Edna Bratton v. Citifinancial, Inc.

Summary

The Kentucky Supreme Court affirmed the Court of Appeals’ reversal of the trial court’s summary judgment, holding that KRS 382.365 applies only to liens that have been satisfied and that the Brattons failed to meet the statutory burden of proving satisfaction. The Court also noted that the notice‑by‑certified‑mail requirement remains mandatory, but that issue was not essential to its decision. The decision rests on a plain‑meaning construction of the statute and the legislature’s expressed intent.