Case: Beaver v. Kingman

Docket No. Not Available | Kansas state trial court

Filed Date: 1974

Closed Date: April 1, 1989

Clearinghouse coding complete

Case Summary

In 1974, two incarcerated individuals at the Shawnee County Jail in Kansas filed separate habeas corpus lawsuits under 42 U.S.C. § 1983 challenging the conditions of their confinement. They were both represented by the Legal Aid Society of Topeka. The outcome of their actions is unclear. However, both individuals subsequently filed a new petition, together, in Shawnee District Court, seeking declaratory and injunctive relief against the County commissioners, in which they purported to represent…

In 1974, two incarcerated individuals at the Shawnee County Jail in Kansas filed separate habeas corpus lawsuits under 42 U.S.C. § 1983 challenging the conditions of their confinement. They were both represented by the Legal Aid Society of Topeka. The outcome of their actions is unclear. However, both individuals subsequently filed a new petition, together, in Shawnee District Court, seeking declaratory and injunctive relief against the County commissioners, in which they purported to represent all past, present, and future inmates as a class. The District Court initially dismissed the action, finding that because the individuals were no longer in jail they could not represent the class and that the nature of the action was such that it could not be certified as a class action. The Kansas Court of Appeals (Judge Richard Foth) reversed and remanded. Beaver v. Chaffee, 2 Kan.App. 2d 364 (1978). Upon remand, the parties entered into a consent judgment that was approved by the Court (Judge Robert L. Gernon) on May 6, 1983.

The consent judgment required the Shawnee County commissioners to construct a new county jail and to comply with the minimum standards for administrative operations under Kansas law for the new jail. he judgment also stated that the Court would retain continuing jurisdiction concerning all matters covered by the consent decree until one year from the date of occupancy of the new jail facility, which was stipulated by the parties as being March 31, 1988. Subsequently, the County commissioners and the Kansas Secretary of Corrections moved to confirm that the Court's jurisdiction over the lawsuit would terminate on April 1, 1989. The Court (Judge Paul Miller) denied the motion, finding that the consent decree did not contemplate terminating the Court's jurisdiction on April 1, 1989, but rather it only terminated the Court's direct supervisory authority over the operation of the jail. The defendants appealed and on January 19, 1990, the Supreme Court of Kansas (Justice Fred Six) reversed, holding that a consent decree was to be interpreted as a contract would, which entitled it to plain-meaning interpretation. Beaver v. Kingman, 785 P.2d 998 (Kan. 1990). The court reasoned that if a consent decree had an expiration date written into its terms, that date was to be interpreted literally, since the absence of such a date entitled the Court to indefinite jurisdiction.

The docket was unavailable on PACER.

Summary Authors

Rebecca Bloch (3/15/2006)

People


Judge(s)

Foth, J. Richard (Kansas)

Six, Fred (Kansas)

Attorneys(s) for Plaintiff

Blumenthal, Thomas M. (Kansas)

Paul, Lowell C. (Kansas)

Rute, Larry R. (Kansas)

Attorneys(s) for Defendant

Johnson, Frank L. (Kansas)

Martin, Douglas F. (Kansas)

Schneider, Curt T. (Kansas)

Theis, Roger M. (Kansas)

Voth, Donna (Kansas)

Judge(s)

Foth, J. Richard (Kansas)

Six, Fred (Kansas)

Attorneys(s) for Plaintiff

Blumenthal, Thomas M. (Kansas)

Paul, Lowell C. (Kansas)

Rute, Larry R. (Kansas)

Attorneys(s) for Defendant

Johnson, Frank L. (Kansas)

Martin, Douglas F. (Kansas)

Schneider, Curt T. (Kansas)

Theis, Roger M. (Kansas)

Voth, Donna (Kansas)

Zima, Joseph W. (Kansas)

Documents in the Clearinghouse

Document

No. 49,116

Opinion

Beaver v. Chaffee

Kansas state appellate court

579 P.2d 1217

June 9, 1978

June 9, 1978

Order/Opinion

No. 63,794

Opinion

Kansas state supreme court

785 P.2d 998

Jan. 19, 1990

Jan. 19, 1990

Order/Opinion

Resources

Docket

Last updated Aug. 1, 2022, 3:03 a.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: Kansas

Case Type(s):

Jail Conditions

Key Dates

Filing Date: 1974

Closing Date: April 1, 1989

Case Ongoing: No

Plaintiffs

Plaintiff Description:

Inmates of a county jail challenging conditions of their confinement

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: Yes

Filed Pro Se: Unknown

Class Action Sought: Yes

Class Action Outcome: Granted

Defendants

Shawnee County Jail (Shawnee), County

Case Details

Causes of Action:

42 U.S.C. § 1983

Availably Documents:

Any published opinion

Outcome

Prevailing Party: Plaintiff

Nature of Relief:

Injunction / Injunctive-like Settlement

Source of Relief:

Settlement

Form of Settlement:

Court Approved Settlement or Consent Decree

Order Duration: 1983 - 1989

Issues

General:

Sanitation / living conditions

Totality of conditions

Type of Facility:

Government-run