The Kentucky Court of Appeals recently ruled in favor of the Parking Authority of River City (PARC), overturning a previous jury verdict that awarded $1.7 million to a class of individuals who claimed they were improperly charged for parking violations. This decision, rendered on November 6, 2026, affects those who received parking citations in Louisville and raises important questions about the enforcement of parking laws in the area.
The case, Parking Authority of River City v. L. Stanley Chauvin, III, Class Representative (Docket No. 2025-CA-0363), stemmed from a dispute over how PARC notified individuals of parking violations. The court's ruling has significant implications for the future of parking enforcement in Kentucky.
Background
The dispute began when the Kentucky General Assembly passed the Local Government Parking Citation Enforcement Act in 1984, allowing local governments to enact parking ordinances. This law required that individuals who received parking citations respond within seven days, either by paying the fine or requesting a hearing.
In 2004 and 2005, the Louisville/Jefferson County Metro Government enacted local ordinances that delegated enforcement of parking violations to PARC. The controversy arose when it was revealed that PARC sent second notices of parking violations via regular mail instead of certified mail, which was required by the statute before it was amended in 2011. This led to allegations of due process violations and a federal lawsuit in 2007, followed by a civil action in 2008 where individuals sought class certification against PARC.
The Ruling
The Kentucky Court of Appeals, led by Judge Moynahan, ruled that the Jefferson Circuit Court erred in denying PARC's motion for a judgment notwithstanding the verdict (JNOV). The court stated, "We hold that the Jefferson Circuit Court erred when it denied PARC’s motion for a judgment notwithstanding the verdict and remand this case with instructions for the circuit court to enter an order dismissing this matter." The ruling effectively dismissed the class action claims against PARC.
The court found that the evidence presented did not adequately establish that PARC's failure to send second notices via certified mail was the proximate cause of the damages claimed by the class. The ruling emphasized that while PARC may have violated the statute, the plaintiffs did not demonstrate that this violation directly resulted in their injuries.
Impact
This ruling has significant implications for the enforcement of parking laws in Kentucky. It clarifies that while local governments must follow specific procedures when issuing parking citations, failure to do so does not automatically result in liability for damages if the plaintiffs cannot prove that the violation caused them harm.
The decision may also discourage similar class action lawsuits against local government entities in the future, as it sets a precedent that emphasizes the need for clear evidence of causation in negligence claims. Individuals who received parking citations and paid fines may need to consider the implications of this ruling before pursuing legal action.
What's Next
Following this ruling, it is unclear whether the class will seek to appeal to the Kentucky Supreme Court. However, the court's decision has effectively dismissed the claims against PARC, and there are currently no related cases pending that could alter this outcome.
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