The Kentucky Supreme Court affirmed a circuit court ruling that allows the City of Paducah to maintain residency requirements for firefighters, rejecting a class action challenge brought by Nathan Torian and the International Association of Fire Fighters Local 168.
The case, decided December 18, 2025, centered on whether Kentucky statute KRS 311A.027(1) prohibited Paducah from enforcing its residency ordinance for firefighters. The statute states that no public agency or publicly funded emergency medical service first response provider shall have a residence requirement for employees or volunteers.
Torian, a Paducah firefighter representing a class of similarly situated firefighters, argued that he and his colleagues qualified as "emergency medical service first response providers" under the statute, which would exempt them from residency requirements. The firefighters sought a declaration of rights and an injunction to prevent enforcement of Paducah's Ordinance § 2-304.
Paducah's ordinance requires all fire department members hired after October 1, 1998, to reside within McCracken County or within 45 minutes of Station 4 as measured by a recognized mapping program as a condition of continued employment. This residency requirement has been a point of contention between the city and the firefighters' union.
The case originated in McCracken Circuit Court, where the trial court granted summary judgment in favor of Paducah, finding that KRS 311A.027(1) did not apply to the firefighters' claims. The firefighters appealed to the Kentucky Court of Appeals, which affirmed the circuit court's decision in case number 2022-CA-1071.
Undeterred, Torian and Local 168 sought discretionary review from the Kentucky Supreme Court, arguing that the lower courts misinterpreted the scope of the emergency medical services statute. The case was assigned docket number 2023-SC-0395-DG and heard by the state's highest court.
In its opinion written by Justice Conley, the Kentucky Supreme Court affirmed the lower courts' rulings, though the high court noted it reached its conclusion "upon different grounds" than the Court of Appeals. The opinion did not elaborate on these alternative grounds in the available excerpts.
The defendants in the case included the City of Paducah and several city officials in their official capacities: City Commissioners Carol C. Gault, David Guess, Raynarldo Henderson, and Sandra Wilson, who also serves as mayor pro tem. Also named were Mayor George P. Bray, the Paducah City Commission as an entity, and Fire Chief Steve Kyle.
The dispute reflects broader tensions between municipal governments and public safety unions over residency requirements. Cities often argue that requiring firefighters and police officers to live within municipal boundaries or nearby areas ensures faster response times during emergencies and creates stronger community ties. Public safety unions frequently contend that such requirements limit employment opportunities and housing choices for their members.
Kentucky's emergency medical services statute was designed to address workforce shortages in emergency medical response by removing barriers to employment, including residency restrictions. However, the statute's application to firefighters who also provide emergency medical services has created interpretive challenges for courts.
The case highlights the complex relationship between state and local authority over public safety employment. While state statutes can preempt local ordinances when there is a clear conflict, courts must carefully analyze the scope and intent of state laws to determine whether such preemption applies.
For the City of Paducah, the Supreme Court's affirmation preserves its ability to maintain local control over firefighter employment conditions. The city likely argued that its residency requirement serves legitimate public safety interests and that firefighters do not fall squarely within the emergency medical services statute's coverage.
The firefighters' union, however, faced a setback in its efforts to challenge what it viewed as an outdated employment restriction. Local 168 had argued that modern firefighters increasingly serve dual roles as both fire suppression personnel and emergency medical first responders, bringing them within the state statute's protection.
The decision affects not only Paducah firefighters but potentially other Kentucky municipalities with similar residency requirements for public safety personnel. The ruling provides clarity for local governments seeking to maintain residency ordinances while establishing precedent for how courts should interpret the scope of Kentucky's emergency medical services employment protections.
Moving forward, the decision stands as final unless the firefighters seek further review, though options for additional appeal appear limited given the state supreme court's ruling. The case demonstrates the ongoing legal challenges faced by public safety unions as they navigate the intersection of state employment protections and local government authority over municipal workforce requirements.