Charlie Kirk’s family has filed a notice of claim against Utah Valley University, the state of Utah and individuals involved in campus leadership and security decisions.
The filing, a precursor to a lawsuit, alleges their failures led to the Turning Point USA founder’s wrongful death.
The prospective plaintiffs are Kirk’s widow, Erika Kirk, and their two juvenile children.
The filing also acknowledges potential claims from his parents, Robert and Kathryn, but does not specify monetary damages.
Kirk, a 31 year old father of two, was shot and killed in a UVU campus courtyard on Sept. 10, 2025.
Authorities say a lone gunman fired from a sniper position on the Losee Center rooftop across the clearing.
Lawyers for the suspect, 23 year old Tyler Robinson, pleaded not guilty on his behalf at an arraignment nearly one year later.
The Kirk family’s filing, signed by attorneys Loren Washburn, Brett Parkinson and Clifford Parkinson, is dated Sept. 9.
“The risk of a rooftop shooter should have been especially top-of-mind given the attempted assassination of President Trump, Charlie Kirk’s close friend and political ally, by a rooftop shooter the previous year,” the filing states.
The notice cites an alleged exchange between Turning Point USA organizers and UVU Police Chief Jeffrey Long.
Organizers reportedly told Long that UVU students had warned them about rooftop access to the Sorenson Center, located “pretty close” to where Kirk was scheduled to speak.
The Sorenson Center sits directly west of the Losee Center, where authorities say the fatal shot originated.
“If this is true, it would be nice to either have it controlled access or allow one of my guys to be there as well,” someone at TPUSA wrote to Long, according to the filing. “If possible.”
“I got you covered,” Long allegedly replied.
Brett Parkinson, counsel for the Kirk family, called the killing entirely preventable and blamed the state and university for allegedly failing to deliver promised security.
He said those promises included protecting the rooftops surrounding the quad where Kirk was speaking.
The filing says Kirk built TPUSA into the country’s largest conservative campus and youth activist organization.
He spoke at the Republican National Conventions in 2016, 2020 and 2024, and had become a personal friend of President Trump and other prominent figures, including leading Utah politicians.
Kirk had detractors, received death threats and publicly discussed those threats before the assassination.
“You should not have to walk around with security for your entire family and for myself just because you support a politician or political candidate or certain values,” he said at an event in May 2025.
“We get death threats,” Kirk continued.
“People want to murder us.”
The filing alleges UVU failed to conduct a meaningful risk assessment or understand the significance of Kirk’s campus appearance.
Campus police allegedly had no written security plan and held no security briefing beforehand.
Attorneys accused university officials of “walking [Kirk] into a fishbowl” surrounded by tall buildings and elevated positions.
The filing says UVU could have rejected the outdoor quad, moved the event indoors or selected a more secure location, as it had done for controversial speakers previously.
Only six campus police officers were assigned to an event that attracted roughly 3,000 spectators, according to the filing.
Long allegedly requested permission from then UVU President Astrid Tuminez to assign more than six officers, representing 25% of the university police force, but the request was denied.
After that denial, campus police did not seek additional personnel from neighboring agencies such as the Orem or Provo police departments, the filing alleges.
WATCH:
It also claims first responders were unavailable after Kirk was shot, forcing his transportation to Timpanogos Regional Hospital in a private vehicle rather than an ambulance.
The university and its leaders had authority unavailable to TPUSA and Kirk’s private security team, according to the notice.
Those powers included establishing a security perimeter, installing physical barriers, deploying metal detectors and using safety measures employed at campus sporting events.
Although UVU had a security camera system, the filing says footage was not monitored in real time.
It also alleges officials used no drones to watch rooftops or other areas around the sprawling outdoor gathering.
“After-the-fact review of the footage at the Preliminary Hearing in the criminal prosecution of the alleged shooter Tyler Robinson showed the shooter running across the roof of the Losee Building to a ‘sniper’s nest,’” the family’s attorneys wrote.
“If such footage had been monitored in real-time, Kirk’s tragic death could have been avoided.”
The Losee Center rooftop allegedly remained unsecured despite warnings about rooftop access.
According to the filing, students were known to frequent the roof, where people often found discarded beer bottles, trash or paraphernalia.
The notice also raises a claim of “state-created danger” under the U.S. Constitution.
“Instead, Mr. Kirk was exposed to the danger of a rooftop shooter that took his life,” the filing concludes.
