Pass "Tony’s Law": A Plan for Prevention

The Issue

TONY' S LAW
Revised Fully Assembled Legislative Package
Kentucky Prefile Bill Package
TABLE OF CONTENTS
TAB 1 — Clean Prefile Bill Text
TAB 2 — Section-by-Section Summary
TAB 3 — LRC Bill Summary
TAB 4 — Fact Sheet
TAB 5 — Fiscal Note
TAB 6 — Implementing Regulation
TAB 7 — Standardized Forms
TAB 8 — Data Dictionary and Validation Rules
TAB 9 — Audit Procedures
TAB 10 — Model Statewide Memorandum of Understanding
TAB 1 — CLEAN PREFILE BILL TEXT
AN ACT relating to transparency, family notifications, whistleblower protections, critical incident safety, custodial grievance procedures, and deaths in custody reporting, and creating new sections of Ky. Rev. Stat. Ann. ch. 61.
Be it enacted by the General Assembly of the Commonwealth of Kentucky:
SECTION 1. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
This Act shall be known and may be cited as "Tony's Law."
SECTION 2. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
As used in Sections 1 to 13 of this Act, unless the context requires otherwise:
(1) "Agency" means any department, office, board, commission, instrumentality, or political subdivision of the Commonwealth or local government, including a law enforcement agency, correctional institution, jail, detention center, juvenile detention facility, or contractor operating or providing services within such facility;
(2) "Autopsy findings" means the official determination or findings of a coroner, medical examiner, or other authorized death investigator regarding cause of death, manner of death, autopsy status, or related death-investigation findings lawfully releasable by the lead agency;
(3) "Cabinet" means the Justice and Public Safety Cabinet;
(4) "Case closure" means the final investigative disposition of a covered death or the final closure entry made in the deaths-in-custody reporting system;
(5) "Confidential or bypass grievance" means a grievance submitted through a correctional grievance platform using the confidential or bypass selection that routes the grievance outside the local facility chain of command and restricts local access to the content and filer identity except as otherwise authorized by law or by administrative regulation promulgated under this Act;
(6) "Correctional grievance platform" means any tablet, kiosk, secure digital interface, or other electronic grievance submission system made available to an inmate, prisoner, or detainee for the submission of requests, complaints, grievances, safety concerns, or allegations of misconduct;
(7) "Covered death" means a death that is reportable within the state deaths-in-custody reporting system for purposes of federal deaths-in-custody reporting compliance;
(8) "Deaths-in-custody reporting system" or "state DCRA reporting system" means the statewide system designated by the Cabinet for collection, validation, retention, and transmission of deaths-in-custody data;
(9) "Dual-key sign-off" means a synchronized digital closure authorization requiring separate authentication by two (2) authorized users through distinct credentials recorded in the system audit log;
(10) "Evidence tampering" has the same meaning as in Ky. Rev. Stat. Ann. § 524.100;
(11) "Family briefing" means a voluntary informational communication with next of kin that is limited to nonexempt factual updates and does not include privileged or protected information;
(12) "Independent oversight body" means the office or entity designated by the Cabinet by administrative regulation to receive, review, manage, and close confidential or bypass grievances outside the chain of command of the facility in which the inmate, prisoner, or detainee is housed. The independent oversight body may be referred to in forms, regulations, data structures, or technical specifications as the "Office";
(13) "Institutional grievance" means a grievance submitted through the correctional grievance platform for review and action within the ordinary institutional grievance process;
(14) "Investigative strategy" means case theories, informant identities, surveillance plans, prospective witness interviews, or planned investigative steps that are not otherwise publicly disclosable;
(15) "Legal privilege" includes attorney-client privilege, work-product protection, law-enforcement exemptions, grand jury secrecy, and any other privilege or confidentiality protection recognized by the Constitution of the United States, the Constitution of Kentucky, the Kentucky Revised Statutes, the Kentucky Rules of Criminal Procedure, or other applicable law;
(16) "Next of kin" means, in the following order of priority, a spouse, adult child, parent, adult sibling, or designated agent or other person legally entitled to control disposition of remains or receive death-related information;
(17) "Preliminary notice" means an initial good-faith effort to notify next of kin that a covered death has occurred, to identify an agency liaison, and to provide only basic nonprivileged information then known;
(18) "Protected disclosure" means a good-faith report of evidence tampering, obstruction, record destruction, fund misuse, retaliation, legal violations, or a health or safety danger made to a supervisor, inspector general, law enforcement agency, prosecuting authority, the Attorney General, the Auditor of Public Accounts, the Legislative Research Commission when otherwise permitted by law, or any other authority designated by administrative regulation;
(19) "Retaliatory action" means an adverse employment action or materially adverse act that would dissuade a reasonable person from making a protected disclosure;
(20) "Shielded Review Active" means a restricted dashboard status indicating that a confidential or bypass grievance has been submitted and is under independent review, without disclosing grievance content, attachments, filer identity, or reviewer notes to local facility staff;
(21) "WORM digital vault" means write-once-read-many immutable storage that preserves records, metadata, access logs, signature logs, timestamps, routing history, and related digital evidence in a nonrewritable and nonerasable format for the retention period required by this Act.
SECTION 3. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) An agency may conduct a discretionary family briefing regarding a covered death if the agency determines that the briefing can be conducted consistently with public safety, investigative integrity, legal privilege, and the rights of affected persons.
(2) A family briefing conducted under this section shall not:
(a) Waive any legal privilege;
(b) Require disclosure of exempt information; or
(c) Create any right to obtain investigative strategy, prosecutor work product, grand jury material, or any other information protected from disclosure by law.
(3) A family briefing shall be limited to nonexempt factual information and status updates.
(4) An agency may establish reasonable ground rules for attendance, timing, participation, note-taking, and recording.
(5) Nothing in this section shall be construed to create a private right to compel a family briefing.
SECTION 4. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) When a covered death is known or reasonably believed to have occurred, the lead agency or responsible facility shall make reasonable efforts to provide preliminary notice to the next of kin within twenty-four (24) hours after the death or discovery of the death, whichever occurs later.
(2) Preliminary notice under this section shall be limited to:
(a) A statement that a death has occurred or is believed to have occurred;
(b) The date, approximate time, and location, if then known and lawfully disclosable;
(c) The name and contact information of a liaison or designated agency representative; and
(d) A statement that additional information may later be provided as permitted by law.
(3) Preliminary notice may be delayed only if:
(a) The next of kin cannot with reasonable diligence be identified or located;
(b) Immediate notice would create a substantial and articulable safety, investigative, or prosecutorial risk; or
(c) Exceptional circumstances documented by the agency make compliance impracticable despite reasonable efforts.
(4) Any delay under subsection (3) of this section shall be documented, including the basis, approving authority, and next review date.
(5) Within three (3) business days of case closure, the lead agency shall provide written notice to the next of kin.
(6) The written notice required by subsection (5) of this section shall include:
(a) A statement that the case has been closed;
(b) The date of closure;
(c) A plain-language summary of the closure that is limited to nonprivileged and nonexempt information; and
(d) The name and contact information of a liaison or designated agency representative.
(7) Written notice under subsection (5) of this section may be delayed only if the agency documents a substantial and articulable investigative or prosecutorial risk that would result from immediate notice.
(8) The agency shall document delivery of any notice required by this section or document reasonable attempts at delivery.
SECTION 5. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) Within two (2) business days after receipt of autopsy findings or within two (2) business days after transmittal of those findings to the appropriate prosecutor, whichever occurs later, the lead agency shall provide written notice to the next of kin.
(2) The notice shall include:
(a) A plain-language statement of the cause of death, if available and lawfully disclosable;
(b) A statement of the manner of death, if available and lawfully disclosable; and
(c) Whether the findings are preliminary or final.
(3) Notice under this section may be delayed only if the agency documents a substantial and articulable investigative or prosecutorial risk that would result from immediate notice, and if the findings have been transmitted to a prosecutor, the delay shall be coordinated with that prosecutor.
(4) An agency providing notice under this section shall coordinate with the coroner, medical examiner, or prosecuting authority as necessary to respect legal restrictions on disclosure, including Ky. Rev. Stat. Ann. § 72.025 and Ky. R. Crim. P. 5.24 as applicable.
(5) The agency shall document delivery of the notice or reasonable attempts at delivery.
SECTION 6. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) No agency, public officer, employee, contractor, or agent shall take retaliatory action against a person because that person made or was perceived to have made a protected disclosure.
(2) Any policy, confidentiality agreement, nondisclosure agreement, handbook provision, or employment term that purports to prohibit, penalize, or chill a protected disclosure shall be void as against public policy to that extent.
(3) A person aggrieved by a violation of this section may bring a civil action for:
(a) Prospective injunctive relief;
(b) Reinstatement, if applicable;
(c) Back pay, front pay in lieu of reinstatement when reinstatement is impracticable, and restoration of benefits;
(d) Reasonable attorney's fees and costs; and
(e) A civil penalty of ten thousand dollars ($10,000) per prevailing action, payable to the General Fund of the Commonwealth.
(4) If a retaliatory action occurs within one hundred eighty (180) days after a protected disclosure, a rebuttable presumption shall arise that the retaliatory action was taken because of the protected disclosure.
(5) An action under this section shall be commenced within three (3) years after the alleged retaliatory action.
(6) Sovereign immunity is waived only to the limited extent necessary to permit the relief authorized by this section against the Commonwealth and its agencies, and no punitive damages shall be awarded under this section.
(7) The remedies provided by this section are supplemental to any other rights or remedies provided by law.
SECTION 7. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) The Cabinet shall:
(a) Designate the state DCRA reporting system;
(b) Promulgate administrative regulations in accordance with Ky. Rev. Stat. Ann. ch. 13A to implement this Act, including forms, training standards, immutable storage specifications, grievance-security standards, validation rules, audit procedures, compliance-scorecard methodology, and corrective-action procedures;
(c) Designate by administrative regulation the independent oversight body that will administer confidential or bypass grievance review and related escalations under Section 8 of this Act;
(d) Provide or require in-person critical incident response training for personnel who supervise or respond to covered deaths;
(e) Establish minimum standards for evidence preservation, digital record retention, litigation holds, and chain of custody;
(f) Establish minimum standards for operation of the Universal Grievance Pillar created in Section 8 of this Act;
(g) Require compatibility among agency, contractor, vendor, and local-facility data structures used to comply with this Act; and
(h) Submit an annual report to the Legislative Research Commission on implementation of this Act, including aggregate metrics on family notifications, evidence preservation compliance, grievance routing and closure metrics, safety audits, corrective-action compliance, and training completion rates, without personally identifying information.
(2) Critical incident response training shall include:
(a) In-person CPR and AED certification or recertification;
(b) Instruction that preservation of life takes priority in an emergency and that no internal policy shall be interpreted to prohibit reasonable lifesaving action otherwise authorized by law;
(c) Evidence preservation in homicide and other death-related investigations;
(d) Recognition of reportable deaths and reporting obligations; and
(e) Reporting obligations relating to protected disclosures, record preservation, and retaliation.
(3) Within ninety (90) days after a covered death occurring in a correctional institution, jail, detention center, or juvenile detention facility, the responsible agency shall complete a safety and operational audit addressing, at a minimum:
(a) Classification and housing;
(b) Medical and mental health access;
(c) Emergency response times and lifesaving efforts;
(d) Supervision and rounds, when applicable;
(e) Evidence preservation; and
(f) Corrective actions and deadlines.
(4) Evidence preservation requirements shall include:
(a) Immediate preservation of all known related records, video, audio, logs, communications, and digital evidence;
(b) A requirement that digital evidence be copied to immutable storage within forty-eight (48) hours of identification when reasonably available;
(c) Maintenance of chain-of-custody logs;
(d) Issuance and tracking of litigation holds where required; and
(e) Recognition that intentional destruction, concealment, or material alteration of evidence relating to a covered death constitutes a protected disclosure concern under this Act.
SECTION 8. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) The Cabinet shall require each state correctional institution, and each local jail or detention facility housing state prisoners to the extent provided by administrative regulation, to maintain within any correctional grievance platform a Universal Grievance Pillar that permits an inmate, prisoner, or detainee to select one (1) of two (2) grievance paths at the time of submission.
(2) Path A — Regular Grievance (Institutional).
