Case: Beaver v. Kingman

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.