Balancing Mental Health Mitigation and Recidivist Misconduct in Negotiated Attorney Sanctions: Commentary on In re Daniel Louis Thompson

Balancing Mental Health Mitigation and Recidivist Misconduct in Negotiated Attorney Sanctions: Commentary on In re Daniel Louis Thompson

I. Introduction

The Supreme Court of Kentucky’s opinion and order in In re: Daniel Louis Thompson, 2025-SC-0423-KB (Dec. 18, 2025), addresses a negotiated disciplinary sanction arising from two consolidated disciplinary proceedings against attorney Daniel Louis Thompson. Acting under Supreme Court Rule (SCR) 3.480(2), the Court approved a 180-day suspension from the practice of law, fully probated for two years with extensive conditions.

The case is significant in several respects:

  • It illustrates how Kentucky’s high court evaluates and either accepts or rejects negotiated sanctions under SCR 3.480(2).
  • It reinforces that violation of a Domestic Violence Order (DVO) constitutes both disobedience of a tribunal (SCR 3.130(3.4)(c)) and a criminal act reflecting adversely on a lawyer’s fitness (SCR 3.130(8.4)(b)).
  • It demonstrates how untreated mental health conditions can mitigate sanction severity while simultaneously justifying stringent, treatment-focused probationary conditions.
  • It clarifies the interaction between prior disciplinary history as an aggravating factor and personal/mental-health circumstances as mitigating factors in calibrating an appropriate sanction.

The parties involved were:

  • Respondent: Daniel Louis Thompson, Kentucky Bar Association (KBA) Member No. 90712, admitted in 2005.
  • Office of Bar Counsel (OBC): The investigative and prosecutorial arm of the KBA in disciplinary matters, which did not oppose Thompson’s proposed sanction.

II. Background and Procedural History

A. The Two Disciplinary Proceedings

1. 24-DIS-0136: Neglect and Communication Failures in a Criminal Case

The first matter arose from Thompson’s representation of a criminal defendant in Madison Circuit Court, with trial set for April 29, 2024. The Court recites several failures:

  • He did not file proposed jury instructions despite a court order to do so.
  • He failed to respond to an email from the court’s staff.
  • He did not meet with his client between the last pretrial hearing and the trial date.
  • He could not be reached by a witness attempting to contact him before trial.
  • He did not appear on the day of trial, though this absence was later attributed to a medical condition.

The Inquiry Commission filed a six-count Charge on July 10, 2024, alleging violations of several subsections of SCR 3.130, Kentucky’s version of the Rules of Professional Conduct. Thompson made the following admissions and denials:

  • Count I – Competence (SCR 3.130(1.1)): Thompson admitted incompetence by failing to prepare adequately for trial, speak with a key witness, and meet with the client.
  • Count II – Diligence (SCR 3.130(1.3)):
    • He admitted violating this rule by not filing jury instructions as ordered.
    • He denied violating it as to failing to appear at trial, citing a medical condition that made attendance impossible.
    • OBC agreed to dismiss the portion of the count relating to his nonappearance at trial.
  • Counts III–V – Communication (SCR 3.130(1.4)(a)(2), (3), (4)):
    • He admitted failing to reasonably consult with the client about how to achieve her objectives (no meeting between last pretrial and trial).
    • He admitted failing to keep the client reasonably informed about the status of the case.
    • He admitted failing to promptly comply with reasonable requests for information (not responding to client inquiries regarding the trial).
  • Count VI – Disobeying Tribunal Rules (SCR 3.130(3.4)(c)):
    • He admitted violating this rule by failing to file court-ordered jury instructions.
    • He denied violating it as to failing to appear for trial, again citing medical incapacity.
    • OBC agreed to dismiss the portion of the count related to his nonappearance at trial.

2. 24-DIS-0140: Violation of a Domestic Violence Order (DVO)

The second matter involved Thompson’s violation of a court-issued Domestic Violence Order that prohibited contact with his wife. Despite this order, Thompson contacted her on two occasions via telephone, text, and email. This led to a criminal conviction:

  • He received a 90-day sentence, fully suspended, and two years of supervised probation.