A grievance submitted without selection of the confidential or bypass option shall be processed as an institutional grievance and shall comply with the following minimum standards:
(a) The grievance shall be visible to the local grievance counselor or other designated institutional grievance official for immediate review and action;
(b) The grievance status displayed to the warden, jailer, or other facility administrator shall remain "IN PROGRESS," or an equivalent nonfinal status, unless and until dual-key sign-off occurs or an approved nonoverride exception workflow is initiated and documented under administrative regulation;
(c) Dual-key sign-off for closure shall require:
1. Authentication by the grievance counselor or designated institutional reviewer through biometric verification, secure personal identification number, or other Cabinet-approved credential on the counselor's terminal; and
2. Authentication by the inmate, prisoner, or detainee through biometric verification, secure personal identification number, or other Cabinet-approved credential on the assigned tablet, kiosk, or secure device;
(d) No system administrator, vendor employee, facility administrator, or other employee shall manually mark an institutional grievance as "Complete," "Closed," or other final disposition without both digital signatures required by paragraph (c) of this subsection; and
(e) If the inmate, prisoner, or detainee refuses to sign, is unavailable, is transferred, is released, is medically unable to authenticate, or cannot authenticate because of a documented technology failure, the grievance shall remain unresolved unless administrative regulation establishes a documented nonoverride exception workflow that preserves the unresolved or exception status and the full audit trail, but no local staff member may use that condition as a substitute for the required dual-key sign-off.
(3) Path B — Confidential or Bypass Grievance (Independent Review).
A grievance submitted with the confidential or bypass option selected shall comply with the following minimum standards:
(a) The grievance content, attachments, filer identity, and routing details shall be encrypted in transit and at rest;
(b) The grievance shall be shielded from all staff assigned to the current facility and routed directly to the independent oversight body;
(c) The local institutional dashboard shall display only that a "Shielded Review Active" status exists and shall not reveal the content of the grievance or the identity of the filer except as authorized by law or administrative regulation for emergency safety purposes;
(d) No local grievance counselor, warden, jailer, facility administrator, system administrator, or vendor employee shall access, edit, delete, or close a confidential or bypass grievance except as expressly authorized by law or administrative regulation;
(e) A confidential or bypass grievance may be marked "Complete," "Closed," or other final disposition only upon dual-key sign-off by:
3. The assigned independent reviewer through biometric verification, secure personal identification number, or other Cabinet-approved credential on a secure external portal; and
4. The inmate, prisoner, or detainee through biometric verification, secure personal identification number, or other Cabinet-approved credential on the assigned tablet, kiosk, or secure device; and
(f) Any emergency disclosure to local staff shall be limited to the minimum information necessary to address an imminent risk of serious harm and shall be documented in the audit log, including the time, basis, approving authority, and information disclosed.
(4) No manual override.
No person, including a system administrator, facility administrator, contractor, vendor, or other employee, shall possess authority to override the digital closure requirements established in subsection (2)(c) or subsection (3)(e) of this section for the purpose of entering a final grievance disposition.
(5) Immediate escalation.
Any override attempt, unauthorized access attempt, deletion attempt, routing failure, or other security event affecting a grievance record shall be preserved in the audit log and escalated immediately to the independent oversight body.
(6) Immutable recordkeeping.
All grievances submitted through the Universal Grievance Pillar, including intake selections, routing events, visibility restrictions, entries, attachments, timestamps, status changes, disclosures, authentication events, signature logs, access logs, attempted access logs, exception records, retaliation-review records, and closure records, shall be stored in a WORM digital vault for not less than ten (10) years.
(7) Auditability and authenticity.
The system shall maintain audit controls sufficient to identify each access, attempted access, view, signature event, routing action, edit, disclosure, and failed closure attempt associated with a grievance record.
(8) Retaliation monitoring.
The Cabinet shall establish automated or equivalent monitoring for patterns suggesting retaliation relating to grievance submissions, including repeated housing changes, disciplinary actions, loss of privileges, transfer patterns, or staff access anomalies occurring after filing of a grievance, and shall establish escalation criteria by administrative regulation.
(9) Forms and implementation.
The Cabinet shall promulgate administrative regulations in accordance with Ky. Rev. Stat. Ann. ch. 13A to implement this section, designate the independent oversight body, establish technical and security specifications, create standardized forms, define documented exception handling, require local access restriction for bypass grievances, and amend or supersede any conflicting policy, procedure, or vendor contract governing inmate tablet communications, grievance review, confidentiality, or record retention.
(10) Minimum standards.
This section establishes minimum standards and shall not be construed to limit any greater confidentiality, retention, auditability, or inmate grievance protection otherwise required by law.
SECTION 9. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) The General Assembly finds and declares that the purposes of this Act are to:
(a) Support families affected by covered deaths with timely and plain-language information;
(b) Improve accountability and lifesaving response in custodial settings;
(c) Preserve evidence and deter tampering;
(d) Protect good-faith reporting; and
(e) Establish secure grievance procedures that permit both institutional resolution and confidential bypass review.
(2) Nothing in this Act shall be construed to:
(a) Expand, waive, or diminish any exemption under the Kentucky Open Records Act, Ky. Rev. Stat. Ann. §§ 61.870-.884;
(b) Require disclosure of grand jury material, investigative strategy, informant information, or privileged material; or
(c) Limit any lawful authority of a prosecutor, coroner, medical examiner, or law enforcement agency.
SECTION 10. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) Nothing in this Act shall be construed to alter the scope of the Kentucky Open Records Act or to require the disclosure of records exempt from inspection under law, including Ky. Rev. Stat. Ann. § 61.878.
(2) Agencies shall protect personally identifying information relating to witnesses, informants, medical information, and other protected information to the extent required by law.
(3) Nothing in this Act shall be construed to require an agency to create a record that is not otherwise required by law, except to the extent this Act expressly requires notice documentation, chain-of-custody logs, audit records, grievance-signature records, litigation-hold documentation, corrective-action records, or administrative forms promulgated under this Act.
(4) The provisions of this Act shall be coordinated with all otherwise applicable laws governing coroners, medical examiners, prosecutors, correctional operations, juvenile justice facilities, and jail standards.
SECTION 11. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) The standards established by this Act are minimum standards, and an agency may adopt policies or procedures that provide greater protection, greater transparency, greater retention, more timely notification, or stronger confidentiality so long as those policies or procedures are not inconsistent with this Act or other applicable law.
(2) A willful failure by an agency employee to comply with a mandatory duty established under Sections 4, 5, 7, or 8 of this Act may constitute grounds for discipline in accordance with applicable law and personnel policy.
(3) A next of kin aggrieved by a willful failure to provide notice required under Section 4 or 5 of this Act may seek prospective injunctive relief to compel future compliance, but no damages remedy is created by this subsection.
(4) The Cabinet may issue deficiency notices, require corrective action plans, and require follow-up documentation for repeated or material noncompliance with mandatory duties established by this Act or by administrative regulation promulgated under this Act.
(5) Nothing in this section shall impair a cause of action otherwise authorized by Section 6 of this Act.
SECTION 12. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
If any provision of this Act or its application to any person or circumstance is held invalid, the invalidity shall not affect other provisions or applications of this Act that can be given effect without the invalid provision or application, and to this end the provisions of this Act are severable.
SECTION 13. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
This Act takes effect January 1, 2027, and shall apply prospectively. The Cabinet shall begin promulgation of administrative regulations, designation of the independent oversight body, preparation of forms, and implementation planning before the effective date as necessary to ensure timely implementation.
TAB 2 — SECTION-BY-SECTION SUMMARY
Sections 1-2: Title and Definitions
Establishes the short title, "Tony's Law."
Defines the key terms needed for family notifications, evidence preservation, whistleblower protections, covered-death reporting, and the Universal Grievance Pillar.
Adds or clarifies:
● confidential or bypass grievance;
● correctional grievance platform;
● independent oversight body, also usable as the "Office" in implementation materials;
● preliminary notice;
● Shielded Review Active;
● dual-key sign-off; and
● WORM digital vault.
Sections 3-5: Family Notifications
Allows discretionary family briefings that do not waive privilege.
Requires reasonable efforts to provide preliminary next-of-kin notice within 24 hours of death or discovery, subject to limited documented exceptions.
Requires next-of-kin written notice within 3 business days of case closure.
Requires next-of-kin written notice within 2 business days of autopsy findings or transmittal to the prosecutor, whichever occurs later.
Limits disclosures to nonprivileged, plain-language facts and requires delivery documentation or reasonable-attempt documentation.
Section 6: Whistleblower Protections
Bars retaliation for good-faith protected disclosures.
Voids conflicting NDAs or policies to the extent they chill protected disclosures.
Creates a civil remedy with injunctive relief, reinstatement or front pay, back pay, fees, and a $10,000 civil penalty.
Includes a 180-day rebuttable presumption and a limited sovereign-immunity waiver.
Section 7: Implementation and Safety Oversight
Directs the Cabinet to designate the state DCRA system and the independent oversight body.
Requires regulations, forms, immutable storage standards, validation rules, audit procedures, compliance-scorecard methods, and corrective-action procedures.
Requires in-person critical incident training.
Requires 90-day safety and operational audits.
Requires evidence preservation, litigation holds where applicable, and 48-hour WORM copying when reasonably available.
Section 8: Universal Grievance Pillar
Creates two grievance paths:
● Path A: Regular institutional grievance.
● Path B: Confidential or bypass grievance to the independent oversight body.
Requires dual-key sign-off for grievance closure, subject only to a documented nonoverride exception workflow.
Prohibits manual overrides.
Requires immediate escalation of override attempts and unauthorized access events.
Requires 10-year WORM retention.
Requires retaliation monitoring and technical-security standards.
Sections 9-10: Construction and Privacy
Preserves Kentucky Open Records Act exemptions.
Preserves privilege, grand jury secrecy, investigative confidentiality, and protected personal information.
Prevents the Act from being read to require disclosure of exempt information.
Section 11: Minimum Standards and Enforcement
Establishes minimum standards.
Allows agencies to exceed the minimum.
Provides for discipline for willful noncompliance with mandatory duties.
Allows limited injunctive relief for family-notice failures.
Authorizes Cabinet deficiency notices and corrective-action demands for material or repeated noncompliance.
Sections 12-13: Severability and Effective Date
Contains a severability clause.
Makes the Act effective January 1, 2027, prospectively only, while allowing pre-effective-date implementation work.
TAB 3 — LRC BILL SUMMARY
This bill creates a statutory framework for family notifications, custodial evidence preservation, whistleblower protections, critical incident training, deaths-in-custody reporting, and an updated grievance-routing system for correctional tablet and kiosk interfaces.
The bill:
● authorizes discretionary family briefings;
● requires reasonable efforts to provide preliminary notice to next of kin within 24 hours of death or discovery, subject to limited documented exceptions;
● requires timely written notice to next of kin after case closure and after autopsy findings or prosecutorial transmittal;
● prohibits retaliation against protected disclosures;
● directs the Cabinet to promulgate implementing regulations and designate an independent oversight body;
● requires in-person CPR/AED and critical incident response training;
● requires 90-day safety and operational audits after covered deaths;
● requires evidence preservation, litigation-hold tracking, and immutable storage transfers where required;
● creates a Universal Grievance Pillar with regular and confidential/bypass grievance paths;
● requires dual-key sign-off for grievance closure and prohibits manual overrides;
● requires immutable WORM retention of grievance records for ten years;
● and preserves existing privilege and Open Records protections.
The bill does not expand the Kentucky Open Records Act or require disclosure of exempt investigative records.
TAB 4 — FACT SHEET
WHAT THE BILL DOES
● Requires reasonable efforts to provide preliminary family notification within 24 hours of death or discovery.
● Requires family notification after case closure within 3 business days.
● Requires family notification after autopsy findings or prosecutorial transmittal within 2 business days.
● Allows family briefings that do not waive privilege.
● Protects whistleblowers from retaliation.
● Requires CPR/AED and critical incident response training.
● Requires 90-day safety and operational audits after covered deaths.
● Requires evidence preservation, chain-of-custody documentation, litigation-hold tracking, and 48-hour WORM copying when reasonably available.
● Creates a Universal Grievance Pillar for correctional tablet and kiosk systems.
● Adds a confidential or bypass grievance path to an independent oversight body.
● Requires dual-key sign-off for grievance closure.
● Requires immediate escalation of override or unauthorized access events.
