Filing Alleges UVU Knew of Rooftop Security Risk Before Charlie Kirk’s Assassination

The family of Charlie Kirk has submitted a notice of claim, the formal step that can precede a lawsuit, against Utah Valley University, the state of Utah and several people connected to campus administration and security planning. The filing alleges that lapses by those parties contributed to the wrongful death of the Turning Point USA founder.

“The risk of a rooftop shooter should have been especially top-of-mind given the attempted assassination of President Trump, Charlie Kirk’s close friend and political ally, by a rooftop shooter the previous year,” the filing states. The Sept. 9 document was signed by attorneys Loren Washburn, Brett Parkinson and Clifford Parkinson, who represent the Kirk family.

Among the claims outlined in the notice is an alleged conversation between Turning Point USA staff and UVU Police Chief Jeffrey Long. According to the filing, organizers said students had told them that the roof of the Sorenson Center was accessible. The building was described as “pretty close” to Kirk’s scheduled speaking location and sits directly west of the Losee Center, the building from which authorities say the fatal shot was fired.

“If this is true, it would be nice to either have it controlled access or allow one of my guys to be there as well,” a TPUSA representative allegedly wrote to the police chief, according to the claim. “If possible.”

Long allegedly responded: “I got you covered.”

Kirk, 31 and the father of two children, was killed in a campus courtyard on Sept. 10, 2025. Authorities have said a lone shooter positioned himself on the rooftop of the Losee Center, across the open area from the event. Tyler Robinson, 23, the man accused in the shooting, entered a not-guilty plea through his attorneys during an arraignment held nearly a year later.

“His murder was entirely preventable and, in fact, would not have happened had the State of Utah and UVU followed through on their stated security promises, which included protecting the rooftops surrounding the quad where Charlie was speaking,” said Brett Parkinson, an attorney for the Kirk family. “Those failures not only robbed Charlie Kirk of his life, but also robbed his family of their husband, father, son, and brother, with impacts that will compound for the rest of their lives.”

The prospective plaintiffs in the filing are Kirk’s widow, Erika Kirk, and their two juvenile children. It also acknowledges potential claims from his parents, Robert and Kathryn. The filing does not specify monetary damages. In addition to the wrongful death claim, it also raises a claim of “state-created danger” under the U.S. Constitution.

Kirk, who built TPUSA into the country’s largest conservative campus and youth-oriented activist organization in the country, also spoke at the Republican National Conventions in 2016, 2020 and 2024. He had become a personal friend of the president’s as well as other prominent figures, including leading Utah politicians, the notice continues.

As a result, he had detractors, faced death threats, and publicly spoke about that before his assassination.

“You should not have to walk around with security for your entire family and for myself just because you support a politician or political candidate or certain values,” he said at an event in May 2025.

“We get death threats,” he continued. “People want to murder us.”

Political violence was on the rise as Kirk geared up for TPUSA’s 2025 campus speaking events, titled, “The American Comeback Tour.” The filing references the numerous attempts on Trump’s life, the home invasion hammer attack on California Rep. Nancy Pelosi’s husband, Paul, and the murders of former Minnesota House Speaker Melissa Hortman and her husband, Mark.

“Tragically, the UVU Parties failed to rise to the occasion,” the filing alleges. “Through a series of stunning failures and reckless decisions, the UVU Parties created a foreseeable danger to Charlie.”

The allegations include a failure to perform a meaningful risk assessment or understand the significance of Kirk’s visit to the UVU campus. Campus police allegedly did not have a written security plan or hold a security briefing in advance.

The second was “walking [Kirk] into a fishbowl” — surrounded on all sides by tall buildings or other elevated positions. “The UVU Parties could have declined to approve the Tour event in the outdoor quad location, or could have moved the venue indoors or to a more secure location, as it had done for controversial speakers in the past,” according to the filing. The school also failed to dedicate additional resources for the outdoor venue despite the allegedly greater risk.

There were only six campus police officers assigned to the event, while Kirk’s appearance attracted roughly 3,000 spectators, according to the filing.

“On information and belief, [UVU Campus Police] Chief Jeffrey Long requested approval from then-UVU President, Astrid Tuminez, to allocate more than the six officers — which represented only 25% of the UVU police force — but his request was denied,” the filing continues.

After the denial, campus police did not seek additional resources from neighboring departments, such as the Orem or Provo police departments, according to the filing.

“The UVU Parties’ planning was so deficient that when Mr. Kirk was shot first responders were not available and Mr. Kirk was transported to Timpanogos Regional Hospital in a private vehicle, not an ambulance,” the notice continues.

The school and its leaders also had “exclusive power” that TPUSA and Kirk’s security team did not have, such as authority to create a security perimeter, use physical barriers, deploy metal detectors or use other “common sense safety measures like those utilized at sporting events on campus.”

Although the campus had a security camera system, footage was not monitored in real time, according to the filing — and there were no drones to monitor rooftops or any other part of the “sprawling outdoor event.”

“After-the-fact review of the footage at the Preliminary Hearing in the criminal prosecution of the alleged shooter Tyler Robinson showed the shooter running across the roof of the Losee Building to a ‘sniper’s nest,'” attorneys for the Kirk family wrote. “If such footage had been monitored in real-time, Kirk’s tragic death could have been avoided.”

Despite warnings to the police chief about rooftop access in the area, the Losee Center rooftop was not secured. This, according to the filing, happened despite the fact that students were known to frequent the rooftop and people often found discarded “beer bottles and other trash” or paraphernalia there.

Together, all of the alleged failures placed Kirk’s life in danger, according to the filing.

“He was legally entitled to believe that when the UVU Parties approved the Tour event to be held on campus on September 10, that the UVU Parties would only hold the event in a venue and with associated security measures that made the event safe for him to attend and participate in,” the notice reads. “Instead, Mr. Kirk was exposed to the danger of a rooftop shooter that took his life.”