Ky. Rev. Stat. » Chapter 65
Kentucky Revised Statutes

Ky. Rev. Stat. § 65.2001 (2026)

Application and construction of KRS 65.2002 to 65.2006

✓ current as of May 2026
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(1) Every action in tort against any local government in this Commonwealth for death, personal injury or property damages proximately caused by:

(a) Any defect or hazardous condition in public lands, buildings or other public property, including personalty;

(b) Any act or omission of any employee, while acting within the scope of his employment or duties; or

(c) Any act or omission of a person other than an employee for which the local government is or may be liable shall be subject to the provisions of KRS 65.2002 to 65.2006.

(2) Except as otherwise specifically provided in KRS 65.2002 to 65.2006, all enacted and case-made law, substantive or procedural, concerning actions in tort against local governments shall continue in force. No provision of KRS 65.2002 to 65.2006 shall in any way be construed to expand the existing common law concerning municipal tort liability as of July 15, 1988, nor eliminate or abrogate the defense of governmental immunity for county governments. Effective: July 15, 1988 History: Created 1988 Ky. Acts ch. 224, sec. 16, effective July 15, 1988.

Notes of Decisions
Cited in 28 cases (17 in the last 5 years), 1991–2026 · leading case: Schwindel v. Meade Cnty., 113 S.W.3d 159 (Ky. 2003).
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Schwindel v. Meade Cnty., 113 S.W.3d 159 (Ky. 2003). · cites it 6× “KRS 65.2001 is titled “Application and construction of KRS 65.”
Phelps v. Louisville Water Co., 103 S.W.3d 46 (Ky. 2003). · cites it 2× “I agree with the majority opinion's conclusion that the Louisville Water Company is not an agency of the City of Louisville, thus leaving for another day the issue of the constitutionality of KRS 65.”
Jones v. Cross, 260 S.W.3d 343 (Ky. 2008). · cites it 2× “And as in Casey , this statute allows a reading that would preserve immunity: the clause providing that the sheriff's office shall be liable for deputy torts could be construed by analogy with Casey and the Claims Against Local Governments Act, KRS 65.2001 to 65.2006, as not…”
Ashby v. City of Louisville, 841 S.W.2d 184 (Ky. Ct. App. 1992). · cites it 2× “This statute, enacted in 1988, states in pertinent part as follows: Notwithstanding KRS 65.2001, a local government shall not be liable for injuries or losses resulting from: [[Image here]] (3) Any claim arising from the exercise of judicial, quasi-judicial, legislative or…”
City of Frankfort v. Byrns, 817 S.W.2d 462 (Ky. Ct. App. 1991). · cites it 4× “2d 144 (1985), a decision significantly restricting the doctrine of immunity for municipalities, the legislature enacted KRS 65.2001 through KRS 65.2006. KRS 65.2001(3) affirms the validity of all existing statutory and case law involving actions in tort against local…”
Richardson v. Louisville/Jefferson Cnty. Metro Gov't, 260 S.W.3d 777 (Ky. 2008). “KRS 65.2001(1). The key to this case is the timing of the acts or omissions which form the basis for the civil claims, not the filing dates of the lawsuits.”
Louisville/Jefferson Cnty. Metro Gov't v. Braden, 519 S.W.3d 386 (Ky. Ct. App. 2017). · cites it 2× “CALGA In 1988, the General Assembly passed CALGA, which sought to protect current and former civil servants from the financial burden of litigation arising from their work for local governments.”
Jennifer Albright, Individually & as Adm'x of the Est. of David K. Albright v. Louisville & Jefferson Cnty. Metro. Sewer Dist. (Ky. Ct. App. 2023). · cites it 5× “CALGA was passed by the General Assembly in 1988, and the disposition of this issue centers upon two provisions of CALGA – KRS 65.2001 and KRS 65.2003. KRS 65.2001 reads: (1) Every action in tort against any local government in this Commonwealth for death, personal injury or…”
Franklin Cnty., Ky. v. Malone, 957 S.W.2d 195 (Ky. 1997). · cites it 2× “The specific language of KRS 65.2001(2) provides "[n]o provision of KRS 65.”
Louisville & Jefferson Cnty. Metro. Sewer Dist. v. Jennifer Albright, Individually & as Adm'x of the Est. of David K. Albright (Ky. 2025). · cites it 3× “Ostensibly based on its desire to codify the common law rather than modify it, CALGA goes on to provide, pertinent to this case, that Notwithstanding KRS 65.2001, a local government shall not be liable for injuries or losses resulting from: .”
