In Commonwealth of Kentucky v. Vester, 956 S.W.2d 204 (Ky. 1997), the Kentucky Supreme Court held that actions of an escaped inmate were not foreseeable by the government defendant.
In Vester, the victims lived fifty miles from the prison and their deaths occurred six days after the escape.
Based on the time and distance involved between the escape and the harm, the Kentucky Supreme Court held that the respondent's complaint should properly be dismissed. Id. at 206.