On October 11, 2025, the Inquiry Commission filed a two-count Charge:

  • Count I – Disobeying Tribunal Orders (SCR 3.130(3.4)(c)): Thompson admitted that by contacting his wife he “knowingly disobeyed” the DVO, a court order.
  • Count II – Criminal Acts Affecting Fitness (SCR 3.130(8.4)(b)): He admitted committing a criminal act by violating the DVO and acknowledged that this called into question his fitness as a lawyer.

B. The Negotiated Sanction Under SCR 3.480(2)

Thompson sought to resolve both disciplinary cases through a negotiated sanction under SCR 3.480(2), proposing:

  • A 180-day suspension from the practice of law;
  • With the entire suspension probated for two years;
  • Subject to detailed conditions related to mental health treatment, participation in the Kentucky Lawyer’s Assistance Program (KYLAP), compliance with bar dues and continuing legal education (CLE), and avoidance of further criminal or disciplinary issues.

The Office of Bar Counsel did not object, leaving the matter to the Supreme Court’s discretion whether to accept or reject the agreement.

III. Summary of the Opinion

The Supreme Court of Kentucky:

  • Formally adjudged Thompson guilty of violating SCR 3.130(1.1), (1.3), (1.4)(a)(2)-(4), (3.4)(c), and (8.4)(b).
  • Accepted the negotiated sanction of a 180-day suspension, fully probated for two years, under SCR 3.480(2).
  • Grounded its acceptance in:
    • Comparative case law imposing similar or lesser sanctions in analogous circumstances;
    • The presence of both aggravating and mitigating factors;
    • Thompson’s mental health diagnosis and ongoing treatment.
  • Imposed extensive probationary conditions, including:
    • No new criminal convictions or disciplinary charges;
    • Completion of a KYLAP assessment and compliance with all KYLAP recommendations;
    • Execution of broad releases allowing OBC to access KYLAP and mental health records;
    • Quarterly proof of continued counseling and/or treatment;
    • Timely payment of bar dues and satisfaction of CLE requirements;
    • Quarterly KYLAP reporting to the Disciplinary Clerk and OBC regarding compliance;
    • Payment of $186.05 in costs;
    • A show-cause mechanism authorizing imposition of the 180-day suspension if probation terms or professional rules are violated during the two-year period.
  • Provided that, upon full compliance for two years, the suspension and all probationary conditions will terminate.

IV. Detailed Analysis

A. The Governing Procedural Framework: SCR 3.480(2)

SCR 3.480(2) allows the Court to consider and, at its discretion, approve “negotiated sanctions” when the respondent attorney and OBC reach an agreed outcome. The rule provides:

“The Court may consider negotiated sanctions of disciplinary investigations, complaints or charges… The Court may approve the sanction agreed to by the parties, or may remand the case for hearing or other proceedings.”

The Court cites Ousley v. Kentucky Bar Ass’n, 677 S.W.3d 380 (Ky. 2023), to reinforce that:

  • The Court is not bound by the agreement of the parties;
  • It retains ultimate discretion to accept, reject, or modify the negotiated sanction, or remand for further proceedings.

In Thompson, the Court exercises this discretion by:

  • Examining the substantive violations admitted by Thompson;
  • Comparing the proposed sanction to analogous precedents;
  • Weighing aggravating and mitigating factors;
  • Concluding the negotiated sanction is “adequate” and supported by case law.

B. Substantive Misconduct in Representation: Competence, Diligence, Communication, and Tribunal Orders

1. Competence – SCR 3.130(1.1)

SCR 3.130(1.1) requires that:

“A lawyer shall provide competent representation to a client.”

Competence typically encompasses legal knowledge, skill, thoroughness, and preparation. Thompson’s admissions show deficiencies primarily in the “thoroughness and preparation” component:

  • Failure to prepare jury instructions;
  • Failure to meet with the client before trial;
  • Failure to communicate with a witness seeking contact prior to trial.

By affirmatively conceding a violation, Thompson effectively accepts that these omissions lowered his representation below the minimum standard of competence expected in criminal defense work.

2. Diligence – SCR 3.130(1.3)

SCR 3.130(1.3) states:

“A lawyer shall act with reasonable diligence and promptness in representing a client.”

Thompson admitted one key aspect of this violation—his failure to file court-ordered jury instructions. That conduct is both:

  • A lack of diligence (failure to act as required for trial preparation); and
  • Separately, a disobedience of a tribunal order (implicating SCR 3.130(3.4)(c)).

