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Request By:

Mr. David H. Bland
Kentucky Jailers Association
McCowans Ferry Road
Versailles, Kentucky 40383

Opinion

Opinion By: Steven L. Beshear, Attorney General; By: Charles W. Runyan, Assistant Deputy Attorney General

Mr. Charles Ladd has for some time operated a restaurant in Princeton, Kentucky. He became jailer of Caldwell County in 1981. Because the county did not and still does not provide the jail a cook or cooking equipment and utensils, Mr. Ladd decided to serve the prisoners from his restaurant and bill the jail account for each meal served. To date this has been the procedure and all billings have been property accounted.

Question No. 1:

Since the county has chosen not to provide staff or equipment for prisoner food preparation, is Mr. Ladd in a conflict of interest situation?

The jailer has the responsibility to furnish prisoners with proper food under the terms of KRS 71.040. Further, the fiscal court, so long as there is a jail in the county under H.B. 440 (1982 regular session), has the implied duty of equipping the county jail with the basic equipment necessary in the preparation and storage of food for prisoners fed therein. Thus a stove, refrigerator, cooking and kitchenware are items necessary for that role. See

Breathitt County v. Cockrell, 250 Ky. 743, 63 S.W.2d 920 (1933) 922. Under H.B. 440 (1982), the jailer no longer (H.B. 440, Sect. 50, repealed KRS 64.150, jailer's fees) is a fee officer. He must be paid a salary. The Caldwell County Attorney and County Judge Executive have informed this office that the ancient practice in that county is that the jailer furnishes his own cook stove for the jail and his wife is the cook.

The recent case of

Buchignani v. Lexington-Fayette Urban County Government, Ky., App., S.W.2d (April 30, 1982), reiterated the judicial principle that a jailer is prohibited from operating any business in connection with the jail for profit. See OAG 80-525, copy enclosed, Miller v. Porter, 47 Ky. (B. Monroe, Vol. 8, 1847-8) 282, and Thompson v. Probert, 65 Ky. (Bush Vol. 2) 144 (1867).

It is our view that the fiscal court and the jailer can get together and establish a "no profit" figure for the food prepared in the restaurant, such that, in essence, the situation would be essentially equivalent to the jailer's preparing the food in the jail at no profit.

Your second question relates to the fiscal court's authorizing the purchase of prisoner meals from the jailer's restaurant. You ask whether that would violate any constitutional prohibition against a public official realizing a profit from his public office? In the above case of Buchignani, the Court of Appeals held that the jailer's operating a commissary on public property for a profit violated § 173 of the Kentucky Constitution. However, where the fiscal court and the jailer work out an established "no profit" figure on the food so purchased, we see no problem.

LLM Summary
The decision addresses whether a jailer, who provides meals to prisoners from his own restaurant due to the lack of county-provided cooking facilities, is in a conflict of interest. It discusses the responsibilities of the jailer and the fiscal court under Kentucky law and previous legal precedents, concluding that a 'no profit' arrangement could be established to avoid any conflict of interest. The decision also considers the legality of the fiscal court authorizing the purchase of meals from the jailer's restaurant, suggesting that a 'no profit' agreement would not violate constitutional prohibitions against public officials profiting from their office.
Disclaimer:
The Sunshine Law Library is not exhaustive and may contain errors from source documents or the import process. Nothing on this website should be taken as legal advice. It is always best to consult with primary sources and appropriate counsel before taking any action.
Type:
Opinion
Lexis Citation:
1982 Ky. AG LEXIS 277
Cites:
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