Huffman v. City of Maize, 116500

In 2014 the City of Maize enacted Ordinance No. 892 regulating mobile home parks; prior to that there was no such ordinance.
City formed a committee, drafted the ordinance with the city attorney, publicized meetings, revised the draft after public comments, and mailed revised language to park owners before final passage.
At final council action the ordinance was amended to exempt existing parks from many requirements (roads, storage, lighting, storm shelters, garbage) unless sold to new owners; ordinance published Dec. 2014 and effective July 1, 2015.
Owners Huffman and the Westhoffs (mobile home park owners) sued for declaratory and injunctive relief alleging Ordinance 892 exceeded police powers and violated due process and equal protection; damages claim was dismissed without prejudice.
The district court granted summary judgment for the City, holding the ordinance was a valid exercise of police power, satisfied rational-basis equal protection, and afforded adequate notice and opportunity to be heard; the court adopted the City’s uncontroverted facts.
Plaintiffs appealed, challenging the ordinance’s constitutionality (police power, due process, equal protection) and the adequacy of the district court’s findings and conclusions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Validity under municipal police power / due process	Ordinance exceeds City police power and violates substantive and procedural due process	Ordinance rationally promotes public health, safety, welfare; plaintiffs had notice and opportunity to be heard	Court upheld ordinance as proper police-power exercise; no due process violation
Equal protection	Ordinance improperly treats mobile-home owners differently from other homeowners	Classification is rationally related to legitimate safety/health objectives	Rational-basis review satisfied; no equal protection violation
Adequacy of district court findings/conclusions	District court improperly adopted City’s proposed findings, violating applicable rules	Adoption is permissible if court considered them; adoption alone is not reversible error	Adoption was acceptable here; no error in findings/conclusions or summary judgment process

Creegan v. State, 305 Kan. 1156 (standard for summary judgment and appellate review) (describing summary-judgment proof burden)
City of Wichita v. Hackett, 275 Kan. 848 (ordinance constitutionality is reviewed de novo and presumptively valid)
Lower v. Board of Dir. of Haskell County Cemetery Dist., 274 Kan. 735 (municipal police power upheld when regulations bear real and substantial relation to health, safety, welfare)
City of Colby v. Hurtt, 212 Kan. 113 (upheld mobile-home regulation as reasonably related to public health and welfare)
State v. Mossman, 294 Kan. 901 (courts must presume constitutionality of municipal enactments)
Stone v. City of Kiowa, 263 Kan. 502 (trial court may adopt party’s proposed findings if individually considered)