He denied that his failure to appear for trial showed a lack of diligence, citing medical incapacity. The OBC’s agreement to dismiss that aspect indicates a recognition that where a lawyer is genuinely unable to appear due to a documented medical crisis, the element of blameworthy “lack of diligence” may be absent.

3. Communication – SCR 3.130(1.4)(a)(2)–(4)

The Court details three specific communication-related provisions:

  • (1.4)(a)(2): Reasonable consultation with the client about how to accomplish the client’s objectives.
  • (1.4)(a)(3): Keeping the client reasonably informed about the status of the matter.
  • (1.4)(a)(4): Prompt compliance with reasonable requests for information.

Thompson’s failure to meet the client, update her on the case status prior to trial, and respond to her information requests clearly violates these provisions. Importantly, the Court treats communication failures as independent misconduct, not merely as symptoms of broader neglect. This reinforces Kentucky’s consistent message that:

Failure to communicate with clients is itself serious misconduct, even when not accompanied by overt financial dishonesty or intentional prejudice.

4. Disobeying Court Orders – SCR 3.130(3.4)(c)

SCR 3.130(3.4)(c) prohibits a lawyer from:

“Knowingly disobey[ing] an obligation under the rules of a tribunal except for an open refusal based on an assertion that no valid obligation exists.”

In both disciplinary matters, this rule is central:

  • In the criminal case, Thompson failed to file ordered jury instructions.
  • In the DVO matter, he knowingly disobeyed a court’s no-contact order.

Notably, the “knowingly” element is key. The dismissal of the “failure to appear for trial” component under both SCR 3.130(1.3) and 3.4(c) (to the extent premised on nonappearance) shows that:

When a lawyer’s failure to comply with a court obligation is due to genuine incapacity (here, a medical/mental health crisis leading to a hospital visit and mental health hold), the “knowing” element may be absent, and discipline for that particular noncompliance may be inappropriate.

C. Personal Misconduct and Fitness to Practice: DVO Violation and SCR 3.130(8.4)(b)

The second disciplinary case focuses on Thompson’s violation of a Domestic Violence Order. SCR 3.130(8.4)(b) provides that it is professional misconduct to:

“Commit a criminal act that reflects adversely on the lawyer's honesty, trustworthiness or fitness as a lawyer in other respects.”

Here, the Court emphasizes that:

  • Violating a DVO is not merely a private or personal failing; it is a criminal offense that implicates a lawyer’s fitness to hold a license.
  • The violation occurred despite a clear and unambiguous court order.
  • Thompson candidly admitted that his actions “seriously” called his fitness into question.

By pairing SCR 3.4(c) (disobeying a tribunal) with SCR 8.4(b) (criminal act affecting fitness), the Court reinforces the principle that domestic violence or related protective-order violations carry professional as well as criminal consequences.

D. Precedents Cited and Their Influence on the Sanction

1. Kentucky Bar Association v. Colston, 54 S.W.3d 158 (Ky. 2001)

In Colston, an attorney violated a domestic violence order by contacting his former girlfriend. The Court:

  • Found a violation of the rule prohibiting criminal acts reflecting adversely on fitness as a lawyer (predecessor to or equivalent of SCR 3.130(8.4)(b));
  • Imposed a six-month suspension, probated for two years with conditions.

The Court in Thompson explicitly notes:

  • The factual similarity between Colston’s DVO violation and Thompson’s conduct;
  • The presence of mental health issues in both cases;
  • The similarity of the sanction framework: a six-month (180-day) suspension, probated for two years with conditions directed in part at mental health.

Influence: Colston serves as a near-direct precedent justifying the length and structure of Thompson’s probated suspension for his DVO violation, especially when considered alongside his treatment and mental health challenges.

2. Scott v. Kentucky Bar Association, 614 S.W.3d 500 (Ky. 2021)

In Scott, an attorney committed an unprovoked physical assault on another lawyer, leading to:

  • A violation of SCR 3.130(8.4)(b) (criminal act impacting fitness);
  • A sanction of a 180-day suspension, probated for two years.

The Court notes that:

  • Scott’s conduct involved physical violence, rendering it in some respects more grave than Thompson’s DVO violation and neglect.
  • However, Scott had no prior disciplinary history, making him less culpable in that dimension than Thompson.

