Charlie Kirk’s family has filed a notice of claim against Utah officials blaming widespread security failures for last year’s assassination of the conservative icon, indicating a wrongful death suit could be coming.

The notice, filed Sept. 9 with Utah’s Office of the Attorney General, cites “a series of stunning failures and reckless decisions” that aligned to create a “foreseeable danger” to Kirk, 31, as he spoke to a crowd of thousands at Utah Valley University.

Kirk was debating students from a tent in a campus courtyard when a shooter perched on a rooftop nearby fired a single shot, striking him in the throat.

The claim alleges the state, university officials, campus police and others’ failures “ultimately rendered Mr. Kirk helpless to the rooftop shooter in an assassination that could have been avoided had the UVU Parties only taken reasonable steps to plan and oversee a safe event, steps outlined below that have been standard practice for other universities hosting controversial speakers,” the claim reads in part.