● Requires ten-year WORM retention of grievance records and audit logs.
● Requires automated or equivalent retaliation monitoring.
● Requires corrective-action plans and compliance scoring.
WHY IT MATTERS
● Helps families receive timely, plain-language updates.
● Improves early communication without waiving privilege.
● Reduces the risk that grievances are buried inside the local chain of command.
● Preserves a verifiable audit trail.
● Protects staff, contractors, inmates, prisoners, and detainees from retaliation.
● Improves transparency while preserving lawful confidentiality.
● Gives the Cabinet a uniform statewide implementation framework.
KEY IMPLEMENTATION FEATURES
Feature Requirement
Preliminary family notice Reasonable efforts within 24 hours
Case-closure notice Within 3 business days
Autopsy/prosecutor notice Within 2 business days
Institutional grievance path Local review and dual-key closure
Confidential/bypass path Routed to independent oversight body
Closure control No manual override
Security incident handling Immediate escalation to Office
Record storage WORM retention for 10 years
Retaliation monitoring Automated or equivalent pattern detection
Corrective action Required for material deficiencies
TAB 5 — FISCAL NOTE
TONY'S LAW
Revised Advocacy Fiscal Estimate
This is an advocacy fiscal estimate only.
ESTIMATED COST CATEGORIES
Component Estimated Startup Estimated Annual
DCRA system updates and integration $150,000 $60,000
Grievance-platform routing, shielding, and audit controls $125,000 $45,000
Training curriculum and delivery $125,000 $55,000
WORM storage, retention, and litigation-hold tracking $110,000 $40,000
Forms, audits, scorecards, and corrective-action administration $75,000 $25,000
Total $585,000 $225,000
NOTES
● Uses existing Cabinet and facility infrastructure where possible.
● Costs may vary depending on the number of local facilities, existing vendor contracts, and current audit-log capability.
● The grievance pillar and 10-year retention requirement add system-routing, shielding, escalation, and long-term storage costs.
● A final official fiscal note should be requested from state fiscal staff before introduction.
TAB 6 — IMPLEMENTING REGULATION
501 KAR [XX]:[XXX]
IMPLEMENTING REGULATION FOR TONY'S LAW
Section 1. Purpose and Scope.
This administrative regulation establishes minimum standards for implementation of Tony's Law, including family notifications, evidence preservation, covered-death reporting, critical incident training, the Universal Grievance Pillar, grievance routing, WORM retention, corrective-action procedures, compliance scoring, and reporting.
Section 2. Definitions.
(1) Terms used in this administrative regulation have the meanings assigned in Tony's Law.
(2) "Office" means the independent oversight body designated by the Cabinet under Tony's Law.
Section 3. Standardized Notifications.
(1) Case-closure notices required by Section 4 of Tony's Law shall be issued on Form TL-1.
(2) Autopsy-findings notices required by Section 5 of Tony's Law shall be issued on Form TL-2.
(3) Delay justifications for preliminary notice, TL-1, or TL-2 shall be recorded on Form TL-3.
(4) Delivery proof shall be maintained in the agency record, or the agency shall document reasonable attempts at delivery.
(5) Preliminary notice required by Section 4 of Tony's Law may be delivered orally or in writing but shall be documented in the agency record.
Section 4. Family Briefings.
(1) Family briefings are discretionary.
(2) They are limited to nonexempt facts.
(3) No privilege waiver occurs.
(4) Agencies may require a briefing agreement on Form TL-4.
(5) No recording shall occur without agency consent unless otherwise required by law.
Section 5. Covered-Death Reporting.
(1) Agencies shall submit initial and supplemental covered-death data to the state DCRA reporting system using Form TL-10 or a Cabinet-approved machine-readable equivalent.
(2) Agencies shall update the report upon autopsy receipt, prosecutorial transmittal, material correction, and case closure as required by Tab 8.
(3) Quarterly zero reports shall be submitted when required.
Section 6. Critical Incident Response Training.
(1) Required for staff who supervise or respond to covered deaths.
(2) Includes CPR/AED certification, lifesaving response, evidence preservation, covered-death reporting, litigation-hold awareness, and protected-disclosure duties.
(3) Training rosters and certifications shall be retained.
Section 7. Safety and Operational Audits.
(1) Each covered death in a facility shall trigger a 90-day audit.
(2) Audits shall use Form TL-5.
(3) Findings shall address classification, medical access, response times, lifesaving efforts, supervision, evidence preservation, and corrective actions.
(4) Corrective action plans shall be documented on Form TL-11 when required.
Section 8. Evidence Preservation and WORM Storage.
(1) Related records, video, audio, logs, communications, metadata, and other known evidence shall be preserved.
(2) Digital evidence shall be copied to immutable WORM storage within 48 hours when reasonably available.
(3) Chain-of-custody documentation shall be maintained.
(4) Litigation holds shall be issued, tracked, and acknowledged when required.
(5) Evidence-preservation logs shall be documented on Form TL-6.
Section 9. Universal Grievance Pillar.
(1) Each correctional grievance platform shall include two grievance paths:
(a) Regular institutional grievance; and
(b) Confidential or bypass grievance routed to the Office.
(2) Institutional grievances shall remain in nonfinal status until dual-key sign-off occurs or a documented nonoverride exception workflow is applied.
(3) Confidential or bypass grievances shall be encrypted, shielded from local facility staff, and marked locally only as "Shielded Review Active" or equivalent noncontent status.
(4) Confidential or bypass grievances shall require local access restriction and Office assignment.
(5) No local staff, system administrator, or vendor employee may manually override closure requirements.
(6) Any override attempt, unauthorized access attempt, deletion attempt, or routing failure shall be logged and escalated immediately to the Office.
(7) All grievance records, signature events, routing events, access logs, retaliation-review records, exception records, and related metadata shall be preserved in a WORM digital vault for no less than 10 years.
(8) Retaliation monitoring shall be enabled for grievance-related patterns.
(9) Exception workflows shall be documented, narrowly coded, and limited to transfer, release, outage, disability, emergency, or other Office-approved circumstances defined by technical specification.
(10) The Office shall maintain secure external review access.
(11) The Cabinet shall issue technical specifications and vendor requirements.
(12) The Cabinet shall incorporate Forms TL-7 through TL-9 and any related technical appendices.
Section 10. Deficiency Notices, Corrective Action, and Compliance Scoring.
(1) Any failed required-field validation, untimely report, missing litigation-hold acknowledgment, or grievance-security event shall be logged as a compliance event.
(2) The Cabinet or Office may issue a deficiency notice to the reporting agency or facility.
(3) Material deficiencies shall require a corrective-action plan on Form TL-11.
(4) The Cabinet shall publish or internally maintain compliance scorecards based on verified data and closed audit periods only.
Section 11. Privacy and Privilege Protections.
(1) This regulation shall not expand the Kentucky Open Records Act, Ky. Rev. Stat. Ann. §§ 61.870-.884.
(2) It shall not require disclosure of privileged, exempt, or investigatory material, including materials protected by Ky. Rev. Stat. Ann. § 61.878 or Ky. R. Crim. P. 5.24.
(3) It shall not require the creation of records not otherwise required by law except as expressly stated in Tony's Law.
Section 12. Reporting.
(1) Agencies shall submit required metrics to the Cabinet on a schedule established by the Cabinet.
(2) Annual reporting to the Legislative Research Commission shall be aggregate only and shall not include personally identifying information.
Section 13. Incorporation by Reference.
The following material is incorporated by reference:
● Form TL-1, Case Closure Notification
● Form TL-2, Autopsy Findings Notification
● Form TL-3, Notification Delay Justification
● Form TL-4, Family Briefing Agreement
● Form TL-5, 90-Day Safety and Operational Audit
● Form TL-6, Evidence Chain-of-Custody / WORM Storage Log
● Form TL-7, Institutional Grievance Intake
● Form TL-8, Confidential / Bypass Grievance Intake
● Form TL-9, Grievance Closure and Audit Log
● Form TL-10, Covered-Death Initial / Supplemental Report
● Form TL-11, Corrective Action Plan and Closure Verification
● Data Dictionary v2.0
● Validation Rules v2.0
● Audit Procedures v2.0
TAB 7 — STANDARDIZED FORMS
TAB 8 — DATA DICTIONARY AND VALIDATION RULES
PURPOSE
This document establishes the minimum data fields, routing logic, timing controls, validation rules, retention rules, escalation rules, and compliance-scorecard inputs necessary to implement Tony's Law in a uniform and auditable manner across all participating agencies, facilities, contractors, and vendors.
GENERAL RULES
11. All required fields shall be captured in machine-readable form unless a narrative field is expressly permitted.
12. No platform subject to Tony's Law may suppress, overwrite, purge, or alter audit metadata required by this document.
13. All date and time fields shall use a uniform timestamp standard designated by the Cabinet.
14. Required fields that are unknown at the time of initial submission shall be marked "Unknown" and updated upon later discovery.
15. Data structures used by agencies, contractors, and vendors shall remain compatible with the statewide reporting and audit framework established by the Cabinet and the Office.
