Louisville Historical League, Inc. v. louisville/jefferson County Metro Government, 709 S.W.3d 213

Louisville/Jefferson County Metro Government (LJCMG) entered into a contract with Omni Louisville, LLC, involving a parcel containing Liberty Hall, requiring LJCMG to remove legal impediments (like landmark status) to allow its demolition.
In 2019, Metro Council initiated a landmark review for Liberty Hall, but later rejected the designation citing history of racism and lack of architectural significance.
Louisville Historical League, Inc. (LHL) challenged the Council's decision in Jefferson Circuit Court, asserting due process violations and arbitrary action by Metro Council.
The Circuit Court found in favor of LHL, ruling the hearing was tainted by predetermined outcomes due to the pre-existing contract with Omni.
On appeal, the Court of Appeals found LHL failed to plead particularized injury or aggrievement as required by local ordinance, thus depriving the Circuit Court of subject matter jurisdiction.
The Supreme Court of Kentucky granted discretionary review to address the jurisdictional and merits questions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether failure to plead injury/aggrievement deprives subject matter jurisdiction or only particular-case jurisdiction	LHL complied or issue was waived as not raised below	Strict pleading is jurisdictional and must be strictly enforced	Failure is an issue of particular-case jurisdiction, not subject matter; issue was waived
Existence of a constitutional right to judicial review of administrative arbitrariness absent statutory grant	Courts can review for arbitrariness even without statute	Review must be strictly permitted by statute unless complied	Judiciary has inherent constitutional authority to review administrative acts for arbitrariness
Whether Metro Council’s reversal of landmark status was arbitrary or due to conflict of interest	Decision was predetermined, contract with Omni tainted process	Contractual duty did not equate to arbitrariness or favoritism	No arbitrariness; contract was relevant, but not sole or unlawful basis for decision
Whether new evidence improperly considered at Council hearing	New evidence not before Commission should not be considered	Public hearing permitted broader evidence	Council acted within its authority as public hearing allowed considering broader information

Kenton Cnty. Bd. of Adj. v. Meitzen, 607 S.W.3d 586 (Ky. 2020) (standing and injury pleading requirements for administrative appeals)
American Beauty Homes Corp. v. Louisville and Jefferson County Planning and Zoning Commission, 379 S.W.2d 450 (Ky. 1964) (judicial review of administrative acts for arbitrariness is constitutionally based)
Hilltop Basic Resources, Inc. v. Cnty. of Boone, 180 S.W.3d 464 (Ky. 2005) (distinction between legitimate policy preference and arbitrary predetermined decisions by government actors)
Louisville Gas & Elec. Co. v. Hardin & Meade Cnty. Property Owners for Co-Location, 319 S.W.3d 397 (Ky. 2010) (strict compliance in administrative appeals)
Commonwealth v. Steadman, 411 S.W.3d 717 (Ky. 2013) (particular-case jurisdiction versus subject-matter jurisdiction)