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Case Name Beaver v. Kingman JC-KS-0003
Docket / Court Docket No. Not Available ( State Court )
State/Territory Kansas
Case Type(s) Jail Conditions
Case Summary
In 1974, two inmates of 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 inmates ... read more >
In 1974, two inmates of 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 inmates 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 inmates 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. The 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.

Rebecca Bloch - 03/15/2006


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Issues and Causes of Action
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Issues
General
Sanitation / living conditions
Totality of conditions
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) Shawnee County Jail
Plaintiff Description Inmates of a county jail challenging conditions of their confinement
Indexed Lawyer Organizations None on record
Class action status sought Yes
Class action status granted Yes
Prevailing Party Plaintiff
Public Int. Lawyer Yes
Nature of Relief Injunction / Injunctive-like Settlement
Source of Relief Settlement
Form of Settlement Court Approved Settlement or Consent Decree
Order Duration 1983 - 1989
Case Closing Year 1989
Case Ongoing No
Additional Resources
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Case Studies After Decision: Implementation of Judicial Decrees in Correctional Settings
Written: Oct. 01, 1977
By: M. Kay Harris & Dudley P. Spiller (Temple University)
Citation: (1977)
[ Detail ] [ PDF ]

Docket(s)
No docket sheet currently in the collection
General Documents
Opinion 06/09/1978 (579 P.2d 1217)
JC-KS-0003-0002.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Opinion 01/19/1990 (785 P.2d 998)
JC-KS-0003-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Google Scholar
Judges Foth, J. Richard (State Appellate Court)
JC-KS-0003-0002
Six, Fred (State Supreme Court)
JC-KS-0003-0001
Monitors/Masters None on record
Plaintiff's Lawyers Blumenthal, Thomas M. (Kansas)
JC-KS-0003-0002
Paul, Lowell C. (Kansas)
JC-KS-0003-0001
Rute, Larry R. (Kansas)
JC-KS-0003-0001
Defendant's Lawyers Johnson, Frank L. (Kansas)
JC-KS-0003-0002
Martin, Douglas F. (Kansas)
JC-KS-0003-0001
Schneider, Curt T. (Kansas)
JC-KS-0003-0002
Theis, Roger M. (Kansas)
JC-KS-0003-0002
Voth, Donna (Kansas)
JC-KS-0003-0002
Zima, Joseph W. (Kansas)
JC-KS-0003-0002
Other Lawyers None on record

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