Kentucky Revised Statutes
Ky. Rev. Stat. § 454.165 (2026)
Personal judgment against defendant constructively summoned forbidden
✓ current as of May 2026
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No personal judgment shall be rendered against a defendant constructively summoned, and who has not appeared in the action, except as provided in KRS 454.210. History: Amended 1968 Ky. Acts ch. 46, sec. 6. -- Transferred 1952 Ky. Acts ch. 84, secs. 1 and 17, effective July 1, 1953, from C.C. sec. 419.
Notes of Decisions
Cited in 12
cases (3 in the last 5 years), 1970–2024 · leading case: Kentucky Farm Bureau Mut. Ins. Co. v. Ryan, 177 S.W.3d 797 (Ky. 2005).
Kentucky Farm Bureau Mut. Ins. Co. v. Ryan, 177 S.W.3d 797 (Ky. 2005). “05 should be read in conjunction with KRS 454.165, which provides that a court cannot achieve in personam jurisdiction over persons who are the subject of constructive service of process.”
Soileau v. Bowman, 382 S.W.3d 888 (Ky. Ct. App. 2012). “1986) (citing KRS 454.165). In Smith v. Gadd, 280 S.W.2d 495, 497 (Ky.”
Miller v. McGinity, 234 S.W.3d 371 (Ky. Ct. App. 2007). “Therefore, the family court had no personal jurisdiction over him and, pursuant to KRS 454.165, the personal judgment that the court initially entered against Darren was improper.”
First Nat'l Bank of Cincinnati v. Hartmann, 747 S.W.2d 614 (Ky. Ct. App. 1988). “KRS 454.165 prohibits our courts from rendering personal judgments against constructively summoned defendants unless they have appeared in the action.”
Dalton v. First Nat'l Bank of Grayson, 712 S.W.2d 954 (Ky. Ct. App. 1986). “KRS 454.165. Constructive service is sufficient merely to confer jurisdiction quasi in rem.”
Cann v. Howard, 850 S.W.2d 57 (Ky. Ct. App. 1993). “KRS 454.165 prohibits our courts from rendering personal judgments against constructively summoned defendants unless they have appeared in the action.”
Richmond v. Louisville & Jefferson Cnty. Metro. Sewer Dist., 572 S.W.2d 601 (Ky. Ct. App. 1977). “However, KRS 454.165 provides that the court can not achieve in personam jurisdiction over persons who are the subject of constructive service of process.”
Joe Hand Promotions, Inc. v. Coakley (W.D. Ky. 2020). “§ 454.165, “[n]o personal judgment shall be rendered against a defendant constructively summoned, and who has not appeared in the action, except as provided in [Kentucky’s Long-Arm Statute].”
Robert G. Hicks v. City of Hopkinsville, Sewerage & Water Works Comm'n, D/B/A Hopkinsville Water Env't Auth. (Ky. Ct. App. 2022). “]” KRS 454.165. “Absent an appearance by the party, constructive service alone is not sufficient to subject nonresidents to a personal judgment[.”
Justin Aldava v. Alyssa Baum (Ky. Ct. App. 2024). “” KRS 454.165. Of course, KRS 454.210 is generally referred to as our “long-arm statute.”
Robert G. Hicks, as Tr. of the Roberta Cherry Hicks Testamentary Trust v. City of Hopkinsville, Sewerage & Water Works Comm'n, D/B/A Hopkinsville Water Env't Auth. (Ky. Ct. App. 2024). “]” KRS 454.165. “Absent an appearance by the party, constructive service alone is not sufficient to subject nonresidents to a personal judgment[.”
Murphy v. Murphy, 464 S.W.2d 231 (Ky. Ct. App. 1970). “However, in view of KRS 454.165, which precludes a personal judgment against a defendant who has been constructively served with process and who does not appear in the action, it would appear that the appellant herein is not barred from maintaining an action for the recovery of…”
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