KY: Relationship Between Probation Officer and Probationer Qualifies for Special Relationship Exception to Public Duty Doctrine

Lane v. Ky. Dep’t of Corr., ___ S.W.3d ____, ____, 2025 WL 2678860, at *15, 2025 Ky. App. LEXIS 78, at *37 (2025) (“The supervisory relationship here—though not involving physical confinement—was sufficient to establish legal control. The law does not require constant physical custody; it requires the power and duty to take reasonable steps to prevent foreseeable harm. [Probation officer’s] statutory obligation to monitor and report probation violations placed him in precisely such a position …