A. COVERED-DEATH REPORTING FIELDS
Field Type Description
Case_ID Text(20) Unique covered-death identifier
Reporting_Agency Text(100) Submitting agency
Lead_Agency Text(100) Lead investigating agency
Covered_Death_Category Text(50) Detained / Arrest / Incarcerated / En Route / 72-Hour Post-Release / other approved category
Decedent_Name Text(150) Full legal name, if known
Decedent_Age Integer Age at death, if known
Decedent_Race Text(50) Race category
Decedent_Ethnicity Text(50) Ethnicity category
Decedent_Gender Text(50) Gender field used by reporting agency
DateTime_Death DateTime Date and time of death
DateTime_Discovered DateTime Date and time death discovered
Facility_Location Text(100) Facility or location of death
Custody_Status Text(50) Custodial status at time of death
Circumstances_Summary Text(500) Brief narrative summary
Initial_Report_Timestamp DateTime Initial submission time
Supplemental_Report_Timestamp DateTime Supplemental submission time
Prosecutor_Referral_Timestamp DateTime Time matter referred or transmitted to prosecutor
Autopsy_Receipt_Timestamp DateTime Time autopsy findings received
Case_Closure_Timestamp DateTime Time case officially closed
Material_Error_Corrected YesNo Whether prior submission corrected
Zero_Report YesNo Quarterly no-death certification
B. FAMILY-NOTIFICATION FIELDS
Field Type Description
Next_of_Kin_Name Text(150) Name of notified person, if confirmed
Next_of_Kin_Relationship Text(50) Relationship to decedent
Preliminary_Notice_Attempted YesNo Whether preliminary notice was attempted
Preliminary_Notice_Timestamp DateTime Timestamp of preliminary notice or reasonable-attempt documentation
Preliminary_Notice_Method Text(50) In person / phone / email / mail / other
Preliminary_Notice_Delay_Documented YesNo Whether delay or exception documented
TL1_Issued YesNo Case-closure notice issued
TL1_Issue_Timestamp DateTime Timestamp of TL-1 issuance
TL2_Issued YesNo Autopsy notice issued
TL2_Issue_Timestamp DateTime Timestamp of TL-2 issuance
TL3_Delay_Used YesNo Delay justification used
Delay_Approval_Timestamp DateTime Time delay approved
Delay_Review_Timestamp DateTime Time next delay review completed
Delivery_Proof_Attached YesNo Proof of delivery attached
Reasonable_Attempts_Documented YesNo Reasonable attempts documented if delivery proof absent
Notice_Delivery_Method Text(50) In person / phone / email / mail / other
Liaison_Name Text(150) Designated liaison or representative
C. EVIDENCE PRESERVATION AND LITIGATION-HOLD FIELDS
Field Type Description
Evidence_Category Text(50) Video / audio / medical / logs / messages / metadata / other
Evidence_Source Text(150) System, camera, contractor, or source location
Preservation_Triggered YesNo Preservation triggered
Preservation_Timestamp DateTime Time preservation initiated
WORM_Transfer_Required YesNo Whether immutable transfer required
WORM_Transfer_Timestamp DateTime Time immutable transfer completed
WORM_Delay_Documented YesNo Delay documented
WORM_Delay_Reason Text(250) Reason transfer not completed within ordinary window
Chain_of_Custody_Started YesNo Chain of custody opened
Chain_of_Custody_Verified YesNo Chain verified
Litigation_Hold_Issued YesNo Hold issued
Litigation_Hold_Timestamp DateTime Hold issuance time
Hold_Recipient_List Text(500) Persons or entities notified
Hold_Acknowledged YesNo Acknowledgment received
Hold_Acknowledgment_Timestamp DateTime Time acknowledgment received
Hold_Release_Timestamp DateTime Time hold released in writing, if applicable
D. TRAINING AND POST-INCIDENT AUDIT FIELDS
Field Type Description
Facility_Audit_Required YesNo Whether 90-day audit required
Facility_Audit_Completion_Timestamp DateTime Timestamp of audit completion
CPR_AED_Training_Current YesNo Current CPR/AED certification verified
Critical_Incident_Training_Current YesNo Current critical incident training verified
Staff_Roster_Verified YesNo Staff roster confirmed accurate
Corrective_Action_Required YesNo Whether corrective-action plan required
Corrective_Action_Submitted YesNo Whether TL-11 submitted
Corrective_Action_Due_Date Date Due date for TL-11
Corrective_Action_Closed YesNo Whether corrective action completed
E. GRIEVANCE ROUTING FIELDS
Field Type Description
Grievance_ID Text(20) Unique grievance identifier
Facility_Name Text(150) Facility of origin
Grievance_Path Text(30) Institutional / Confidential / Bypass
Confidential_Bypass_Selected YesNo Whether bypass path was selected
Office_Route YesNo Routed to Office
Shielded_Review_Status Text(50) Shielded Review Active / Other
Office_Reviewer_Assigned YesNo Office reviewer assigned
Local_Access_Restricted YesNo Local staff blocked from content
Emergency_Disclosure_Made YesNo Emergency disclosure occurred
Emergency_Disclosure_Timestamp DateTime Time of emergency disclosure
Emergency_Disclosure_Basis Text(250) Imminent-harm basis
F. GRIEVANCE CLOSURE, EXCEPTIONS, AND RETENTION FIELDS
Field Type Description
Dual_Key_Required YesNo Whether dual sign-off is required
Reviewer_Signature_Timestamp DateTime Reviewer signature time
Filer_Signature_Timestamp DateTime Filer signature time
Dual_Key_Completed YesNo Whether both signatures were collected
Closure_Timestamp DateTime Final disposition timestamp
Closure_Disposition Text(50) Granted / denied / referred / other
Exception_Workflow_Used YesNo Whether exception workflow used
Exception_Workflow_Code Text(30) Transfer / Release / Outage / Disability / Emergency / Other
Exception_Approved_By Text(150) Approving authority
Override_Attempt YesNo Attempted unauthorized override
Override_Attempt_Timestamp DateTime Time of attempted override
Override_Escalated_To_Office YesNo Escalated to Office
Retaliation_Flag YesNo Monitoring flag
Retaliation_Review_Timestamp DateTime Time designated reviewer assessed retaliation flag
WORM_Retention_Years Integer Must be at least 10
WORM_Stored_Until Date Minimum retention date
G. COMPLIANCE SCORECARD FIELDS
Field Type Description
Reporting_Compliance_Score Decimal Facility or agency score
Notice_Compliance_Score Decimal Family-notification score
Preservation_Compliance_Score Decimal Preservation and hold score
Grievance_Compliance_Score Decimal Grievance-system score
Training_Compliance_Score Decimal Training completion score
Audit_Compliance_Score Decimal Audit completion score
Corrective_Action_Status Text(50) Open / overdue / cured
Overall_Compliance_Status Text(50) Compliant / needs improvement / noncompliant
VALIDATION RULES
Rule Condition Requirement
CD1 Any covered death Initial_Report_Timestamp within 24 hours of death or discovery
CD2 Any covered death Supplemental_Report_Timestamp within 7 days
CD3 Autopsy findings received Updated report within 2 business days
CD4 Prosecutor referral or transmittal Updated report within 2 business days
CD5 Case closure Updated report within 2 business days
CD6 Quarterly reporting cycle closes and no covered death reported Zero_Report = Yes
FN1 Covered death confirmed Preliminary_Notice_Attempted = Yes within 24 hours unless Preliminary_Notice_Delay_Documented = Yes
FN2 TL1_Issued = Yes TL1_Issue_Timestamp within 3 business days of case closure unless valid TL-3 delay documented
FN3 TL2_Issued = Yes TL2_Issue_Timestamp within 2 business days of autopsy receipt or prosecutorial transmittal, whichever occurs later, unless valid TL-3 delay documented
FN4 TL3_Delay_Used = Yes Delay_Approval_Timestamp required and supervisory approval required
FN5 Any required notice Delivery_Proof_Attached = Yes or Reasonable_Attempts_Documented = Yes
EV1 Preservation_Triggered = Yes Preservation_Timestamp required
EV2 WORM_Transfer_Required = Yes WORM_Transfer_Timestamp within 48 hours unless WORM_Delay_Documented = Yes
EV3 WORM_Delay_Documented = Yes WORM_Delay_Reason required
EV4 Litigation_Hold_Issued = Yes Litigation_Hold_Timestamp required
EV5 Litigation_Hold_Issued = Yes Hold_Acknowledged = Yes within 24 hours unless documented good-cause exception
EV6 Chain_of_Custody_Started = Yes Chain_of_Custody_Verified must be completed before audit closure
TR1 Facility_Audit_Required = Yes Facility_Audit_Completion_Timestamp within 90 days
TR2 Covered-death event CPR_AED_Training_Current and Critical_Incident_Training_Current must be verifiable for affected personnel
TR3 Corrective_Action_Required = Yes Corrective_Action_Submitted = Yes by due date
GR1 Confidential_Bypass_Selected = Yes Office_Route = Yes
GR2 Confidential_Bypass_Selected = Yes Local_Access_Restricted = Yes
GR3 Grievance_Path = Institutional Dual_Key_Required = Yes
GR4 Grievance_Path = Confidential / Bypass Shielded_Review_Status = Shielded Review Active
GR5 Final closure requested Dual_Key_Completed = Yes or approved exception workflow documented
GR6 Override_Attempt = Yes Override_Escalated_To_Office = Yes automatically
GR7 Retaliation_Flag = Yes Retaliation_Review_Timestamp required
GR8 Any grievance record WORM_Retention_Years >= 10
GR9 Emergency_Disclosure_Made = Yes Emergency_Disclosure_Basis required
CS1 Compliance scorecard published All component scores must be based on verified data fields and closed audit review period
ESCALATION RULES
16. Any failed required-field validation for a covered-death report shall generate a deficiency notice to the reporting agency.
17. Any untimely submission shall be logged as a compliance event for audit scoring.
18. Any override attempt, unauthorized access attempt, deletion attempt, or routing failure affecting a grievance shall be escalated immediately to the Office.
19. Any missing litigation-hold acknowledgment after 24 hours shall trigger follow-up notice to the agency head, records custodian, and designated compliance official.
20. Any overdue corrective-action submission shall generate follow-up notice and may be treated as a continuing deficiency.
21. Repeated validation failures may be treated as a significant or critical audit finding under Tab 9.
RETENTION RULES
22. Covered-death reporting records shall be retained for the period established by the Cabinet and no less than the longest applicable period required by law, audit, investigation, or litigation hold.
23. Grievance records governed by Tony's Law shall be retained in WORM storage for not less than ten (10) years.
24. Records subject to a litigation hold shall not be deleted, purged, overwritten, or disposed of until written release of the hold.
25. Audit work papers, corrective-action records, and compliance-scorecard source materials shall be retained for not less than ten (10) years unless a longer period is required by law or litigation hold.
IMPLEMENTATION NOTE
All forms, platforms, vendor configurations, data exports, dashboards, audit logs, scorecards, and corrective-action workflows shall conform to this Tab 8 document as incorporated by reference in the implementing regulation.
TAB 9 — AUDIT PROCEDURES
PURPOSE
Verify compliance with:
● covered-death reporting;
● family notifications;
● evidence preservation;
● litigation holds;
● training;
● safety audits;
● corrective action; and
● Universal Grievance Pillar operation.
AUDIT TOPICS
1. COVERED-DEATH REPORTING COMPLIANCE
Confirm timely initial and supplemental reporting.
Confirm autopsy, prosecutor, correction, closure, and zero-report updates.
Confirm data accuracy and material-correction handling.
2. NOTIFICATION COMPLIANCE
Confirm preliminary notice timing or documented exception.
Confirm TL-1 and TL-2 timing.
Confirm proof of delivery or reasonable-attempt documentation.
Confirm delay documentation where applicable.
3. TRAINING COMPLIANCE
Confirm CPR/AED and critical incident training.
Confirm staff roster accuracy.
4. EVIDENCE PRESERVATION
Confirm 48-hour WORM transfer where required.
Confirm chain-of-custody logs.
Confirm litigation-hold issuance and acknowledgment.
Confirm retention schedule.
5. GRIEVANCE PILLAR COMPLIANCE
Confirm both grievance paths are operational.
Confirm confidential/bypass routing works.
Confirm local access restriction is active for bypass grievances.
Confirm dual-key sign-off is required and cannot be overridden.
Confirm TL-7 through TL-9 are in use.
Confirm WORM retention for grievance records.
Confirm retaliation monitoring is enabled.
6. EXCEPTION HANDLING
Confirm any emergency disclosure is documented.
Confirm any unresolved grievance remains unresolved until proper sign-off or authorized workflow.
Confirm override attempts are logged and escalated.
Confirm exception workflows are coded, approved, and not used as informal overrides.
7. CORRECTIVE ACTION
Confirm written corrective-action plans are completed when required.
Confirm follow-up review occurs until cured.
Confirm overdue corrective actions are elevated in scoring.
8. FINDINGS CLASSIFICATION
● Critical
● Significant
● Minor
9. CONFIDENTIALITY
Audit work papers remain subject to applicable exemptions and privacy protections, including Ky. Rev. Stat. Ann. § 61.878 where applicable.
TAB 10 — MODEL STATEWIDE MEMORANDUM OF UNDERSTANDING
MODEL STATEWIDE MEMORANDUM OF UNDERSTANDING
PARTIES
Justice and Public Safety Cabinet
Department of Corrections
Department of Juvenile Justice
Kentucky State Police
Local Jails and Detention Centers
Coroners / Medical Examiners
Prosecutorial Offices
Other Participating Agencies
PURPOSE
To coordinate implementation of Tony's Law, including:
● covered-death reporting;
● family notifications;
● training;
● evidence preservation;
● litigation-hold compliance;
● safety audits;
● corrective action; and
● the Universal Grievance Pillar.
KEY PROVISIONS
1. DCRA REPORTING
Agencies shall coordinate data submission to the state system and use Form TL-10 or a Cabinet-approved machine-readable equivalent.
2. FAMILY NOTIFICATIONS
Agencies shall document preliminary notice efforts and shall use TL-1, TL-2, and TL-3 as applicable.
3. TRAINING
Agencies shall provide required critical incident response training and maintain training rosters.
4. EVIDENCE PRESERVATION
Agencies shall preserve records, issue and track litigation holds where required, maintain chain-of-custody documentation, and use WORM storage as required.
5. UNIVERSAL GRIEVANCE PILLAR
Agencies operating correctional tablet or kiosk grievance systems shall:
● provide the two-path grievance option;
● maintain confidential/bypass routing;
● route bypass grievances to the Office;
● restrict local access to bypass grievance content;
● prevent manual override of closure;
● preserve audit logs;
● escalate override attempts and unauthorized access events immediately; and
● retain grievance records for ten years in WORM storage.
6. FORMS
Agencies shall use TL-7, TL-8, and TL-9 for grievance intake and closure documentation, TL-11 for corrective actions, and all other Tony's Law forms as applicable.
7. DATA COMPATIBILITY
Participating agencies, vendors, and contractors shall maintain data compatibility with Cabinet technical specifications and Tab 8 validation rules.
8. DISPUTE RESOLUTION
Implementation issues shall be escalated through designated agency points of contact and, where necessary, to the Cabinet or Office.
9. TERM
This MOU remains in effect unless superseded, amended, or withdrawn in writing.
END OF REVISED PACKAGE

Ashley ElginPetition StarterI am the wife of Robert 'Tony' Broyles 9 days away from coming home he was murdered in prison He should have been safe not locked in a cage with a predator.

