negligence per se claim (Kentucky) · Go Syfert
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negligence per se claim in Kentucky

17 Kentucky opinions name it 2 courts 1953–2026 7 in the last five years

The cases below were cited by Kentucky courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (15)

CaseFollowedCited
Young v. Carrangreen
kyctapp · 2008 · cited in 2 Kentucky opinions naming this issue, 2019–2025
2 sentences

2025We begin the discussion with the statutory or negligence per se claims, which are premised upon Kentucky Revised Statutes (“KRS”) 177.106 and 179.240. a) Negligence Per Se A negligence per se claim “is merely a negligence claim with a statutory standard of care substituted for the common law standard of care.” Lewis v. B&R Corp., 56 S.W.3d 432, 438 (Ky. App. 2001) (citation omitted); see also Young v. Carran, 289 S.W.3d 586, 588-89 (Ky. App. 2008) (citation omitted).

2019As noted above, that statute provides, “A person injured by the violation of any statute may recover from the offender such damages as he sustained by reason of the violation, although a penalty or forfeiture is imposed for such violation.” KRS 446.070 codifies the doctrine of negligence per se and allows an injured party to recover “for a violation of a statutory standard of care if the statute in question provides no inclusive civil remedy and if the party is within the class of persons the statute is intended to protect.” Young v. Carran, 289 S.W.3d 586, 589 (Ky. App. 2008).

22
Lewis v. B & R CORPORATIONgreen
kyctapp · 2001 · cited in 2 Kentucky opinions naming this issue, 2021–2025
2 sentences

2025We begin the discussion with the statutory or negligence per se claims, which are premised upon Kentucky Revised Statutes (“KRS”) 177.106 and 179.240. a) Negligence Per Se A negligence per se claim “is merely a negligence claim with a statutory standard of care substituted for the common law standard of care.” Lewis v. B&R Corp., 56 S.W.3d 432, 438 (Ky. App. 2001) (citation omitted); see also Young v. Carran, 289 S.W.3d 586, 588-89 (Ky. App. 2008) (citation omitted).

2021A negligence per se claim is merely a negligence claim with a statutory standard of care substituted for the common law standard of care.” Lewis v. B & R Corp., 56 S.W.3d 432, 438 (Ky. App. 2001) (internal quotation marks and footnotes omitted).

22
Hargis v. Baizegreen
ky · 2005 · cited in 2 Kentucky opinions naming this issue, 2021–2024
2 sentences

2024Hargis v. Baize, 168 S.W.3d 36, 40 (Ky. 2005). -19- The negligence per se claim fails as a matter of law as Xhale’s failure to ensure Sims’ licensure would not have prevented an unwanted touching.

2021And, to prevail upon a negligence per se claim, a “violation [of the statute] must have been a substantial factor in causing the result.” McCarty v. Covol Fuels No. 2, LLC, 476 S.W.3d 224, 228 (Ky. 2015) (quoting Hargis v. Baize, 168 S.W.3d 36, 46 (Ky. 2005)).

22
Howard v. Prudential Insurance Co. of Americagreen
kywd · 2017 · cited in 1 Kentucky opinions naming this issue, 2026–2026
1 sentence

2026Howard v. Prudential Insurance Company of America, 248 F.Supp. 3d 862, 867 (W.D.

11
St. Luke Hospital, Inc. v. Straubgreen
ky · 2011 · cited in 1 Kentucky opinions naming this issue, 2025–2025
2 sentences

2025Straub, 354 S.W.3d at 534 (Negligence per se is a legal doctrine whereby a statutory standard of care is substituted for the common law standard of care.).

2025Id.

11
Wright v. House of Imports, Inc.green
ky · 2012 · cited in 1 Kentucky opinions naming this issue, 2025–2025
1 sentence

2025Setting aside the issue of whether the tenants’ expenditures qualify as repair costs, the court correctly determined that their negligence per se claim failed as a matter of law. -9- The statutory authority for a negligence per se action arises under KRS 446.070, which states that “[a] person injured by the violation of any statute may recover from the offender such damages as he sustained by reason of the violation, although a penalty or forfeiture is imposed for such violation.” The effect of a negligence per se claim is to replace the common law standard of care with a statutory standard, W

11
Grzyb v. Evansgreen
ky · 1985 · cited in 1 Kentucky opinions naming this issue, 2025–2025
1 sentence

2025However, “[w]here the statute both declares the unlawful act and specifies the civil remedy available to the aggrieved party, the aggrieved party is limited to the remedy provided by the statute.” Waugh, 584 S.W.3d at 753 (quoting Grzyb v. Evans, 700 S.W.2d 399, 401 (Ky. 1985)).