Influence: The Court uses Scott as a calibration point:

If a first-time offender who commits an unprovoked assault receives 180 days probated for two years, then a lawyer with multiple prior disciplinary actions, but arguably slightly less immediately violent conduct, may appropriately receive an identical sanction.

3. Kentucky Bar Association v. Conley, 203 S.W.3d 142 (Ky. 2006)

In Conley, the attorney:

  • Failed to appear at multiple scheduled hearings and a trial;
  • Failed to appear for a show-cause hearing ordered by the court;
  • Was found to have violated SCR 3.130(1.3) (diligence) and SCR 3.130(3.4) (disobeying tribunal orders).

The Court imposed:

  • A 60-day suspension, wholly probated for two years with conditions.

Influence: Conley provides a lower benchmark:

  • Conley’s misconduct involved repeated nonappearances but did not involve:
    • Communication failures as extensive as Thompson’s;
    • Violation of a domestic violence order;
    • Criminal conduct directly reflecting on fitness.
  • Therefore, Thompson’s conduct is more severe and justifies a longer (180-day) suspension, even if probated, and more intrusive probationary conditions.

4. Kentucky Bar Association v. Morgan, 651 S.W.3d 779 (Ky. 2022)

Morgan is cited for the general principle that prior disciplinary offenses are a recognized aggravating factor in lawyer discipline. The Court there references, and effectively applies, the analytical framework of the ABA Standards for Imposing Lawyer Sanctions, which treat:

  • Prior disciplinary offenses;
  • Pattern of misconduct;
  • Multiple offenses;
  • Substantial experience in the practice of law

as aggravating.

Influence: In Thompson, the Court adopts this analytic lens by expressly treating Thompson’s “history of four prior disciplinary matters” as aggravating, thereby supporting a more serious sanction than might be imposed for a first offense.

E. Legal Reasoning and Balancing of Aggravating and Mitigating Factors

1. Aggravating Factors

The Court emphasizes one principal aggravating factor: Thompson’s disciplinary history over 20 years of practice, which includes:

  1. Private admonition for failing to submit to hair follicle testing or appear at a hearing in a child custody case.
  2. 61-day suspension, with 31 days probated for two years, for:
    • Failure to deposit unearned fees into a trust account;
    • Failure to withdraw from representation when unable to file an appellate brief;
    • Failure to return unearned fees;
    • Failure to represent a client.
  3. Private admonition for making an inappropriate sexual comment to a client.
  4. Private admonition for failure to promptly return an unearned fee upon termination of representation.

Collectively, these prior matters show:

  • A pattern of client-related misconduct (neglect, failure to return fees, inappropriate conduct);
  • Prior imposition of probationary conditions that apparently did not fully deter future misconduct.

2. Mitigating Factors

The Court identifies a critical mitigating factor: Thompson’s mental health condition. According to the opinion:

  • A close friend and long-time client was shot and killed, leaving Thompson “heartbroken.”
  • Following this trauma, he developed a sleep disorder and diminished cognitive abilities.
  • He subsequently went to a hospital emergency room and was placed under a mental health hold that prevented him from attending the scheduled trial.
  • Psychiatric evaluation revealed that he suffers from bipolar disorder.
  • Thompson has since consistently seen a psychiatrist and taken prescribed medication.

The Court treats this as:

A mitigating factor that partially explains, but does not excuse, his misconduct and supports a rehabilitative rather than purely punitive sanction.

3. The Sanction: Why 180 Days, Fully Probated for Two Years?

Synthesizing the aggravating and mitigating factors alongside the precedents, the Court reasons:

  • From Colston: A six-month suspended/probated sanction is appropriate for DVO-type violations with mental health concerns.
  • From Scott: 180 days probated is an appropriate benchmark where a serious criminal act (an unprovoked assault) is involved, even for a first-time offender.
  • From Conley: Lesser neglect/disobedience justifies 60 days probated; Thompson’s additional communication failures and DVO violation justify a more substantial suspension.
  • From Morgan and general disciplinary principles: Multiple prior disciplinary matters demand more serious sanctions than those imposed in first-offense cases.

At the same time, the Court recognizes:

  • Thompson’s documented bipolar disorder and current treatment;
  • The direct connection between his mental health crisis and at least some of the misconduct (e.g., failure to appear at trial);
  • The value of structured rehabilitation and monitoring (KYLAP, mental health treatment) to protect the public and the courts going forward.