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The Issue

TONY' S LAW
Revised Fully Assembled Legislative Package
Kentucky Prefile Bill Package
TABLE OF CONTENTS
TAB 1 — Clean Prefile Bill Text
TAB 2 — Section-by-Section Summary
TAB 3 — LRC Bill Summary
TAB 4 — Fact Sheet
TAB 5 — Fiscal Note
TAB 6 — Implementing Regulation
TAB 7 — Standardized Forms
TAB 8 — Data Dictionary and Validation Rules
TAB 9 — Audit Procedures
TAB 10 — Model Statewide Memorandum of Understanding
TAB 1 — CLEAN PREFILE BILL TEXT
AN ACT relating to transparency, family notifications, whistleblower protections, critical incident safety, custodial grievance procedures, and deaths in custody reporting, and creating new sections of Ky. Rev. Stat. Ann. ch. 61.
Be it enacted by the General Assembly of the Commonwealth of Kentucky:
SECTION 1. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
This Act shall be known and may be cited as "Tony's Law."
SECTION 2. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
As used in Sections 1 to 13 of this Act, unless the context requires otherwise:
(1) "Agency" means any department, office, board, commission, instrumentality, or political subdivision of the Commonwealth or local government, including a law enforcement agency, correctional institution, jail, detention center, juvenile detention facility, or contractor operating or providing services within such facility;
(2) "Autopsy findings" means the official determination or findings of a coroner, medical examiner, or other authorized death investigator regarding cause of death, manner of death, autopsy status, or related death-investigation findings lawfully releasable by the lead agency;
(3) "Cabinet" means the Justice and Public Safety Cabinet;
(4) "Case closure" means the final investigative disposition of a covered death or the final closure entry made in the deaths-in-custody reporting system;
(5) "Confidential or bypass grievance" means a grievance submitted through a correctional grievance platform using the confidential or bypass selection that routes the grievance outside the local facility chain of command and restricts local access to the content and filer identity except as otherwise authorized by law or by administrative regulation promulgated under this Act;
(6) "Correctional grievance platform" means any tablet, kiosk, secure digital interface, or other electronic grievance submission system made available to an inmate, prisoner, or detainee for the submission of requests, complaints, grievances, safety concerns, or allegations of misconduct;
(7) "Covered death" means a death that is reportable within the state deaths-in-custody reporting system for purposes of federal deaths-in-custody reporting compliance;
(8) "Deaths-in-custody reporting system" or "state DCRA reporting system" means the statewide system designated by the Cabinet for collection, validation, retention, and transmission of deaths-in-custody data;
(9) "Dual-key sign-off" means a synchronized digital closure authorization requiring separate authentication by two (2) authorized users through distinct credentials recorded in the system audit log;
(10) "Evidence tampering" has the same meaning as in Ky. Rev. Stat. Ann. § 524.100;
(11) "Family briefing" means a voluntary informational communication with next of kin that is limited to nonexempt factual updates and does not include privileged or protected information;
(12) "Independent oversight body" means the office or entity designated by the Cabinet by administrative regulation to receive, review, manage, and close confidential or bypass grievances outside the chain of command of the facility in which the inmate, prisoner, or detainee is housed. The independent oversight body may be referred to in forms, regulations, data structures, or technical specifications as the "Office";
(13) "Institutional grievance" means a grievance submitted through the correctional grievance platform for review and action within the ordinary institutional grievance process;
(14) "Investigative strategy" means case theories, informant identities, surveillance plans, prospective witness interviews, or planned investigative steps that are not otherwise publicly disclosable;
(15) "Legal privilege" includes attorney-client privilege, work-product protection, law-enforcement exemptions, grand jury secrecy, and any other privilege or confidentiality protection recognized by the Constitution of the United States, the Constitution of Kentucky, the Kentucky Revised Statutes, the Kentucky Rules of Criminal Procedure, or other applicable law;
(16) "Next of kin" means, in the following order of priority, a spouse, adult child, parent, adult sibling, or designated agent or other person legally entitled to control disposition of remains or receive death-related information;
(17) "Preliminary notice" means an initial good-faith effort to notify next of kin that a covered death has occurred, to identify an agency liaison, and to provide only basic nonprivileged information then known;
(18) "Protected disclosure" means a good-faith report of evidence tampering, obstruction, record destruction, fund misuse, retaliation, legal violations, or a health or safety danger made to a supervisor, inspector general, law enforcement agency, prosecuting authority, the Attorney General, the Auditor of Public Accounts, the Legislative Research Commission when otherwise permitted by law, or any other authority designated by administrative regulation;
(19) "Retaliatory action" means an adverse employment action or materially adverse act that would dissuade a reasonable person from making a protected disclosure;
(20) "Shielded Review Active" means a restricted dashboard status indicating that a confidential or bypass grievance has been submitted and is under independent review, without disclosing grievance content, attachments, filer identity, or reviewer notes to local facility staff;
(21) "WORM digital vault" means write-once-read-many immutable storage that preserves records, metadata, access logs, signature logs, timestamps, routing history, and related digital evidence in a nonrewritable and nonerasable format for the retention period required by this Act.
SECTION 3. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) An agency may conduct a discretionary family briefing regarding a covered death if the agency determines that the briefing can be conducted consistently with public safety, investigative integrity, legal privilege, and the rights of affected persons.
(2) A family briefing conducted under this section shall not:
(a) Waive any legal privilege;
(b) Require disclosure of exempt information; or
(c) Create any right to obtain investigative strategy, prosecutor work product, grand jury material, or any other information protected from disclosure by law.
(3) A family briefing shall be limited to nonexempt factual information and status updates.
(4) An agency may establish reasonable ground rules for attendance, timing, participation, note-taking, and recording.
(5) Nothing in this section shall be construed to create a private right to compel a family briefing.
SECTION 4. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) When a covered death is known or reasonably believed to have occurred, the lead agency or responsible facility shall make reasonable efforts to provide preliminary notice to the next of kin within twenty-four (24) hours after the death or discovery of the death, whichever occurs later.
(2) Preliminary notice under this section shall be limited to:
(a) A statement that a death has occurred or is believed to have occurred;
(b) The date, approximate time, and location, if then known and lawfully disclosable;
(c) The name and contact information of a liaison or designated agency representative; and
(d) A statement that additional information may later be provided as permitted by law.
(3) Preliminary notice may be delayed only if:
(a) The next of kin cannot with reasonable diligence be identified or located;
(b) Immediate notice would create a substantial and articulable safety, investigative, or prosecutorial risk; or
(c) Exceptional circumstances documented by the agency make compliance impracticable despite reasonable efforts.
(4) Any delay under subsection (3) of this section shall be documented, including the basis, approving authority, and next review date.
(5) Within three (3) business days of case closure, the lead agency shall provide written notice to the next of kin.
(6) The written notice required by subsection (5) of this section shall include:
(a) A statement that the case has been closed;
(b) The date of closure;
(c) A plain-language summary of the closure that is limited to nonprivileged and nonexempt information; and
(d) The name and contact information of a liaison or designated agency representative.
(7) Written notice under subsection (5) of this section may be delayed only if the agency documents a substantial and articulable investigative or prosecutorial risk that would result from immediate notice.
(8) The agency shall document delivery of any notice required by this section or document reasonable attempts at delivery.
SECTION 5. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) Within two (2) business days after receipt of autopsy findings or within two (2) business days after transmittal of those findings to the appropriate prosecutor, whichever occurs later, the lead agency shall provide written notice to the next of kin.
(2) The notice shall include:
(a) A plain-language statement of the cause of death, if available and lawfully disclosable;
(b) A statement of the manner of death, if available and lawfully disclosable; and
(c) Whether the findings are preliminary or final.
(3) Notice under this section may be delayed only if the agency documents a substantial and articulable investigative or prosecutorial risk that would result from immediate notice, and if the findings have been transmitted to a prosecutor, the delay shall be coordinated with that prosecutor.
(4) An agency providing notice under this section shall coordinate with the coroner, medical examiner, or prosecuting authority as necessary to respect legal restrictions on disclosure, including Ky. Rev. Stat. Ann. § 72.025 and Ky. R. Crim. P. 5.24 as applicable.
(5) The agency shall document delivery of the notice or reasonable attempts at delivery.
SECTION 6. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) No agency, public officer, employee, contractor, or agent shall take retaliatory action against a person because that person made or was perceived to have made a protected disclosure.
(2) Any policy, confidentiality agreement, nondisclosure agreement, handbook provision, or employment term that purports to prohibit, penalize, or chill a protected disclosure shall be void as against public policy to that extent.
(3) A person aggrieved by a violation of this section may bring a civil action for:
(a) Prospective injunctive relief;
(b) Reinstatement, if applicable;
(c) Back pay, front pay in lieu of reinstatement when reinstatement is impracticable, and restoration of benefits;
(d) Reasonable attorney's fees and costs; and
(e) A civil penalty of ten thousand dollars ($10,000) per prevailing action, payable to the General Fund of the Commonwealth.
(4) If a retaliatory action occurs within one hundred eighty (180) days after a protected disclosure, a rebuttable presumption shall arise that the retaliatory action was taken because of the protected disclosure.
(5) An action under this section shall be commenced within three (3) years after the alleged retaliatory action.
(6) Sovereign immunity is waived only to the limited extent necessary to permit the relief authorized by this section against the Commonwealth and its agencies, and no punitive damages shall be awarded under this section.
(7) The remedies provided by this section are supplemental to any other rights or remedies provided by law.
SECTION 7. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) The Cabinet shall:
(a) Designate the state DCRA reporting system;
(b) Promulgate administrative regulations in accordance with Ky. Rev. Stat. Ann. ch. 13A to implement this Act, including forms, training standards, immutable storage specifications, grievance-security standards, validation rules, audit procedures, compliance-scorecard methodology, and corrective-action procedures;
(c) Designate by administrative regulation the independent oversight body that will administer confidential or bypass grievance review and related escalations under Section 8 of this Act;
(d) Provide or require in-person critical incident response training for personnel who supervise or respond to covered deaths;
(e) Establish minimum standards for evidence preservation, digital record retention, litigation holds, and chain of custody;
(f) Establish minimum standards for operation of the Universal Grievance Pillar created in Section 8 of this Act;
(g) Require compatibility among agency, contractor, vendor, and local-facility data structures used to comply with this Act; and
(h) Submit an annual report to the Legislative Research Commission on implementation of this Act, including aggregate metrics on family notifications, evidence preservation compliance, grievance routing and closure metrics, safety audits, corrective-action compliance, and training completion rates, without personally identifying information.
(2) Critical incident response training shall include:
(a) In-person CPR and AED certification or recertification;
(b) Instruction that preservation of life takes priority in an emergency and that no internal policy shall be interpreted to prohibit reasonable lifesaving action otherwise authorized by law;
(c) Evidence preservation in homicide and other death-related investigations;
(d) Recognition of reportable deaths and reporting obligations; and
(e) Reporting obligations relating to protected disclosures, record preservation, and retaliation.
(3) Within ninety (90) days after a covered death occurring in a correctional institution, jail, detention center, or juvenile detention facility, the responsible agency shall complete a safety and operational audit addressing, at a minimum:
(a) Classification and housing;
(b) Medical and mental health access;
(c) Emergency response times and lifesaving efforts;
(d) Supervision and rounds, when applicable;
(e) Evidence preservation; and
(f) Corrective actions and deadlines.
(4) Evidence preservation requirements shall include:
(a) Immediate preservation of all known related records, video, audio, logs, communications, and digital evidence;
(b) A requirement that digital evidence be copied to immutable storage within forty-eight (48) hours of identification when reasonably available;
(c) Maintenance of chain-of-custody logs;
(d) Issuance and tracking of litigation holds where required; and
(e) Recognition that intentional destruction, concealment, or material alteration of evidence relating to a covered death constitutes a protected disclosure concern under this Act.
SECTION 8. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) The Cabinet shall require each state correctional institution, and each local jail or detention facility housing state prisoners to the extent provided by administrative regulation, to maintain within any correctional grievance platform a Universal Grievance Pillar that permits an inmate, prisoner, or detainee to select one (1) of two (2) grievance paths at the time of submission.
(2) Path A — Regular Grievance (Institutional).
