Board of Riley County Comm'rs v. Kansas Historical Society

CourtCourt of Appeals of Kansas
DecidedDecember 19, 2025
Docket126435
StatusPublished

This text of Board of Riley County Comm'rs v. Kansas Historical Society (Board of Riley County Comm'rs v. Kansas Historical Society) is published on Counsel Stack Legal Research, covering Court of Appeals of Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Board of Riley County Comm'rs v. Kansas Historical Society, (kanctapp 2025).

Opinion

No. 126,435

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

BOARD OF RILEY COUNTY COMMISSIONERS, Appellant/Cross-appellee,

v.

KANSAS HISTORICAL SOCIETY, JENNIE CHINN, STATE HISTORIC PRESERVATION OFFICER, and KANSAS HISTORIC SITES BOARD OF REVIEW, Appellees/Cross-appellants.

SYLLABUS BY THE COURT

1. A case is moot when the actual controversy has ended and any judgment that could be entered would be ineffectual for any purpose and would not affect any of the parties' rights. A case is not moot when a party articulates a substantial interest that would be impaired by dismissal.

2. Agency decisions must be based on known rules and standards.

3. Unless a statute provides otherwise, all Kansas rules and regulations must be adopted using the procedures in the Kansas Rules and Regulations Filing Act, K.S.A. 77- 415 et seq.

1 4. When a rule or regulation must be adopted using the process outlined in the Kansas Rules and Regulations Filing Act but its adoption does not follow that procedure, the rule or regulation has no force or effect.

5. The Kansas Judicial Review Act provides broad authority to a district court to order appropriate relief when an agency has exceeded its legal authority. Appellate courts will set the district court's remedy aside only when that remedy results from an abuse of discretion.

Appeal from Riley District Court; W. LEE FOWLER, judge. Oral argument held February 19, 2025. Opinion filed December 19, 2025. Affirmed.

Bryant Parker, deputy county counselor, and Clancy Holeman, county counselor, for appellant/cross-appellee.

Whitney L. Casement, of Stevens & Brand, L.L.P., of Topeka, for appellees/cross-appellants.

Before WARNER, C.J., GARDNER and HURST, JJ.

WARNER, C.J.: State agencies are governmental actors, and the standards they adopt carry the force of law. For this reason, Kansas statutes generally require an agency to give the public notice of any rule they intend to adopt and to allow an opportunity for interested members of the public to provide feedback before a proposed rule becomes law. This notice-and-comment rulemaking process applies to nearly all agencies for nearly all agency rules—from professional licensing regulations to environmental restrictions to securities laws. The process helps ensure that members of the public are not subjected to agency rules and regulations whose existence is known only by agency personnel.

2 This case tests the extent to which this notice-and-comment process applies to agencies charged with preserving and protecting historic property in this state. The former First Christian Church building in downtown Manhattan has been the subject of much discussion in the Riley County government for nearly two decades. The County, which purchased the church in 2020, would like to tear it down to make way for modern government offices. After the County bought the church, several residents sought to preserve it as a historic building and nominated the church for listing on the National Historic Register of Places (which we call the National Register). In August 2021, the Kansas Historic Sites Board of Review (a state agency) recommended that the National Park Service—which makes the final decision regarding the National Register—include the church on that list. The church has been listed on the National Register since March 2022.

This case is an administrative appeal by the County against the Board, as well as the Kansas Historical Society and its agency head (the State Historic Preservation Officer, or SHPO), challenging the Board's decision. But the issues only tangentially concern the church's listing on the National Register. Instead, they concern the process the Board used and the standards it applied to also list the property on the Register of Historic Kansas Places (which we call the Kansas Register). The County asserts that the Historical Society had not adopted any rules or regulations defining when and how property could be placed on the Kansas Register. Thus, the County and the public had no meaningful notice of what the Board was considering or how the Board was carrying out its duties.

The state agencies assert that these concerns have little, if any, practical effect because Kansas law states that any building listed on the National Register will also be listed on the Kansas Register. In other words, the Board argues that the County's concerns have been rendered moot by the church's federal historic protections.

3 There is some validity to each side's position.

Kansas law requires state agencies tasked with developing standards that will be applied to the public—like the Board here—to undergo certain steps to promulgate those standards through rules and regulations. These steps notify the public how these rules will be applied, so everyone understands the applicable administrative standards. The State Historical Society did not undergo these steps to adopt rules on how it places buildings on the Kansas Register, so it did not have administrative authority to list the church on that register in August 2021. That listing was premature.

But other than filing this declaratory-judgment action, the County took no steps between August 2021 and March 2022 to move forward with its development plans. And after the church was listed on the National Register in 2022, Kansas law required the Board to also list the property on the Kansas Register—which it did. So regardless of the legal shortcomings before the church received federal protection, the County has not shown that it suffered any real harm by the church's earlier listing on the Kansas Register.

Thus, as the district court ruled, the Board erred when it prematurely listed the church on the Kansas Register. But given the subsequent history of this case, we agree with the district court that the listing did not harm the County in a meaningful way, as the relief the County requests is not available. We affirm the district court's judgment.

FACTUAL AND PROCEDURAL BACKGROUND

The church at the heart of this case is a limestone building constructed in 1908, with additions in 1938 and 1962. It is part of a "Courthouse Plaza" in downtown Manhattan that includes the Riley County Courthouse, Carnegie Library, and the County's office complex.

4 The County had expressed interest in purchasing the church since at least 2007 to expand the County's downtown footprint. Though the County previously considered remodeling the church, it determined the office potential was limited and instead sought to acquire the church to raze the structure and construct a new office building. The County ultimately purchased the church in 2020.

The Church's Nomination for Historic Preservation

Sparked in part by talk of demolishing the church, the Riley County Preservation Alliance—a group of community members interested in the preservation of historic properties—submitted a form to the Historical Society in May 2021, nominating the church for the National Register. This form did not mention the Kansas Register.

After receiving this form, the Deputy SHPO informed the County that the church would be considered by the Board "for nomination to the National Register of Historic Places and the Register of Historic Kansas Places (state register)" on August 7, 2021.

The Riley County Commission consists of three commissioners. One commissioner—Kathryn Focke—wrote a letter to the Deputy SHPO in support of the church's nomination to the National Register. The other two commissioners wrote a letter to the Deputy SHPO opposing the nomination.

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Board of Riley County Comm'rs v. Kansas Historical Society, Counsel Stack Legal Research, https://law.counselstack.com/opinion/board-of-riley-county-commrs-v-kansas-historical-society-kanctapp-2025.