Thus, the Court approves:

A 180-day “paper” suspension—meaning that if Thompson complies with conditions for two years, he will not actually be removed from practice for 180 days, but that sanction remains available if he violates probation.

F. Conditions of Probation and Their Significance

The opinion’s detailed probation conditions are more than formalities; they reflect the Court’s approach to risk management and rehabilitation:

  • No new crimes or disciplinary charges:
    Ensures immediate scrutiny and potential enforcement of the suspension if Thompson reoffends professionally or criminally.
  • KYLAP assessment and compliance:
    Integrates KYLAP—a confidential assistance program for lawyers—into the sanction to address underlying mental health and wellness issues.
  • Authorizations for OBC to access mental health and KYLAP records:
    Represents a significant intrusion into Thompson’s privacy, justified by the Court’s duty to oversee his fitness and protect the public. It ensures that:
    • Probation is not merely self-reported;
    • OBC receives independent verification of compliance and progress.
  • Quarterly proof of continued counseling/treatment:
    Establishes an ongoing, documented commitment to treatment, not a one-time evaluation.
  • KYLAP quarterly reports to the Disciplinary Clerk:
    Creates a structured feedback loop; KYLAP is required to notify OBC immediately of any violations, linking the treatment and disciplinary systems.
  • Compliance with dues and CLE:
    Signals that basic professional responsibilities must be maintained; failure to meet these simple obligations could trigger enforcement of the suspension.
  • Payment of costs:
    Reinforces that the respondent bears financial responsibility for the disciplinary process.
  • Show-cause mechanism:
    Authorizes OBC to seek imposition of the 180-day suspension if Thompson violates probation terms or incurs new charges, with the burden on Thompson to show why the suspension should not be activated.

Collectively, these conditions:

Transform the sanction from a nominally lenient “probated suspension” into a robust supervisory regime focused on both public protection and the respondent’s rehabilitation.

G. Impact on Future Cases and the Broader Area of Law

1. Domestic Violence, Criminal Conduct, and Professional Discipline

Thompson reinforces and modernizes the principle seen in Colston that:

  • Violations of domestic violence or protective orders are professionally disqualifying conduct, not purely private matters.
  • Such violations will typically trigger SCR 3.4(c) (disobeying tribunal) and SCR 8.4(b) (criminal acts reflecting on fitness).

Future respondents who violate protective orders can expect the Court to:

  • Rely on Colston and Thompson as benchmarks for sanction severity;
  • Impose at least a probated suspension, often with conditions addressing underlying personal or mental health issues.

2. Mental Health as Both Mitigating and Regulatory Focus

The opinion reflects an evolving approach to lawyer well-being in disciplinary practice:

  • Mental illness does not excuse misconduct or obviate the need for public protection.
  • However, documented, treated mental illness can:
    • Mitigate sanction severity;
    • Justify a probationary rather than an immediate active suspension;
    • Lead to mandatory treatment and monitoring conditions.

The decision thus contributes to a trend:

From purely punitive discipline toward a more hybrid model that integrates treatment, supervision, and ongoing risk management—particularly where serious mental health challenges are credibly documented and actively addressed.

3. Prior Discipline and Recidivism

Thompson also underscores that:

  • A pattern of prior disciplinary actions significantly increases sanction severity, even when the current misconduct is partially mitigated by mental health issues.
  • The Court will not treat each new matter in isolation when an attorney has a disciplinary record spanning multiple types of misconduct (neglect, trust violations, inappropriate client interactions, fee issues).

For future respondents and counsel, this implies:

  • Efforts at early rehabilitation and strict compliance after an initial disciplinary sanction are crucial.
  • Repeated issues—even if individually “minor”—can culminate in substantial sanctions when aggregated, especially if they reflect a pattern of disregard for professional norms.

4. The Role and Limits of Negotiated Sanctions

By approving the negotiated sanction, the Court confirms that:

  • SCR 3.480(2) is a viable and regularly used mechanism for global resolutions of multiple disciplinary matters;
  • The Court will accept negotiated sanctions when they:
    • Align with precedent;
    • Account adequately for aggravating and mitigating factors;
    • Include conditions sufficient to protect the public and the courts.

At the same time, the opinion’s reliance on Ousley preserves the principle that:

Parties cannot bind the Supreme Court to their agreed sanction; the Court remains the ultimate guardian of the integrity of the profession and may reject agreements it finds insufficient.