A grievance submitted without selection of the confidential or bypass option shall be processed as an institutional grievance and shall comply with the following minimum standards:
(a) The grievance shall be visible to the local grievance counselor or other designated institutional grievance official for immediate review and action;
(b) The grievance status displayed to the warden, jailer, or other facility administrator shall remain "IN PROGRESS," or an equivalent nonfinal status, unless and until dual-key sign-off occurs or an approved nonoverride exception workflow is initiated and documented under administrative regulation;
(c) Dual-key sign-off for closure shall require:
1. Authentication by the grievance counselor or designated institutional reviewer through biometric verification, secure personal identification number, or other Cabinet-approved credential on the counselor's terminal; and
2. Authentication by the inmate, prisoner, or detainee through biometric verification, secure personal identification number, or other Cabinet-approved credential on the assigned tablet, kiosk, or secure device;
(d) No system administrator, vendor employee, facility administrator, or other employee shall manually mark an institutional grievance as "Complete," "Closed," or other final disposition without both digital signatures required by paragraph (c) of this subsection; and
(e) If the inmate, prisoner, or detainee refuses to sign, is unavailable, is transferred, is released, is medically unable to authenticate, or cannot authenticate because of a documented technology failure, the grievance shall remain unresolved unless administrative regulation establishes a documented nonoverride exception workflow that preserves the unresolved or exception status and the full audit trail, but no local staff member may use that condition as a substitute for the required dual-key sign-off.
(3) Path B — Confidential or Bypass Grievance (Independent Review).
A grievance submitted with the confidential or bypass option selected shall comply with the following minimum standards:
(a) The grievance content, attachments, filer identity, and routing details shall be encrypted in transit and at rest;
(b) The grievance shall be shielded from all staff assigned to the current facility and routed directly to the independent oversight body;
(c) The local institutional dashboard shall display only that a "Shielded Review Active" status exists and shall not reveal the content of the grievance or the identity of the filer except as authorized by law or administrative regulation for emergency safety purposes;
(d) No local grievance counselor, warden, jailer, facility administrator, system administrator, or vendor employee shall access, edit, delete, or close a confidential or bypass grievance except as expressly authorized by law or administrative regulation;
(e) A confidential or bypass grievance may be marked "Complete," "Closed," or other final disposition only upon dual-key sign-off by:
3. The assigned independent reviewer through biometric verification, secure personal identification number, or other Cabinet-approved credential on a secure external portal; and
4. The inmate, prisoner, or detainee through biometric verification, secure personal identification number, or other Cabinet-approved credential on the assigned tablet, kiosk, or secure device; and
(f) Any emergency disclosure to local staff shall be limited to the minimum information necessary to address an imminent risk of serious harm and shall be documented in the audit log, including the time, basis, approving authority, and information disclosed.
(4) No manual override.
No person, including a system administrator, facility administrator, contractor, vendor, or other employee, shall possess authority to override the digital closure requirements established in subsection (2)(c) or subsection (3)(e) of this section for the purpose of entering a final grievance disposition.
(5) Immediate escalation.
Any override attempt, unauthorized access attempt, deletion attempt, routing failure, or other security event affecting a grievance record shall be preserved in the audit log and escalated immediately to the independent oversight body.
(6) Immutable recordkeeping.
All grievances submitted through the Universal Grievance Pillar, including intake selections, routing events, visibility restrictions, entries, attachments, timestamps, status changes, disclosures, authentication events, signature logs, access logs, attempted access logs, exception records, retaliation-review records, and closure records, shall be stored in a WORM digital vault for not less than ten (10) years.
(7) Auditability and authenticity.
The system shall maintain audit controls sufficient to identify each access, attempted access, view, signature event, routing action, edit, disclosure, and failed closure attempt associated with a grievance record.
(8) Retaliation monitoring.
The Cabinet shall establish automated or equivalent monitoring for patterns suggesting retaliation relating to grievance submissions, including repeated housing changes, disciplinary actions, loss of privileges, transfer patterns, or staff access anomalies occurring after filing of a grievance, and shall establish escalation criteria by administrative regulation.
(9) Forms and implementation.
The Cabinet shall promulgate administrative regulations in accordance with Ky. Rev. Stat. Ann. ch. 13A to implement this section, designate the independent oversight body, establish technical and security specifications, create standardized forms, define documented exception handling, require local access restriction for bypass grievances, and amend or supersede any conflicting policy, procedure, or vendor contract governing inmate tablet communications, grievance review, confidentiality, or record retention.
(10) Minimum standards.
This section establishes minimum standards and shall not be construed to limit any greater confidentiality, retention, auditability, or inmate grievance protection otherwise required by law.
SECTION 9. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) The General Assembly finds and declares that the purposes of this Act are to:
(a) Support families affected by covered deaths with timely and plain-language information;
(b) Improve accountability and lifesaving response in custodial settings;
(c) Preserve evidence and deter tampering;
(d) Protect good-faith reporting; and
(e) Establish secure grievance procedures that permit both institutional resolution and confidential bypass review.
(2) Nothing in this Act shall be construed to:
(a) Expand, waive, or diminish any exemption under the Kentucky Open Records Act, Ky. Rev. Stat. Ann. §§ 61.870-.884;
(b) Require disclosure of grand jury material, investigative strategy, informant information, or privileged material; or
(c) Limit any lawful authority of a prosecutor, coroner, medical examiner, or law enforcement agency.
SECTION 10. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) Nothing in this Act shall be construed to alter the scope of the Kentucky Open Records Act or to require the disclosure of records exempt from inspection under law, including Ky. Rev. Stat. Ann. § 61.878.
(2) Agencies shall protect personally identifying information relating to witnesses, informants, medical information, and other protected information to the extent required by law.
(3) Nothing in this Act shall be construed to require an agency to create a record that is not otherwise required by law, except to the extent this Act expressly requires notice documentation, chain-of-custody logs, audit records, grievance-signature records, litigation-hold documentation, corrective-action records, or administrative forms promulgated under this Act.
(4) The provisions of this Act shall be coordinated with all otherwise applicable laws governing coroners, medical examiners, prosecutors, correctional operations, juvenile justice facilities, and jail standards.
SECTION 11. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
(1) The standards established by this Act are minimum standards, and an agency may adopt policies or procedures that provide greater protection, greater transparency, greater retention, more timely notification, or stronger confidentiality so long as those policies or procedures are not inconsistent with this Act or other applicable law.
(2) A willful failure by an agency employee to comply with a mandatory duty established under Sections 4, 5, 7, or 8 of this Act may constitute grounds for discipline in accordance with applicable law and personnel policy.
(3) A next of kin aggrieved by a willful failure to provide notice required under Section 4 or 5 of this Act may seek prospective injunctive relief to compel future compliance, but no damages remedy is created by this subsection.
(4) The Cabinet may issue deficiency notices, require corrective action plans, and require follow-up documentation for repeated or material noncompliance with mandatory duties established by this Act or by administrative regulation promulgated under this Act.
(5) Nothing in this section shall impair a cause of action otherwise authorized by Section 6 of this Act.
SECTION 12. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
If any provision of this Act or its application to any person or circumstance is held invalid, the invalidity shall not affect other provisions or applications of this Act that can be given effect without the invalid provision or application, and to this end the provisions of this Act are severable.
SECTION 13. A NEW SECTION OF Ky. Rev. Stat. Ann. ch. 61 IS CREATED TO READ AS FOLLOWS:
This Act takes effect January 1, 2027, and shall apply prospectively. The Cabinet shall begin promulgation of administrative regulations, designation of the independent oversight body, preparation of forms, and implementation planning before the effective date as necessary to ensure timely implementation.
TAB 2 — SECTION-BY-SECTION SUMMARY
Sections 1-2: Title and Definitions
Establishes the short title, "Tony's Law."
Defines the key terms needed for family notifications, evidence preservation, whistleblower protections, covered-death reporting, and the Universal Grievance Pillar.
Adds or clarifies:
● confidential or bypass grievance;
● correctional grievance platform;
● independent oversight body, also usable as the "Office" in implementation materials;
● preliminary notice;
● Shielded Review Active;
● dual-key sign-off; and
● WORM digital vault.
Sections 3-5: Family Notifications
Allows discretionary family briefings that do not waive privilege.
Requires reasonable efforts to provide preliminary next-of-kin notice within 24 hours of death or discovery, subject to limited documented exceptions.
Requires next-of-kin written notice within 3 business days of case closure.
Requires next-of-kin written notice within 2 business days of autopsy findings or transmittal to the prosecutor, whichever occurs later.
Limits disclosures to nonprivileged, plain-language facts and requires delivery documentation or reasonable-attempt documentation.
Section 6: Whistleblower Protections
Bars retaliation for good-faith protected disclosures.
Voids conflicting NDAs or policies to the extent they chill protected disclosures.
Creates a civil remedy with injunctive relief, reinstatement or front pay, back pay, fees, and a $10,000 civil penalty.
Includes a 180-day rebuttable presumption and a limited sovereign-immunity waiver.
Section 7: Implementation and Safety Oversight
Directs the Cabinet to designate the state DCRA system and the independent oversight body.
Requires regulations, forms, immutable storage standards, validation rules, audit procedures, compliance-scorecard methods, and corrective-action procedures.
Requires in-person critical incident training.
Requires 90-day safety and operational audits.
Requires evidence preservation, litigation holds where applicable, and 48-hour WORM copying when reasonably available.
Section 8: Universal Grievance Pillar
Creates two grievance paths:
● Path A: Regular institutional grievance.
● Path B: Confidential or bypass grievance to the independent oversight body.
Requires dual-key sign-off for grievance closure, subject only to a documented nonoverride exception workflow.
Prohibits manual overrides.
Requires immediate escalation of override attempts and unauthorized access events.
Requires 10-year WORM retention.
Requires retaliation monitoring and technical-security standards.
Sections 9-10: Construction and Privacy
Preserves Kentucky Open Records Act exemptions.
Preserves privilege, grand jury secrecy, investigative confidentiality, and protected personal information.
Prevents the Act from being read to require disclosure of exempt information.
Section 11: Minimum Standards and Enforcement
Establishes minimum standards.
Allows agencies to exceed the minimum.
Provides for discipline for willful noncompliance with mandatory duties.
Allows limited injunctive relief for family-notice failures.
Authorizes Cabinet deficiency notices and corrective-action demands for material or repeated noncompliance.
Sections 12-13: Severability and Effective Date
Contains a severability clause.
Makes the Act effective January 1, 2027, prospectively only, while allowing pre-effective-date implementation work.
TAB 3 — LRC BILL SUMMARY
This bill creates a statutory framework for family notifications, custodial evidence preservation, whistleblower protections, critical incident training, deaths-in-custody reporting, and an updated grievance-routing system for correctional tablet and kiosk interfaces.
The bill:
● authorizes discretionary family briefings;
● requires reasonable efforts to provide preliminary notice to next of kin within 24 hours of death or discovery, subject to limited documented exceptions;
● requires timely written notice to next of kin after case closure and after autopsy findings or prosecutorial transmittal;
● prohibits retaliation against protected disclosures;
● directs the Cabinet to promulgate implementing regulations and designate an independent oversight body;
● requires in-person CPR/AED and critical incident response training;
● requires 90-day safety and operational audits after covered deaths;
● requires evidence preservation, litigation-hold tracking, and immutable storage transfers where required;
● creates a Universal Grievance Pillar with regular and confidential/bypass grievance paths;
● requires dual-key sign-off for grievance closure and prohibits manual overrides;
● requires immutable WORM retention of grievance records for ten years;
● and preserves existing privilege and Open Records protections.
The bill does not expand the Kentucky Open Records Act or require disclosure of exempt investigative records.
TAB 4 — FACT SHEET
WHAT THE BILL DOES
● Requires reasonable efforts to provide preliminary family notification within 24 hours of death or discovery.
● Requires family notification after case closure within 3 business days.
● Requires family notification after autopsy findings or prosecutorial transmittal within 2 business days.
● Allows family briefings that do not waive privilege.
● Protects whistleblowers from retaliation.
● Requires CPR/AED and critical incident response training.
● Requires 90-day safety and operational audits after covered deaths.
● Requires evidence preservation, chain-of-custody documentation, litigation-hold tracking, and 48-hour WORM copying when reasonably available.
● Creates a Universal Grievance Pillar for correctional tablet and kiosk systems.
● Adds a confidential or bypass grievance path to an independent oversight body.
● Requires dual-key sign-off for grievance closure.
