Stanley v. Sullivan
300 Kan. 1015
Kan.2014Background
- Petitioner Billy J. Stanley, an involuntarily committed persistent sexual offender at Lamed State Security Hospital, filed three habeas corpus petitions challenging (1) documents posted on resident computers (two petitions) and (2) bright lights on inmates' beds during sleeping hours.
- District court dismissed all three petitions for failure to exhaust administrative remedies without requiring responses or holding hearings; Court of Appeals affirmed after consolidating the cases.
- The controlling statute is K.S.A. 2013 Supp. 59-29a24 (effective July 1, 2012), which generally requires exhausted administrative remedies for civil actions by patients but contains subsection (d): "The provisions of this section shall not apply to a writ of habeas corpus."
- Secretary argued exhaustion was required (and points to K.S.A. 2013 Supp. 60-1501(c)’s tolling language) and that the Court of Appeals reasonably relied on common-law exhaustion and legislative history to construe the statute.
- Kansas Supreme Court reviewed statutory interpretation de novo, held the statutory text is clear: the exhaustion requirement does not apply to habeas corpus petitions, reversed the lower courts, and remanded the cases to district court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether involuntarily committed sexual offenders must exhaust administrative remedies before filing habeas corpus | Stanley: K.S.A. 2013 Supp. 59-29a24(d) exempts writs of habeas corpus from exhaustion; no exhaustion required | Secretary: Common-law exhaustion applies; new statutes (including 60-1501(c)) imply exhaustion and tolling, so exhaustion is required | Court: Statutory text is clear — subsection (d) exempts habeas petitions from exhaustion; exhaustion not required |
| Whether phrase "this section" is ambiguous (could refer only to subsection (c)) | Stanley: Plain meaning refers to entire section; no ambiguity | Secretary/Ct. of Appeals: argued ambiguity and used legislative history to limit subsection (d) to subsection (c) | Court: Not ambiguous; "section" refers to whole statutory section; legislature could have said "preceding subsection" if intended otherwise |
| Whether K.S.A. 60-1501(c) conflicts with 59-29a24(d) (tolling vs. exemption) | Stanley: No conflict — 59-29a24(d) exempts habeas from exhaustion; 60-1501(c) tolls the 30-day filing period if pursuing administrative remedies | Secretary: If no exhaustion requirement, 60-1501(c) is unnecessary and inconsistent | Court: Harmonizes both — a patient may either exhaust (tolling the filing deadline) or forgo exhaustion and proceed within 30 days; no conflict or absurdity |
| Whether courts may consult legislative history when statute is plain | Stanley: Courts should follow plain statutory language and not resort to legislative history | Secretary/Ct. of Appeals: Relied on legislative history to interpret intent | Court: Must apply plain text first; resorting to legislative history here was improper because statute is clear |
Key Cases Cited
- State v. Looney, 299 Kan. 903 (dispositive rule of statutory interpretation; de novo review)
- Battrick v. State, 267 Kan. 389 (discussing common-law exhaustion principles)
- Levier v. State, 209 Kan. 442 (historical authority on exhaustion for prisoners)
- Wilcox v. Fisher, 163 Kan. 74 (older precedent on habeas/exhaustion issues)
- Schoenholz v. Hinzman, 295 Kan. 786 (statutory law supersedes common law)
- Downtown Bar and Grill v. State, 294 Kan. 188 (treating references to "section" as the entire statutory section)
- Northern Natural Gas Co. v. ONEOK Field Services Co., 296 Kan. 906 (statutory harmonization and avoiding absurd results)