V. Simplifying Key Legal Concepts and Terms

1. Suspension “Probated” for a Period

A “probated” suspension means:

  • The suspension is imposed but not immediately enforced;
  • The lawyer is allowed to continue practicing during the probation period;
  • If the lawyer complies with all conditions and commits no further violations during the probation period, the suspension never becomes active;

2. Domestic Violence Order (DVO)

A DVO is a protective order issued by a court, typically in domestic or family violence contexts. It often:

  • Prohibits contact with a protected person (in this case, Thompson’s wife);
  • Has the force of law—violating it is a criminal offense;
  • Counts as “disobeying a tribunal” when violated by a lawyer.

3. SCR 3.130 – Rules of Professional Conduct

Key subsections involved in Thompson:

  • 1.1 – Competence: The duty to be prepared and capable.
  • 1.3 – Diligence: The duty to handle a case promptly and actively.
  • 1.4 – Communication: The duty to consult, inform, and respond to clients.
  • 3.4(c) – Obedience to Tribunal Orders: The duty not to knowingly disobey court orders.
  • 8.4(b) – Criminal Acts Affecting Fitness: The prohibition on criminal conduct that suggests a lawyer may be unfit.

4. Inquiry Commission

The Inquiry Commission is:

  • The body authorized to investigate and initiate charges of attorney misconduct in Kentucky;
  • Responsible for filing formal Charges (like 24-DIS-0136 and 24-DIS-0140) based on its investigations.

5. Kentucky Lawyer’s Assistance Program (KYLAP)

KYLAP is a confidential program designed to help lawyers with:

  • Mental health challenges (e.g., depression, bipolar disorder);
  • Substance use disorders;
  • Other issues affecting professional functioning.

In disciplinary cases, KYLAP can:

  • Provide evaluations and treatment recommendations;
  • Monitor compliance with recovery or treatment plans;
  • Report compliance or noncompliance to the Court or OBC when conditions require it.

6. Show Cause Order

A “show cause order” is a directive from the Court requiring a lawyer to appear and explain why a particular sanction (here, the 180-day suspension) should not be imposed. If the lawyer cannot provide an adequate explanation or defense, the Court may:

  • Activate the previously probated suspension;
  • Impose additional sanctions, if warranted.

VI. Conclusion: Key Takeaways and Significance

In re: Daniel Louis Thompson reinforces several important principles in Kentucky’s attorney discipline jurisprudence:

  • Negotiated sanctions are subject to careful judicial scrutiny. Under SCR 3.480(2), the Court will compare proposed sanctions to precedent, evaluate aggravating and mitigating factors, and adopt only those sanctions that protect the public and the integrity of the profession.
  • DVO violations and related criminal acts are professional, not merely private, misconduct. They trigger SCR 3.4(c) and 8.4(b), and can justify substantial sanctions, including probated suspensions.
  • Mental health conditions can mitigate but not erase misconduct. Documented serious mental illness, particularly when tied to the timing and nature of the misconduct and followed by consistent treatment, may support a rehabilitative, treatment-focused sanction rather than an immediate active suspension.
  • Prior disciplinary history carries significant weight. Thompson’s four prior matters and one prior suspension served as a major aggravator, distinguishing his case from first-time offenders and justifying the length and intrusiveness of his probation.
  • Probated suspensions can function as stringent supervisory regimes. Conditions involving KYLAP, mental health treatment, quarterly reporting, and broad releases of records turn a nominally lenient “probated” sanction into a robust system of oversight and accountability.

In sum, the decision does not radically alter Kentucky disciplinary law but meaningfully develops it by:

  • Clarifying how domestic-violence-related misconduct interacts with professional rules;
  • Demonstrating a modern, integrated approach to mental health mitigation and regulation;
  • Providing a detailed template for negotiated sanctions in complex, multi-matter disciplinary cases involving both professional and personal misconduct.

For practitioners, Thompson serves as a cautionary example of how personal crises and untreated mental illness can lead to significant professional consequences, but also as an indication that the Court is willing to structure sanctions in ways that prioritize both public protection and the possibility of rehabilitation, provided there is candor, acceptance of responsibility, and genuine engagement with treatment.

Case Details

Year: 2025
Court: Supreme Court of Kentucky

Judge(s)

Comments