fields’s claim, and (2) the circuit court lacked subject‑matter jurisdiction.
- The Kentucky Court of Appeals affirmed, holding Fields’s conversion claim was not statutorily barred and the circuit court had jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal tax statutes/Anti‑Injunction Act bar the suit | Fields: this is a conversion claim — she wanted withholdings made; she alleges conversion of withheld funds | Defs: 26 U.S.C. §3403 and Anti‑Injunction Act prohibit suits that challenge employer withholding or collection | Court: Rejected defendants — claim alleges conversion of funds, not a suit to restrain tax withholding or collection; statutory bar inapplicable |
| Whether circuit court had subject‑matter jurisdiction over conversion claim | Fields: common‑law conversion is within circuit court jurisdiction | Defs: court lacked jurisdiction (no further development) | Court: Circuit court had jurisdiction; affirmance |
Key Cases Cited
- C&H Mfg., LLC v. Harlan County Indus. Dev. Auth., 600 S.W.3d 740 (Ky. App. 2020) (sets out elements of conversion)
- Jones v. Marquis Terminal, Inc., 454 S.W.3d 849 (Ky. App. 2014) (conversion elements relied upon)
- State Auto. Mut. Ins. Co. v. Chrysler Credit Corp., 792 S.W.2d 626 (Ky. App. 1990) (definition/characterization of conversion)
- Benningfield v. Pettit Environmental, Inc., 183 S.W.3d 567 (Ky. App. 2005) (de novo review of legal questions)
- Chandler v. Perini Power Constructors, Inc., 520 F. Supp. 1152 (D.N.H. 1981) (example applying Anti‑Injunction Act to bar suits restraining tax collection)