Kansas Supreme Court: Recreation Immunity Covers Libraries and Their Parking Lots

In my work defending Kansas cities, counties, schools, and universities when accidents happen in parks, gyms, libraries, and similar spots, this new decision grabbed my attention.

Kansas Supreme Court: recreation immunity covers libraries and their parking lots

A visitor fell in a Johnson County library parking lot and sued.
The Court held the county is protected by the Kansas Tort Claims Act’s recreational-use rule, which applies to places meant for leisure activities, indoors or outdoors.

Plain-language takeaways

• Recreation is broader than parks or trails. A library qualifies because people visit to read, study, and attend programs.

• The shield reaches connected areas like sidewalks and parking lots if they serve the recreational space.

• To succeed, an injured visitor must prove the government acted in a grossly or wantonly unsafe way. Ordinary carelessness is not enough.

Bottom line: when you enjoy public spaces designed for recreation, the government is immune from a typical slip-and-fall claim unless its conduct was truly reckless.

Zaragoza v. Board of Johnson County Commissioners, No. 126,732 (Kan. June 27, 2025)