11
Nancy J. McCarty v. Covol Fuels No. 2, LLC a Utah Corporationgreen
ky · 2015 · cited in 1 Kentucky opinions naming this issue, 2021–2021
1 sentence

2021And, to prevail upon a negligence per se claim, a “violation [of the statute] must have been a substantial factor in causing the result.” McCarty v. Covol Fuels No. 2, LLC, 476 S.W.3d 224, 228 (Ky. 2015) (quoting Hargis v. Baize, 168 S.W.3d 36, 46 (Ky. 2005)).

11
Eades v. Stephensgreen
kyctapp · 1957 · cited in 1 Kentucky opinions naming this issue, 2018–2018
1 sentence

2018It, too, was purely 5 302 S.W.2d 117, 120 (Ky. 1957). 6 399 S.W.2d 491, 493 (Ky. 1966). based upon an argument of law pertaining to the applicability of KOSHA regulations with which the LLC admittedly did not comply.

11
Flynn v. Songergreen
kyctapphigh · 1966 · cited in 1 Kentucky opinions naming this issue, 2018–2018
1 sentence

2018It, too, was purely 5 302 S.W.2d 117, 120 (Ky. 1957). 6 399 S.W.2d 491, 493 (Ky. 1966). based upon an argument of law pertaining to the applicability of KOSHA regulations with which the LLC admittedly did not comply.

11
Goodyear Tire and Rubber Co. v. Thompsongreen
ky · 2000 · cited in 1 Kentucky opinions naming this issue, 2012–2012
2 sentences

2012See Goodyear Tire & Rubber Co. v. Thompson, 11 S.W.3d 575, 578 (Ky.2000) (describing the relevancy of expert testimony to a particular fact in issue as one of “fit”).

2012See Goodyear Tire & Rubber Co. v. Thompson, 11 S.W.3d 575, 578 (Ky.2000) (describing the relevancy of expert testimony to a particular fact in issue as one of “fit”).

11
Chalothorn v. Meadegreen
kyctapp · 1999 · cited in 1 Kentucky opinions naming this issue, 2009–2009
2 sentences

2009See 15 S.W.3d at 393 .

2009See 15 S.W.3d at 393 .

11
Hilen v. Haysgreen
ky · 1984 · cited in 1 Kentucky opinions naming this issue, 2009–2009
2 sentences

2009See 673 S.W.2d 713, 720 (Ky.1984).

2009See 673 S.W.2d 713, 720 (Ky.1984).

11
Britton v. Wootengreen
ky · 1991 · cited in 1 Kentucky opinions naming this issue, 2001–2001
1 sentence

2001Under common law premises liability, the owner of a premises to which the public is invited has a general duty to exercise ordinary care to keep the premises in a reasonably safe condition and warn invitees of dangers that are latent, unknown or not obvious. 15 Similarly, statutes, ordinances, regulations and building codes may create a duty subject to liability as negligence per se. 16 A negligence per se claim “is merely a negligence claim with a statutory standard of care substituted for the common law standard of care.” 17 While it is unquestioned that violations of statutes constitute neg

11
ATHERTON CONDO APARTMENT-OWNERS ASS'N BD OF DIRECTORS v. Blume Dev. Co.green
wash · 1990 · cited in 1 Kentucky opinions naming this issue, 1994–1994
2 sentences

1994See Atherton Condominium, Apartment-Owners Association Board of Directors v. Blume Development Company, 115 Wash.2d 506 , 799 P.2d 250 (1990).” KRS 446.070 elevates proof of violation of statutory standards to the status of negligence per se, by stating: “A person injured by the violation of any statute may recover from the offender such damages as he sustained by reason of the violation, although a penalty or forfeiture is imposed for such violation.” The interrelationship between the statutory standard and KRS 446.070 is illustrated by Grayson Fraternal Order of Eagles v. Claywell, Ky., 736

1994See Atherton Condominium, Apartment-Owners Association Board of Directors v. Blume Development Company, 115 Wash.2d 506 , 799 P.2d 250 (1990).” KRS 446.070 elevates proof of violation of statutory standards to the status of negligence per se, by stating: “A person injured by the violation of any statute may recover from the offender such damages as he sustained by reason of the violation, although a penalty or forfeiture is imposed for such violation.” The interrelationship between the statutory standard and KRS 446.070 is illustrated by Grayson Fraternal Order of Eagles v. Claywell, Ky., 736

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Kentucky. Read the followed side critically anyway.

Also cited on this issue (7)

CaseCitedYears
Laws v. Harter red
kyctapp · 1976
2 sentences

2009VENTERS, Justice, concurring in part and dissenting in part: I concur with the sound reasoning and scholarly analysis expressed by Special Justice Mando in our rejection of the negligence per se rule of Laws v. Harter, 534 S.W.2d 449 (Ky.1975), and adoption of the res ipsa loquitor approach to medical negligence issues arising from surgical objects left in a patient.

