Louisville & Jefferson County Metropolitan Sewer District v. Jennifer Albright, Individually and as Administratrix of the Estate of David K. Albright

CourtKentucky Supreme Court
DecidedMarch 20, 2025
Docket2023-SC-0079
StatusPublished

This text of Louisville & Jefferson County Metropolitan Sewer District v. Jennifer Albright, Individually and as Administratrix of the Estate of David K. Albright (Louisville & Jefferson County Metropolitan Sewer District v. Jennifer Albright, Individually and as Administratrix of the Estate of David K. Albright) is published on Counsel Stack Legal Research, covering Kentucky Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Louisville & Jefferson County Metropolitan Sewer District v. Jennifer Albright, Individually and as Administratrix of the Estate of David K. Albright, (Ky. 2025).

Opinion

RENDERED: MARCH 20, 2025 TO BE PUBLISHED

Supreme Court of Kentucky 2023-SC-0079-DG

LOUISVILLE & JEFFERSON COUNTY APPELLANT METROPOLITAN SEWER DISTRICT

ON REVIEW FROM COURT OF APPEALS V. NO. 2021-CA-0181 JEFFERSON CIRCUIT COURT NO. 18-CI-07082

JENNIFER ALBRIGHT, INDIVIDUALLY, APPELLEE AND AS ADMINISTRATRIX OF THE ESTATE OF DAVID K. ALBRIGHT

OPINION OF THE COURT BY CHIEF JUSTICE LAMBERT

AFFIRMING

In this appeal, we address whether the Louisville and Jefferson County

Metropolitan Sewer District (MSD) is entitled to municipal immunity under the

Claims Against Local Governments Act (CALGA) 1 against Jennifer Albright’s

(Albright) claims against it in relation to the death of her minor child. The

circuit court granted summary judgment in favor of MSD after finding that it

qualified for immunity under CALGA, and the Court of Appeals reversed. After

thorough review we hold that MSD, though subject to CALGA, is not entitled to

immunity under the facts of this case. We accordingly affirm the Court of

1 Kentucky Revised Statues (KRS) 65.200-65.2006. Appeals, vacate the circuit court’s summary judgment opinion and order, and

remand this case to the circuit court for further proceedings.

I. FACTS AND PROCEDURAL BACKGROUND

As this is an appeal from an entry of summary judgment, this Court’s

review provides no deference to the circuit court’s assessment of the record or

its legal conclusions. See Hammons v. Hammons, 327 S.W.3d 444, 448 (Ky.

2010) (citing Malone v. Kentucky Farm Bureau Mut. Ins. Co., 287 S.W.3d 656,

658 (Ky. 2009)). Accordingly, in this section we provide only the facts that are

necessary for context and provide a more thorough discussion of the record in

Section II(C) of this Opinion.

At the time of the events at issue in this case Albright had been living in

a residential subdivision known as Old Dorsey Place 2 in Louisville, Kentucky

with her fifteen-year-old son David Albright (David) and her twelve-year-old son

Maxwell Albright (Max) for six years. David attended Trinity High School and

was an A and B average student who participated in the school’s chorus and

drumline. He also had an afterschool job at a bakery and was involved in the

Boy Scouts.

Sometime around 6:30 p.m. on August 31, 2018, Albright and her

children came home and noticed that the grass covered drainage swale in their

backyard had filled with rain water to approximately ankle-deep. The swale

carried water from right to left across Albright’s backyard at 9805 Melissa Drive

2 Also referred to as Foxboro Estates.

2 and continued across the yard of Albright’s neighbor to the left at 9803 Melissa

Drive. The swale then ended at the property line between 9803 and 9801

Melissa Drive where it emptied into a drainage pipe that was either eighteen

inches or twenty-one inches in diameter, housed within a concrete headwall.

The backyards of the properties on Melissa Drive abutted the backyards of the

homes on Foxfire Drive. Accordingly, the swale simultaneously ran through

the backyards of the homes located at 805, 803, and 801 Foxfire Drive, and the

headwall was also in the backyard of the property at 801 Foxfire Drive. A

concrete pad was in front of the headwall below the pipe entrance. It is

undisputed that the swale and drainage pipe were part of a drainage easement

owned by MSD.

Albright and her children decided they would play in the swale together

for a little while before dinner. At first, Albright did not accompany the boys

outside and instead filmed a video of them playing on her cellphone from inside

her home. A few moments later Albright joined them outside. After a few

minutes of splashing and running around in the swale, the trio moved down to

the headwall. Albright stood on top of the headwall while David and Max

played in the approximately 16-inch-deep water that had pooled at the pipe’s

opening. David, who was barefoot and standing upright, suddenly lost his

footing and was swept feet-first towards the drainage pipe. Albright grabbed

his hands and tried to prevent him from going into the pipe but was unable to

maintain her grasp. David—who was five foot nine and weighed 162 pounds—

was “sucked into” the drainage pipe. That pipe ran for four hundred and thirty

3 feet entirely underground, including two ninety degree turns, and contained no

means for someone to extricate themselves if they became trapped inside.

There were no warning signs in the vicinity of the pipe’s opening, nor were

there any safety measurements in place, such as a trash rack or safety grate

that would have prevented someone from being swept into the pipe during a

rain event. The pipe emptied into a detention pond that was also owned by

MSD. David was located by first responders in that detention pond and was

transported to a hospital where he died from his injuries on September 7,

2018.

In December 2018, Albright filed suit against MSD in both her individual

capacity and as the administratrix of David’s estate alleging negligence,

negligence/failure to warn, negligence per se, attractive nuisance, negligent

infliction of emotional distress, and loss of consortium. Of particular import,

Albright’s negligence claim asserted that MSD negligently maintained the

drainage system and that it knew or should have known of the unsafe,

defective, or dangerous condition created by it, while her claim for failure to

warn contended that MSD failed to fulfill its duty to warn the public of the

unreasonable danger created by the drainage system. Albright’s primary

contention was that MSD was negligent in failing to install a grate over the

entrance to the pipe or, at the very least, for failing to warn the public of the

pipe’s dangers, of which it had or should have had knowledge. MSD’s answer

to Albright’s complaint asserted several defenses including municipal immunity

under CALGA.

4 After roughly one year of pre-trial proceedings that included numerous

depositions, expert reports, and various other items of discovery, MSD filed a

motion for summary judgment. MSD’s motion asserted it was entitled to

summary judgment, in pertinent part, 3 because it was immune from suit

pursuant to CALGA. In particular, under KRS 65.2003, which states that a

local government “shall not be liable for injuries or losses resulting from any

claim arising from the exercise of. . . legislative or quasi-legislative authority.”

KRS 65.2003 then provides a non-exhaustive list of examples that include

“[t]he adoption or failure to adopt any ordinance, resolution, order, regulation,

or rule;” “[t]he exercise of discretion when in the face of competing demands,

the local government determines whether and how to utilize or apply existing

resources;” and the “failure to make an inspection.” KRS 65.2003(3)(a), (d),

and (e).

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Louisville & Jefferson County Metropolitan Sewer District v. Jennifer Albright, Individually and as Administratrix of the Estate of David K. Albright, Counsel Stack Legal Research, https://law.counselstack.com/opinion/louisville-jefferson-county-metropolitan-sewer-district-v-jennifer-ky-2025.