● Requires immediate escalation of override or unauthorized access events.
● Requires ten-year WORM retention of grievance records and audit logs.
● Requires automated or equivalent retaliation monitoring.
● Requires corrective-action plans and compliance scoring.
WHY IT MATTERS
● Helps families receive timely, plain-language updates.
● Improves early communication without waiving privilege.
● Reduces the risk that grievances are buried inside the local chain of command.
● Preserves a verifiable audit trail.
● Protects staff, contractors, inmates, prisoners, and detainees from retaliation.
● Improves transparency while preserving lawful confidentiality.
● Gives the Cabinet a uniform statewide implementation framework.
KEY IMPLEMENTATION FEATURES
Feature Requirement
Preliminary family notice Reasonable efforts within 24 hours
Case-closure notice Within 3 business days
Autopsy/prosecutor notice Within 2 business days
Institutional grievance path Local review and dual-key closure
Confidential/bypass path Routed to independent oversight body
Closure control No manual override
Security incident handling Immediate escalation to Office
Record storage WORM retention for 10 years
Retaliation monitoring Automated or equivalent pattern detection
Corrective action Required for material deficiencies
TAB 5 — FISCAL NOTE
TONY'S LAW
Revised Advocacy Fiscal Estimate
This is an advocacy fiscal estimate only.
ESTIMATED COST CATEGORIES
Component Estimated Startup Estimated Annual
DCRA system updates and integration $150,000 $60,000
Grievance-platform routing, shielding, and audit controls $125,000 $45,000
Training curriculum and delivery $125,000 $55,000
WORM storage, retention, and litigation-hold tracking $110,000 $40,000
Forms, audits, scorecards, and corrective-action administration $75,000 $25,000
Total $585,000 $225,000
NOTES
● Uses existing Cabinet and facility infrastructure where possible.
● Costs may vary depending on the number of local facilities, existing vendor contracts, and current audit-log capability.
● The grievance pillar and 10-year retention requirement add system-routing, shielding, escalation, and long-term storage costs.
● A final official fiscal note should be requested from state fiscal staff before introduction.
TAB 6 — IMPLEMENTING REGULATION
501 KAR [XX]:[XXX]
IMPLEMENTING REGULATION FOR TONY'S LAW
Section 1. Purpose and Scope.
This administrative regulation establishes minimum standards for implementation of Tony's Law, including family notifications, evidence preservation, covered-death reporting, critical incident training, the Universal Grievance Pillar, grievance routing, WORM retention, corrective-action procedures, compliance scoring, and reporting.
Section 2. Definitions.
(1) Terms used in this administrative regulation have the meanings assigned in Tony's Law.
(2) "Office" means the independent oversight body designated by the Cabinet under Tony's Law.
Section 3. Standardized Notifications.
(1) Case-closure notices required by Section 4 of Tony's Law shall be issued on Form TL-1.
(2) Autopsy-findings notices required by Section 5 of Tony's Law shall be issued on Form TL-2.
(3) Delay justifications for preliminary notice, TL-1, or TL-2 shall be recorded on Form TL-3.
(4) Delivery proof shall be maintained in the agency record, or the agency shall document reasonable attempts at delivery.
(5) Preliminary notice required by Section 4 of Tony's Law may be delivered orally or in writing but shall be documented in the agency record.
Section 4. Family Briefings.
(1) Family briefings are discretionary.
(2) They are limited to nonexempt facts.
(3) No privilege waiver occurs.
(4) Agencies may require a briefing agreement on Form TL-4.
(5) No recording shall occur without agency consent unless otherwise required by law.
Section 5. Covered-Death Reporting.
(1) Agencies shall submit initial and supplemental covered-death data to the state DCRA reporting system using Form TL-10 or a Cabinet-approved machine-readable equivalent.
(2) Agencies shall update the report upon autopsy receipt, prosecutorial transmittal, material correction, and case closure as required by Tab 8.
(3) Quarterly zero reports shall be submitted when required.
Section 6. Critical Incident Response Training.
(1) Required for staff who supervise or respond to covered deaths.
(2) Includes CPR/AED certification, lifesaving response, evidence preservation, covered-death reporting, litigation-hold awareness, and protected-disclosure duties.
(3) Training rosters and certifications shall be retained.
Section 7. Safety and Operational Audits.
(1) Each covered death in a facility shall trigger a 90-day audit.
(2) Audits shall use Form TL-5.
(3) Findings shall address classification, medical access, response times, lifesaving efforts, supervision, evidence preservation, and corrective actions.
(4) Corrective action plans shall be documented on Form TL-11 when required.
Section 8. Evidence Preservation and WORM Storage.
(1) Related records, video, audio, logs, communications, metadata, and other known evidence shall be preserved.
(2) Digital evidence shall be copied to immutable WORM storage within 48 hours when reasonably available.
(3) Chain-of-custody documentation shall be maintained.
(4) Litigation holds shall be issued, tracked, and acknowledged when required.
(5) Evidence-preservation logs shall be documented on Form TL-6.
Section 9. Universal Grievance Pillar.
(1) Each correctional grievance platform shall include two grievance paths:
(a) Regular institutional grievance; and
(b) Confidential or bypass grievance routed to the Office.
(2) Institutional grievances shall remain in nonfinal status until dual-key sign-off occurs or a documented nonoverride exception workflow is applied.
(3) Confidential or bypass grievances shall be encrypted, shielded from local facility staff, and marked locally only as "Shielded Review Active" or equivalent noncontent status.
(4) Confidential or bypass grievances shall require local access restriction and Office assignment.
(5) No local staff, system administrator, or vendor employee may manually override closure requirements.
(6) Any override attempt, unauthorized access attempt, deletion attempt, or routing failure shall be logged and escalated immediately to the Office.
(7) All grievance records, signature events, routing events, access logs, retaliation-review records, exception records, and related metadata shall be preserved in a WORM digital vault for no less than 10 years.
(8) Retaliation monitoring shall be enabled for grievance-related patterns.
(9) Exception workflows shall be documented, narrowly coded, and limited to transfer, release, outage, disability, emergency, or other Office-approved circumstances defined by technical specification.
(10) The Office shall maintain secure external review access.
(11) The Cabinet shall issue technical specifications and vendor requirements.
(12) The Cabinet shall incorporate Forms TL-7 through TL-9 and any related technical appendices.
Section 10. Deficiency Notices, Corrective Action, and Compliance Scoring.
(1) Any failed required-field validation, untimely report, missing litigation-hold acknowledgment, or grievance-security event shall be logged as a compliance event.
(2) The Cabinet or Office may issue a deficiency notice to the reporting agency or facility.
(3) Material deficiencies shall require a corrective-action plan on Form TL-11.
(4) The Cabinet shall publish or internally maintain compliance scorecards based on verified data and closed audit periods only.
Section 11. Privacy and Privilege Protections.
(1) This regulation shall not expand the Kentucky Open Records Act, Ky. Rev. Stat. Ann. §§ 61.870-.884.
(2) It shall not require disclosure of privileged, exempt, or investigatory material, including materials protected by Ky. Rev. Stat. Ann. § 61.878 or Ky. R. Crim. P. 5.24.
(3) It shall not require the creation of records not otherwise required by law except as expressly stated in Tony's Law.
Section 12. Reporting.
(1) Agencies shall submit required metrics to the Cabinet on a schedule established by the Cabinet.
(2) Annual reporting to the Legislative Research Commission shall be aggregate only and shall not include personally identifying information.
Section 13. Incorporation by Reference.
The following material is incorporated by reference:
● Form TL-1, Case Closure Notification
● Form TL-2, Autopsy Findings Notification
● Form TL-3, Notification Delay Justification
● Form TL-4, Family Briefing Agreement
● Form TL-5, 90-Day Safety and Operational Audit
● Form TL-6, Evidence Chain-of-Custody / WORM Storage Log
● Form TL-7, Institutional Grievance Intake
● Form TL-8, Confidential / Bypass Grievance Intake
● Form TL-9, Grievance Closure and Audit Log
● Form TL-10, Covered-Death Initial / Supplemental Report
● Form TL-11, Corrective Action Plan and Closure Verification
● Data Dictionary v2.0
● Validation Rules v2.0
● Audit Procedures v2.0
TAB 7 — STANDARDIZED FORMS
TAB 8 — DATA DICTIONARY AND VALIDATION RULES
PURPOSE
This document establishes the minimum data fields, routing logic, timing controls, validation rules, retention rules, escalation rules, and compliance-scorecard inputs necessary to implement Tony's Law in a uniform and auditable manner across all participating agencies, facilities, contractors, and vendors.
GENERAL RULES
11. All required fields shall be captured in machine-readable form unless a narrative field is expressly permitted.
12. No platform subject to Tony's Law may suppress, overwrite, purge, or alter audit metadata required by this document.
13. All date and time fields shall use a uniform timestamp standard designated by the Cabinet.
14. Required fields that are unknown at the time of initial submission shall be marked "Unknown" and updated upon later discovery.
15. Data structures used by agencies, contractors, and vendors shall remain compatible with the statewide reporting and audit framework established by the Cabinet and the Office.
