McGivern v. Kansas Real Estate Comm'n

CourtCourt of Appeals of Kansas
DecidedMay 1, 2026
Docket128017
StatusUnpublished

This text of McGivern v. Kansas Real Estate Comm'n (McGivern v. Kansas Real Estate Comm'n) 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
McGivern v. Kansas Real Estate Comm'n, (kanctapp 2026).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 128,017

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

BRAD J. MCGIVERN, Appellant,

v.

KANSAS REAL ESTATE COMMISSION, Appellee.

MEMORANDUM OPINION

Appeal from Shawnee District Court; THOMAS G. LUEDKE, judge. Oral argument held August 5, 2025. Opinion filed May 1, 2026. Affirmed.

R. Patrick Riordan and Lauren E. Bartee, of Riordan, Fincher & Mayo, P.A., of Topeka, for appellant.

Dwight R. Carswell, deputy solicitor general, and Kris W. Kobach, attorney general, for appellee.

BEFORE HILL, P.J., MALONE and HURST, JJ.

HURST, J.: Kansas real estate agents are expected to act in good faith for the benefit of their clients' best interests, and when they fail to adhere to those tenants the Kansas Real Estate Commission (Commission) can fine them accordingly—which is what occurred here. The Commission found that Brad J. McGivern, an experienced real estate agent, violated the Kansas Real Estate Brokers' and Salespersons' License Act (Real Estate Act), K.S.A. 58-3034 et seq., when McGivern advised a client, Drew (a pseudonym), of a listing price for their personal residence that was substantially lower than the actual market value. Not only did McGivern provide a low value, but he then 1 offered to buy the property based on that low price. On top of that, McGivern's purchase price also accounted for a 6 percent brokerage fee to McGivern despite McGivern also being the buyer. The day after closing on the property, McGivern turned around and listed it for sale for approximately $46,000 more than the purchase price of a day earlier.

Based on these events, Drew sought redress and after multiple proceedings, the Commission found that McGivern had violated K.S.A. 58-3062(a)(13) of the Real Estate Act by engaging in fraud or making a substantial misrepresentation and imposed a fine and assessed associated costs. McGivern appeals the Commission's findings and imposition of fees.

Despite McGivern's attempts to excuse his actions, the facts establish that the Commission did not err in finding that McGivern violated the Real Estate Act by fraudulently or substantially misrepresenting the property's value to Drew. Nor did the Commission err in assessing costs incurred from the Office of Administrative Hearings. Therefore, this case is affirmed.

FACTUAL AND PROCEDURAL BACKGROUND

McGivern has been a licensed real estate agent since 1998. In 2013, McGivern represented Drew in purchasing the residential property in Topeka (Property) for $110,000. In 2021, Drew moved in with her son at his residence and subsequently rented the Property to a friend but later decided to sell the Property. About nine years after first working with McGivern, Drew contacted him to represent her in selling the Property. Drew explained that she trusted McGivern and believed he was a good real estate agent and would secure a good price for the Property. The 2021 county appraisal for the Property estimated its value at $119,860.

2 In February 2022, McGivern met with Drew to assess the Property as Drew was trying to decide whether to invest in improvements or sell the Property "as-is." McGivern recommended selling the Property "as-is" and recommended listing the Property for $109,900, hoping it would create a bidding war that would increase the sale price to about $120,000.

Two days later, McGivern emailed Drew an Exclusive Listing Agreement. The day after sending Drew the Exclusive Listing Agreement, McGivern called her and offered to buy the Property, saying that he might use it as a rental. McGivern offered Drew $102,706 for the Property, explaining the offer was the approximate result of subtracting a 6 percent brokerage fee and a $600 transaction fee from the anticipated $109,900 listing price. Drew offered to sell the Property to McGivern for $105,000 to allow her to pay off the remainder of her car loan and become debt-free, but McGivern declined if there were no inspections of the roof and sewer line. Drew thereafter agreed to McGivern's offer. The parties executed a contract—drawn up by McGivern—for the sale of the Property for $102,706.

The sale closed on March 31, 2022. One day later, and despite making no improvements to the Property beyond possibly painting its interior, McGivern listed the Property for $149,000—nearly $40,000 more than the listing price he proposed when representing Drew, and approximately $46,000 greater than he paid for the Property the day before. Less than a week later, the Property was under contract for $139,900— $37,000 more than McGivern paid just days earlier. After expenses, McGivern made a profit of $27,762.43 on the resale of the Property.

McGivern's lender for the purchase of the Property was Capitol Federal Savings Bank. Capitol Federal's internal valuation report estimated the value of the Property to be approximately $154,900 to $162,500, depending on improvements, and noted the sale

3 price of $102,706 was well below both the market and property-tax valuations. Drew's son—with her support—filed a complaint against McGivern with the Commission alleging that McGivern "misled [Drew] on the value of her home" which "directly impacted the choice she made on how to sell her home."

Based on Drew's complaint, the Commission issued a summary proceeding order finding McGivern violated K.S.A. 58-3062(a)(13)—which prohibits licensees from engaging in fraud or making any substantial misrepresentation—and K.S.A. 58- 30,113(b)(2)—which obligates a transaction broker to exercise reasonable skill and care—and fining McGivern $1,000 for each violation. McGivern sought review of the Commission's summary proceeding order. An administrative law judge with the Office of Administrative Hearings (OAH) conducted a hearing on the matter, at which Drew, her son, and McGivern testified. The ALJ issued an initial order upholding the findings and penalties for both violations.

The initial order found McGivern "did not make a market analysis or use comparable sales in the area when he determined" the $109,900 price. It referenced McGivern's testimony that "he has experience with the local market" and that "[Drew] wanted a quick sale, with the Property 'as is.'" The initial order concluded that Drew and her son contacted McGivern to be their seller's agent and believed they had hired McGivern as that, therefore McGivern had an obligation to inform Drew that his interests had changed—from helping to sell the Property to being interested in purchasing the Property. Based on these violations, the initial order found the $1,000 fines were proper.

McGivern sought review of the initial order, primarily arguing the initial order's factual findings did not support a legal finding of fraud or substantial misrepresentation under K.S.A. 58-3062(a)(13) and that McGivern did not meet the definition of a transaction broker under K.S.A. 58-30,102(u) and K.S.A. 58-30,113(b)(2). The

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McGivern v. Kansas Real Estate Comm'n, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcgivern-v-kansas-real-estate-commn-kanctapp-2026.