2009VENTERS, JUSTICE, CONCURRING IN PART AND DISSENTING IN PART: I concur with the sound reasoning and scholarly analysis expressed by Special Justice Mando in our rejection of the negligence per se rule of Laws v. Harter, 534 S.W.2d 449 (Ky. 1975), and adoption of the res ipso loquitor approach to medical negligence issues arising from surgical objects left in a patient.

22009–2009
Peak v. Barlow Homes, Inc. green
kyctapp · 1988
1 sentence

2025In Peak v. Barlow Homes, Inc., a passenger in one vehicle was killed when it collided with another vehicle turning left into a service entrance created by an adjoining landowner. 765 S.W.2d at 578 .

12025–2025
Hughes v. Boston Scientific Corp. green
ca5 · 2011
1 sentence

2020Further, Hughes “conclude[d] that invoking the negligence per se doctrine to support a negligence claim that is otherwise parallel to federal requirements is not expressly preempted.” Id. at 772 .

12020–2020
Real Estate Marketing, Inc. v. Franz green
ky · 1994
1 sentence

2011Having concluded that a warranty claim was not viable without privity of contract, the Court turned to the negligence per se claim and found that in Kentucky “tort recovery is contingent upon damage from a destructive occurrence as contrasted with economic loss related solely to the diminution in value ...” Id. at 926 (citing Dealers Transport Co., Inc. v. Battery Distributing Co., 402 S.W.2d 441 (Ky.1966), which had adopted Section 402A of the Restatement (Second) of Torts).

12011–2011
Dealers Transport Co. v. Battery Distributing Co. green
kyctapphigh · 1966
1 sentence

2011Having concluded that a warranty claim was not viable without privity of contract, the Court turned to the negligence per se claim and found that in Kentucky “tort recovery is contingent upon damage from a destructive occurrence as contrasted with economic loss related solely to the diminution in value ...” Id. at 926 (citing Dealers Transport Co., Inc. v. Battery Distributing Co., 402 S.W.2d 441 (Ky.1966), which had adopted Section 402A of the Restatement (Second) of Torts).

12011–2011
Grayson Fraternal Order of Eagles, Aerie No. 3738, Inc. v. Claywell red
ky · 1987
1 sentence

1994See Atherton Condominium, Apartment-Owners Association Board of Directors v. Blume Development Company, 115 Wash.2d 506 , 799 P.2d 250 (1990).” KRS 446.070 elevates proof of violation of statutory standards to the status of negligence per se, by stating: “A person injured by the violation of any statute may recover from the offender such damages as he sustained by reason of the violation, although a penalty or forfeiture is imposed for such violation.” The interrelationship between the statutory standard and KRS 446.070 is illustrated by Grayson Fraternal Order of Eagles v. Claywell, Ky., 736

11994–1994
Pryor's Administrator v. Otter green
kyctapphigh · 1937
1 sentence

1953Pryor’s Adm’r v. Otter, 268 Ky, 602, 105 S.W.2d 564 . ’ There are certain exceptions to the rule .which are not involved in this case.- The problem here is; whether- the violation of an ordinance may ever be explained or, excused to such an extent as to avoid the application of the negligence per se rule.

11953–1953

Statutes the citing opinions construe

KY § Ky. Rev. Stat. § 446.070 (5)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 117 (1934–2026) TX 68 (1959–2025) CO 35 (1988–2026) OR 33 (1970–2026) MS 32 (1994–2025) OH 27 (1936–2025) GA 21 (1921–2025) AK 21 (1975–2019) CT 21 (1981–2016) WA 20 (1942–2014) PA 18 (1996–2021) TN 18 (2000–2024) MO 17 (1979–2025) KY 17 (1953–2026) NY 16 (1983–2026) NM 16 (1963–2025) ID 12 (1986–2016) AZ 12 (1962–2024) MN 11 (1987–2026) IN 10 (1943–2018) NC 10 (1975–2026) VA 9 (2000–2024) IA 9 (1992–2024) NV 8 (1983–2021) OK 8 (1994–2022) AL 8 (1923–2024) WI 8 (1976–2025) DC 8 (1978–2014) LA 7 (1992–2023) DE 7 (1962–2021) MI 6 (1974–2022) MT 6 (1999–2026) WY 5 (1965–2017) NH 5 (1995–2015) KS 5 (1994–2019) FL 5 (1979–2001) IL 4 (1997–2006) ME 3 (1996–2004) SC 3 (1997–2023) VT 2 (1999–2018) SD 2 (1988–2026) UT 2 (2000–2018)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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