Pearce v. University of Louisville ex rel. Board of Trustees, 448 S.W.3d 746

Two police officers (Jeffery Pearce, Univ. of Louisville campus officer; Stephen Hill, Mt. Washington officer) were disciplined after allegations originating within their departments (termination in Pearce; suspension/demotion in Hill).
Both officers sought the administrative hearing and procedural protections of the Kentucky Police Officer’s Bill of Rights, KRS 15.520; their requests were denied by department authorities and trial courts.
Court of Appeals panels held KRS 15.520 applies only when disciplinary proceedings are triggered by an external "citizen’s complaint," and therefore officers with internally initiated discipline were not entitled to its protections.
The Kentucky Supreme Court granted review to resolve whether KRS 15.520’s procedural protections apply to intra‑departmental disciplinary actions as well as those originating from outside the department.
The majority concluded the statute’s plain text and structure show no limitation to citizen‑originated complaints and held KRS 15.520 applies to both internal and external complaints; cases were reversed and remanded.
A dissent argued the statute should be harmonized with preexisting statutory disciplinary schemes (various KRS chapters) and therefore limited to citizen complaints to avoid conflict and implied repeal of older laws.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether KRS 15.520’s procedural protections apply to disciplinary proceedings originating within a police department (intra‑departmental complaints) as well as to those initiated by external/citizen complaints	Pearce/Hill: statute’s language is broad ("any complaint," "any individual," "any hearing") and its purpose (set administrative due process rights) applies to all administrative disciplinary proceedings regardless of complaint source	Univ. of Louisville/Mt. Washington: KRS 15.520 was intended to implement a citizen‑complaint redress mechanism; applying it to internal discipline conflicts with and would override existing statutory schemes that tailor process by jurisdiction and government form	Court holds KRS 15.520 applies to both intra‑departmental and citizen‑originated disciplinary proceedings; reverses Court of Appeals and remands for further proceedings consistent with that holding

Cumberland Valley Contractors, Inc. v. Bell County Coal Corp., 238 S.W.3d 644 (Ky. 2007) (statutory construction reviewed de novo)
Richardson v. Louisville/Jefferson County Metro Government, 260 S.W.3d 777 (Ky. 2008) (interpret statutes by plain language to determine legislative intent)
MPM Financial Group Inc. v. Morton, 289 S.W.3d 193 (Ky. 2009) (if statute ambiguous, examine legislative history and public policy)
Lichtenstein v. Barbanel, 322 S.W.3d 27 (Ky. 2010) (read statutes as a whole and in context with other laws)
Withers v. University of Kentucky, 939 S.W.2d 340 (Ky. 1997) (specific, later statute controls over earlier general statute)
City of Munfordville v. Sheldon, 977 S.W.2d 497 (Ky. 1998) (KRS 15.520 requires a hearing before adverse action based on a citizen complaint)
Commonwealth v. Brasher, 842 S.W.2d 535 (Ky. App. 1992) (later-specific statute controls earlier-general statute)