KNEA v. State, 114135

Background

Kansas National Education Association (KNEA), representing ~19,800 public school teachers, sued after 2014 Senate Substitute for House Bill No. 2506 (H.B. 2506) became law, seeking declaratory and injunctive relief against amendments to the Teacher Due Process Act that removed many K-12 teachers from prior procedural protections.
H.B. 2506 was enacted quickly in response to this court's Gannon decision on school finance; the bill (titled "concerning education") combined substantive changes to school finance and teacher due process with multiple appropriations and transfers reallocating funds toward education.
The State moved to dismiss for lack of subject-matter jurisdiction, arguing KNEA lacked associational standing and the claim was unripe; the district court rejected those jurisdictional defenses but granted dismissal on the merits, holding the bill did not violate the one-subject rule.
On appeal to the Kansas Supreme Court the issues presented were: (1) KNEA's associational standing, (2) ripeness of the constitutional claim, and (3) whether H.B. 2506 violated Article 2, § 16 (the one-subject rule), particularly whether appropriations may be combined with substantive legislation in one bill.
The Supreme Court held KNEA sufficiently alleged standing and the claim was ripe, and on the merits ruled Article 2, § 16 permits combining appropriations and general legislation in a single bill so long as all provisions are germane to a single subject; it concluded H.B. 2506's provisions all related to the single subject of "education," and affirmed dismissal.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Associational standing	KNEA: members lost "valuable rights" under Teacher Due Process Act, so KNEA may sue for members	State: KNEA alleged only generalized or conclusory injury; no individual member shown to have standing	KNEA made a prima facie showing at motion-to-dismiss stage that at least one member suffered cognizable injury caused by the statute; associational standing satisfied
Ripeness	KNEA: legal question is pure and no further facts required to decide constitutionality	State: claim premature because no teacher has yet been disciplined under new law	Claim is ripe: statute effective, issue purely legal, and KNEA had alleged sufficient standing
Whether appropriations may be mixed with substantive law	KNEA: Carlin and earlier cases show appropriations bills cannot include unrelated substantive provisions; here appropriations in H.B. 2506 are not education-related	State: Article 2 § 16 does not categorically forbid combining appropriations and substantive provisions; all provisions must simply relate to one subject	Court: No per se ban; appropriations and substantive legislation may coexist in one bill if all provisions are germane to a single subject
Whether H.B. 2506 violates one-subject rule	KNEA: appropriations to various agencies are unrelated to education and thus make bill multiplicitous	State: bill titled and focused on "education"; reallocations and substantive provisions relate to education policy and funding	Court: H.B. 2506 addresses a single comprehensive subject—education—and does not embrace dissimilar, discordant subjects; upholds statute

Key Cases Cited

Gannon v. State, 298 Kan. 1107 (2014) (underlying school finance decision prompting H.B. 2506)
Sierra Club v. Moser, 298 Kan. 22 (2013) (association standing test and standing ripeness principles)
Kansas One-Call System v. State, 294 Kan. 220 (2012) (holding multiple provisions germane under a broad subject comply with one-subject rule)
U.S.D. No. 229 v. State, 256 Kan. 232 (1994) (upholding package tying funding measures to substantive school reforms as single subject)
State ex rel. Stephan v. Carlin, 230 Kan. 252 (1981) (invalidating substantive amendment inserted in an omnibus appropriation bill; discussed and distinguished)
KPERS v. Reimer & Koger Assocs., Inc., 262 Kan. 635 (1997) (articulating test that act is invalid if it embraces dissimilar and discordant subjects)