Kentucky Supreme Court

City of Paintsville v. Paula M. Haney, as Personal Representative of Estate of Donald Prater, Jr.

August 14, 2025

Summary

The Kentucky Supreme Court held that the first responders were entitled to qualified official immunity because their arrest-related conduct was discretionary, within their authority, performed in good faith, and involved reasonable force against an actively resisting suspect. The court also held that the governmental entities could not be liable for vicarious liability or negligent hiring, training, retention, or supervision without an underlying tort by an employee, and that any special relationship arising from custody did not defeat immunity. The court affirmed the dismissals that were upheld below, reversed the Court of Appeals’ reinstatement of claims, and remanded for any remaining proceedings.