A. COVERED-DEATH REPORTING FIELDS
Field Type Description
Case_ID Text(20) Unique covered-death identifier
Reporting_Agency Text(100) Submitting agency
Lead_Agency Text(100) Lead investigating agency
Covered_Death_Category Text(50) Detained / Arrest / Incarcerated / En Route / 72-Hour Post-Release / other approved category
Decedent_Name Text(150) Full legal name, if known
Decedent_Age Integer Age at death, if known
Decedent_Race Text(50) Race category
Decedent_Ethnicity Text(50) Ethnicity category
Decedent_Gender Text(50) Gender field used by reporting agency
DateTime_Death DateTime Date and time of death
DateTime_Discovered DateTime Date and time death discovered
Facility_Location Text(100) Facility or location of death
Custody_Status Text(50) Custodial status at time of death
Circumstances_Summary Text(500) Brief narrative summary
Initial_Report_Timestamp DateTime Initial submission time
Supplemental_Report_Timestamp DateTime Supplemental submission time
Prosecutor_Referral_Timestamp DateTime Time matter referred or transmitted to prosecutor
Autopsy_Receipt_Timestamp DateTime Time autopsy findings received
Case_Closure_Timestamp DateTime Time case officially closed
Material_Error_Corrected YesNo Whether prior submission corrected
Zero_Report YesNo Quarterly no-death certification
B. FAMILY-NOTIFICATION FIELDS
Field Type Description
Next_of_Kin_Name Text(150) Name of notified person, if confirmed
Next_of_Kin_Relationship Text(50) Relationship to decedent
Preliminary_Notice_Attempted YesNo Whether preliminary notice was attempted
Preliminary_Notice_Timestamp DateTime Timestamp of preliminary notice or reasonable-attempt documentation
Preliminary_Notice_Method Text(50) In person / phone / email / mail / other
Preliminary_Notice_Delay_Documented YesNo Whether delay or exception documented
TL1_Issued YesNo Case-closure notice issued
TL1_Issue_Timestamp DateTime Timestamp of TL-1 issuance
TL2_Issued YesNo Autopsy notice issued
TL2_Issue_Timestamp DateTime Timestamp of TL-2 issuance
TL3_Delay_Used YesNo Delay justification used
Delay_Approval_Timestamp DateTime Time delay approved
Delay_Review_Timestamp DateTime Time next delay review completed
Delivery_Proof_Attached YesNo Proof of delivery attached
Reasonable_Attempts_Documented YesNo Reasonable attempts documented if delivery proof absent
Notice_Delivery_Method Text(50) In person / phone / email / mail / other
Liaison_Name Text(150) Designated liaison or representative
C. EVIDENCE PRESERVATION AND LITIGATION-HOLD FIELDS
Field Type Description
Evidence_Category Text(50) Video / audio / medical / logs / messages / metadata / other
Evidence_Source Text(150) System, camera, contractor, or source location
Preservation_Triggered YesNo Preservation triggered
Preservation_Timestamp DateTime Time preservation initiated
WORM_Transfer_Required YesNo Whether immutable transfer required
WORM_Transfer_Timestamp DateTime Time immutable transfer completed
WORM_Delay_Documented YesNo Delay documented
WORM_Delay_Reason Text(250) Reason transfer not completed within ordinary window
Chain_of_Custody_Started YesNo Chain of custody opened
Chain_of_Custody_Verified YesNo Chain verified
Litigation_Hold_Issued YesNo Hold issued
Litigation_Hold_Timestamp DateTime Hold issuance time
Hold_Recipient_List Text(500) Persons or entities notified
Hold_Acknowledged YesNo Acknowledgment received
Hold_Acknowledgment_Timestamp DateTime Time acknowledgment received
Hold_Release_Timestamp DateTime Time hold released in writing, if applicable
D. TRAINING AND POST-INCIDENT AUDIT FIELDS
Field Type Description
Facility_Audit_Required YesNo Whether 90-day audit required
Facility_Audit_Completion_Timestamp DateTime Timestamp of audit completion
CPR_AED_Training_Current YesNo Current CPR/AED certification verified
Critical_Incident_Training_Current YesNo Current critical incident training verified
Staff_Roster_Verified YesNo Staff roster confirmed accurate
Corrective_Action_Required YesNo Whether corrective-action plan required
Corrective_Action_Submitted YesNo Whether TL-11 submitted
Corrective_Action_Due_Date Date Due date for TL-11
Corrective_Action_Closed YesNo Whether corrective action completed
E. GRIEVANCE ROUTING FIELDS
Field Type Description
Grievance_ID Text(20) Unique grievance identifier
Facility_Name Text(150) Facility of origin
Grievance_Path Text(30) Institutional / Confidential / Bypass
Confidential_Bypass_Selected YesNo Whether bypass path was selected
Office_Route YesNo Routed to Office
Shielded_Review_Status Text(50) Shielded Review Active / Other
Office_Reviewer_Assigned YesNo Office reviewer assigned
Local_Access_Restricted YesNo Local staff blocked from content
Emergency_Disclosure_Made YesNo Emergency disclosure occurred
Emergency_Disclosure_Timestamp DateTime Time of emergency disclosure
Emergency_Disclosure_Basis Text(250) Imminent-harm basis
F. GRIEVANCE CLOSURE, EXCEPTIONS, AND RETENTION FIELDS
Field Type Description
Dual_Key_Required YesNo Whether dual sign-off is required
Reviewer_Signature_Timestamp DateTime Reviewer signature time
Filer_Signature_Timestamp DateTime Filer signature time
Dual_Key_Completed YesNo Whether both signatures were collected
Closure_Timestamp DateTime Final disposition timestamp
Closure_Disposition Text(50) Granted / denied / referred / other
Exception_Workflow_Used YesNo Whether exception workflow used
Exception_Workflow_Code Text(30) Transfer / Release / Outage / Disability / Emergency / Other
Exception_Approved_By Text(150) Approving authority
Override_Attempt YesNo Attempted unauthorized override
Override_Attempt_Timestamp DateTime Time of attempted override
Override_Escalated_To_Office YesNo Escalated to Office
Retaliation_Flag YesNo Monitoring flag
Retaliation_Review_Timestamp DateTime Time designated reviewer assessed retaliation flag
WORM_Retention_Years Integer Must be at least 10
WORM_Stored_Until Date Minimum retention date
G. COMPLIANCE SCORECARD FIELDS
Field Type Description
Reporting_Compliance_Score Decimal Facility or agency score
Notice_Compliance_Score Decimal Family-notification score
Preservation_Compliance_Score Decimal Preservation and hold score
Grievance_Compliance_Score Decimal Grievance-system score
Training_Compliance_Score Decimal Training completion score
Audit_Compliance_Score Decimal Audit completion score
Corrective_Action_Status Text(50) Open / overdue / cured
Overall_Compliance_Status Text(50) Compliant / needs improvement / noncompliant
VALIDATION RULES
Rule Condition Requirement
CD1 Any covered death Initial_Report_Timestamp within 24 hours of death or discovery
CD2 Any covered death Supplemental_Report_Timestamp within 7 days
CD3 Autopsy findings received Updated report within 2 business days
CD4 Prosecutor referral or transmittal Updated report within 2 business days
CD5 Case closure Updated report within 2 business days
CD6 Quarterly reporting cycle closes and no covered death reported Zero_Report = Yes
FN1 Covered death confirmed Preliminary_Notice_Attempted = Yes within 24 hours unless Preliminary_Notice_Delay_Documented = Yes
FN2 TL1_Issued = Yes TL1_Issue_Timestamp within 3 business days of case closure unless valid TL-3 delay documented
FN3 TL2_Issued = Yes TL2_Issue_Timestamp within 2 business days of autopsy receipt or prosecutorial transmittal, whichever occurs later, unless valid TL-3 delay documented
FN4 TL3_Delay_Used = Yes Delay_Approval_Timestamp required and supervisory approval required
FN5 Any required notice Delivery_Proof_Attached = Yes or Reasonable_Attempts_Documented = Yes
EV1 Preservation_Triggered = Yes Preservation_Timestamp required
EV2 WORM_Transfer_Required = Yes WORM_Transfer_Timestamp within 48 hours unless WORM_Delay_Documented = Yes
EV3 WORM_Delay_Documented = Yes WORM_Delay_Reason required
EV4 Litigation_Hold_Issued = Yes Litigation_Hold_Timestamp required
EV5 Litigation_Hold_Issued = Yes Hold_Acknowledged = Yes within 24 hours unless documented good-cause exception
EV6 Chain_of_Custody_Started = Yes Chain_of_Custody_Verified must be completed before audit closure
TR1 Facility_Audit_Required = Yes Facility_Audit_Completion_Timestamp within 90 days
TR2 Covered-death event CPR_AED_Training_Current and Critical_Incident_Training_Current must be verifiable for affected personnel
TR3 Corrective_Action_Required = Yes Corrective_Action_Submitted = Yes by due date
GR1 Confidential_Bypass_Selected = Yes Office_Route = Yes
GR2 Confidential_Bypass_Selected = Yes Local_Access_Restricted = Yes
GR3 Grievance_Path = Institutional Dual_Key_Required = Yes
GR4 Grievance_Path = Confidential / Bypass Shielded_Review_Status = Shielded Review Active
GR5 Final closure requested Dual_Key_Completed = Yes or approved exception workflow documented
GR6 Override_Attempt = Yes Override_Escalated_To_Office = Yes automatically
GR7 Retaliation_Flag = Yes Retaliation_Review_Timestamp required
GR8 Any grievance record WORM_Retention_Years >= 10
GR9 Emergency_Disclosure_Made = Yes Emergency_Disclosure_Basis required
CS1 Compliance scorecard published All component scores must be based on verified data fields and closed audit review period
ESCALATION RULES
16. Any failed required-field validation for a covered-death report shall generate a deficiency notice to the reporting agency.
17. Any untimely submission shall be logged as a compliance event for audit scoring.
18. Any override attempt, unauthorized access attempt, deletion attempt, or routing failure affecting a grievance shall be escalated immediately to the Office.
19. Any missing litigation-hold acknowledgment after 24 hours shall trigger follow-up notice to the agency head, records custodian, and designated compliance official.
20. Any overdue corrective-action submission shall generate follow-up notice and may be treated as a continuing deficiency.
21. Repeated validation failures may be treated as a significant or critical audit finding under Tab 9.
RETENTION RULES
22. Covered-death reporting records shall be retained for the period established by the Cabinet and no less than the longest applicable period required by law, audit, investigation, or litigation hold.
23. Grievance records governed by Tony's Law shall be retained in WORM storage for not less than ten (10) years.
24. Records subject to a litigation hold shall not be deleted, purged, overwritten, or disposed of until written release of the hold.
25. Audit work papers, corrective-action records, and compliance-scorecard source materials shall be retained for not less than ten (10) years unless a longer period is required by law or litigation hold.
IMPLEMENTATION NOTE
All forms, platforms, vendor configurations, data exports, dashboards, audit logs, scorecards, and corrective-action workflows shall conform to this Tab 8 document as incorporated by reference in the implementing regulation.
TAB 9 — AUDIT PROCEDURES
PURPOSE
Verify compliance with:
● covered-death reporting;
● family notifications;
● evidence preservation;
● litigation holds;
● training;
● safety audits;
● corrective action; and
● Universal Grievance Pillar operation.
AUDIT TOPICS
1. COVERED-DEATH REPORTING COMPLIANCE
Confirm timely initial and supplemental reporting.
Confirm autopsy, prosecutor, correction, closure, and zero-report updates.
Confirm data accuracy and material-correction handling.
2. NOTIFICATION COMPLIANCE
Confirm preliminary notice timing or documented exception.
Confirm TL-1 and TL-2 timing.
Confirm proof of delivery or reasonable-attempt documentation.
Confirm delay documentation where applicable.
3. TRAINING COMPLIANCE
Confirm CPR/AED and critical incident training.
Confirm staff roster accuracy.
4. EVIDENCE PRESERVATION
Confirm 48-hour WORM transfer where required.
Confirm chain-of-custody logs.
Confirm litigation-hold issuance and acknowledgment.
Confirm retention schedule.
5. GRIEVANCE PILLAR COMPLIANCE
Confirm both grievance paths are operational.
Confirm confidential/bypass routing works.
Confirm local access restriction is active for bypass grievances.
Confirm dual-key sign-off is required and cannot be overridden.
Confirm TL-7 through TL-9 are in use.
Confirm WORM retention for grievance records.
Confirm retaliation monitoring is enabled.
6. EXCEPTION HANDLING
Confirm any emergency disclosure is documented.
Confirm any unresolved grievance remains unresolved until proper sign-off or authorized workflow.
Confirm override attempts are logged and escalated.
Confirm exception workflows are coded, approved, and not used as informal overrides.
7. CORRECTIVE ACTION
Confirm written corrective-action plans are completed when required.
Confirm follow-up review occurs until cured.
Confirm overdue corrective actions are elevated in scoring.
8. FINDINGS CLASSIFICATION
● Critical
● Significant
● Minor
9. CONFIDENTIALITY
Audit work papers remain subject to applicable exemptions and privacy protections, including Ky. Rev. Stat. Ann. § 61.878 where applicable.
TAB 10 — MODEL STATEWIDE MEMORANDUM OF UNDERSTANDING
MODEL STATEWIDE MEMORANDUM OF UNDERSTANDING
PARTIES
Justice and Public Safety Cabinet
Department of Corrections
Department of Juvenile Justice
Kentucky State Police
Local Jails and Detention Centers
Coroners / Medical Examiners
Prosecutorial Offices
Other Participating Agencies
PURPOSE
To coordinate implementation of Tony's Law, including:
● covered-death reporting;
● family notifications;
● training;
● evidence preservation;
● litigation-hold compliance;
● safety audits;
● corrective action; and
● the Universal Grievance Pillar.
KEY PROVISIONS
1. DCRA REPORTING
Agencies shall coordinate data submission to the state system and use Form TL-10 or a Cabinet-approved machine-readable equivalent.
2. FAMILY NOTIFICATIONS
Agencies shall document preliminary notice efforts and shall use TL-1, TL-2, and TL-3 as applicable.
3. TRAINING
Agencies shall provide required critical incident response training and maintain training rosters.
4. EVIDENCE PRESERVATION
Agencies shall preserve records, issue and track litigation holds where required, maintain chain-of-custody documentation, and use WORM storage as required.
5. UNIVERSAL GRIEVANCE PILLAR
Agencies operating correctional tablet or kiosk grievance systems shall:
● provide the two-path grievance option;
● maintain confidential/bypass routing;
● route bypass grievances to the Office;
● restrict local access to bypass grievance content;
● prevent manual override of closure;
● preserve audit logs;
● escalate override attempts and unauthorized access events immediately; and
● retain grievance records for ten years in WORM storage.
6. FORMS
Agencies shall use TL-7, TL-8, and TL-9 for grievance intake and closure documentation, TL-11 for corrective actions, and all other Tony's Law forms as applicable.
7. DATA COMPATIBILITY
Participating agencies, vendors, and contractors shall maintain data compatibility with Cabinet technical specifications and Tab 8 validation rules.
8. DISPUTE RESOLUTION
Implementation issues shall be escalated through designated agency points of contact and, where necessary, to the Cabinet or Office.
9. TERM
This MOU remains in effect unless superseded, amended, or withdrawn in writing.
END OF REVISED PACKAGE

Ashley ElginPetition StarterI am the wife of Robert 'Tony' Broyles 9 days away from coming home he was murdered in prison He should have been safe not locked in a cage with a predator.

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