Jay Picard v. Katherine Knight

Summary

The Kentucky Supreme Court held that CR 68 does not apply to family-law proceedings because it is inconsistent with KRS Chapter 403 and specifically with KRS 403.220. Attorney fees and costs in those proceedings must instead be addressed under the discretionary statutory framework, so Picard could not obtain CR 68 fees and costs in the child-support modification matter. The Court affirmed the lower courts' denial of his motion.