Thurman v. City of Frankfort (E.D. Ky. 2022). · cites it 2× “nal injury or property damages proximately caused by: (a) Any defect or hazardous condition in public lands, buildings or other public property, including personalty; (b) Any act or omission of any employee, while acting within the scope of his employment or duties; or (c) Any…”
Smith v. Stanton, KY (E.D. Ky. 2022). · cites it 2× “KRS § 65.2001. CALGA defines “action in tort” as “any claim for money damages based upon negligence, medical malpractice, intentional tort, nuisance, products liability and strict liability, and also includes any wrongful death or survival-type action.”
Show all 28 citing cases →
— Ky. Rev. Stat. § 65.2001(1) — 4 cases
Richardson v. Louisville/Jefferson Cnty. Metro Gov't, 260 S.W.3d 777 (Ky. 2008). “KRS 65.2001(1). The key to this case is the timing of the acts or omissions which form the basis for the civil claims, not the filing dates of the lawsuits.”
Jennifer Albright, Individually & as Adm'x of the Est. of David K. Albright v. Louisville & Jefferson Cnty. Metro. Sewer Dist. (Ky. Ct. App. 2023). “CALGA was passed by the General Assembly in 1988, and the disposition of this issue centers upon two provisions of CALGA – KRS 65.2001 and KRS 65.2003. KRS 65.2001 reads: (1) Every action in tort against any local government in this Commonwealth for death, personal injury or…”
The Est. of Jeremy Marr v. City of Glasgow (W.D. Ky. 2022).
Suzette Sewell-Scheuermann v. Michael Scalise (Ky. Ct. App. 2026).
— Ky. Rev. Stat. § 65.2001(1)(a) — 2 cases
Louisville & Jefferson Cnty. Metro. Sewer Dist. v. Jennifer Albright, Individually & as Adm'x of the Est. of David K. Albright (Ky. 2025). “Ostensibly based on its desire to codify the common law rather than modify it, CALGA goes on to provide, pertinent to this case, that Notwithstanding KRS 65.2001, a local government shall not be liable for injuries or losses resulting from: .”
Little Bent Farm, LLC v. W. Kentucky Univ. (Ky. Ct. App. 2025).
— Ky. Rev. Stat. § 65.2001(1)(b) — 3 cases
New Albany Main Street Props. v. Watco Companies, LLC (W.D. Ky. 2022).
Michael Schell v. Troy L. Young (Ky. Ct. App. 2021).
Hollon v. HCA Healthcare, Inc. (E.D. Ky. 2024).
— Ky. Rev. Stat. § 65.2001(2) — 9 cases
Schwindel v. Meade Cnty., 113 S.W.3d 159 (Ky. 2003). “KRS 65.2001 is titled “Application and construction of KRS 65.”
Louisville/Jefferson Cnty. Metro Gov't v. Braden, 519 S.W.3d 386 (Ky. Ct. App. 2017). “CALGA In 1988, the General Assembly passed CALGA, which sought to protect current and former civil servants from the financial burden of litigation arising from their work for local governments.”
City of Frankfort v. Byrns, 817 S.W.2d 462 (Ky. Ct. App. 1991). “2d 144 (1985), a decision significantly restricting the doctrine of immunity for municipalities, the legislature enacted KRS 65.2001 through KRS 65.2006. KRS 65.2001(3) affirms the validity of all existing statutory and case law involving actions in tort against local…”
Franklin Cnty., Ky. v. Malone, 957 S.W.2d 195 (Ky. 1997). “The specific language of KRS 65.2001(2) provides "[n]o provision of KRS 65.”
Jennifer Albright, Individually & as Adm'x of the Est. of David K. Albright v. Louisville & Jefferson Cnty. Metro. Sewer Dist. (Ky. Ct. App. 2023). “CALGA was passed by the General Assembly in 1988, and the disposition of this issue centers upon two provisions of CALGA – KRS 65.2001 and KRS 65.2003. KRS 65.2001 reads: (1) Every action in tort against any local government in this Commonwealth for death, personal injury or…”
— Ky. Rev. Stat. § 65.2001(3) — 1 case
City of Frankfort v. Byrns, 817 S.W.2d 462 (Ky. Ct. App. 1991). “2d 144 (1985), a decision significantly restricting the doctrine of immunity for municipalities, the legislature enacted KRS 65.2001 through KRS 65.2006. KRS 65.2001(3) affirms the validity of all existing statutory and case law involving actions in tort against local…”
— Ky. Rev. Stat. § 65.2001(l)(b) — 1 case
Louisville/Jefferson Cnty. Metro Gov't v. Braden, 519 S.W.3d 386 (Ky. Ct. App. 2017). “CALGA In 1988, the General Assembly passed CALGA, which sought to protect current and former civil servants from the financial burden of litigation arising from their work for local governments.”
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