Plain v. Kansas Dept. of Revenue

CourtCourt of Appeals of Kansas
DecidedApril 10, 2026
Docket128634
StatusPublished

This text of Plain v. Kansas Dept. of Revenue (Plain v. Kansas Dept. of Revenue) 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
Plain v. Kansas Dept. of Revenue, (kanctapp 2026).

Opinion

No. 128,634

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

KOWAN PLAIN, Appellant,

v.

KANSAS DEPARTMENT OF REVENUE, Appellee.

SYLLABUS BY THE COURT

1. A Kansas driver's license may be suspended and simultaneously revoked due to overlapping driving restrictions and penalties.

2. The Kansas Driver License Compact, found in K.S.A. 8-1212, requires compliance with all three sections of Article V before a Kansas license will issue.

Appeal from Harper District Court; GATEN T. WOOD, judge. Submitted without oral argument. Opinion filed April 10, 2026. Affirmed.

Kowan Plain, appellant pro se.

Charles P. Bradley, of Legal Services Bureau, Kansas Department of Revenue, for appellee.

Before PICKERING, P.J., SCHROEDER and HURST, JJ.

PICKERING, J.: If you move to Kansas and apply for a Kansas driver's license while your current state's license is revoked and suspended, it is doubtful you will be issued a Kansas license. Kowan Plain did just that and was denied a Kansas driver's

1 license. He now appeals the district court's affirmance of the Kansas Department of Revenue's (KDOR) decision not to issue him a driver's license based on pending suspensions and revocation of his Alabama license. Plain argues KDOR erred by applying the incorrect subsection of the Kansas Driver License Compact and violated his constitutional rights. As a matter of first impression, we find no error and affirm.

FACTUAL AND PROCEDURAL BACKGROUND

The facts in this case are not in dispute. Plain applied for a Kansas driver's license, which KDOR denied. In doing so, it noted that Plain's driving record indicated a license revocation on June 22, 2018, which would not preclude his ability to apply for a Kansas license under the Kansas Driver License Compact, K.S.A. 8-1212 et seq. But KDOR also explained that Plain's driving record showed multiple suspensions and advised Plain that his out-of-state suspensions must be resolved before Kansas could issue him a license.

Plain's driving record shows 13 Alabama driver's license suspensions, dating from January 26, 2011, until April 12, 2017. It also shows his license was revoked in Alabama four times: on December 8, 2015; June 8, 2016; December 8, 2016; and June 22, 2018. Finally, his driving record shows Plain's license was canceled in Colorado on March 16, 2020. There are no reinstatement dates listed next to any of Plain's suspensions, revocations, or the Colorado cancellation.

Plain filed a petition for review under the Kansas Judicial Review Act (KJRA), K.S.A. 77-601 et seq. He asserted KDOR made an error of law when it applied Article V, (1) of the Kansas Driver License Compact, K.S.A. 8-1212, instead of Article V, (2). Section 1 prohibits a licensing authority from issuing a license when an individual has an outstanding out-of-state suspension of his or her license. In contrast, (2) prohibits issuance of a license when an individual has an out-of-state driver's license revocation

2 unless that revocation is more than one year old and, after investigation, the licensing authority is convinced it is safe to grant the applicant the privilege of driving.

After a hearing, the district court affirmed KDOR's decision to deny Plain a license. The district court found Plain's suspensions were "continuing in nature and do not show an eligibility or reinstatement date." Similarly, it found Plain's revocations were continuing in nature. The district court concluded that there was no language in the Kansas Driver License Compact that would compel KDOR to choose between Article V, (1) and (2). In other words, the two sections were not mutually exclusive. The district court concluded that Plain failed to carry his burden to show that KDOR's action was "unreasonable, arbitrary, or capricious."

Plain timely appealed.

ANALYSIS

I. KDOR Did Not Commit an Error of Law by Applying Section 1 of the Driver License Compact Instead of Section 2

The KJRA defines the scope of judicial review of state agency actions unless the agency is specifically exempted from the application of the statute. K.S.A. 77-603(a). "The burden of proving the invalidity of agency action is on the party asserting invalidity." K.S.A. 77-621(a)(1). A reviewing court shall grant relief only if it determines:

"(1) The agency action, or the statute or rule and regulation on which the agency action is based, is unconstitutional on its face or as applied; "(2) the agency has acted beyond the jurisdiction conferred by any provision of law;

3 "(3) the agency has not decided an issue requiring resolution; "(4) the agency has erroneously interpreted or applied the law; "(5) the agency has engaged in an unlawful procedure or has failed to follow prescribed procedure; "(6) the persons taking the agency action were improperly constituted as a decision-making body or subject to disqualification; "(7) the agency action is based on a determination of fact, made or implied by the agency, that is not supported to the appropriate standard of proof by evidence that is substantial when viewed in light of the record as a whole, which includes the agency record for judicial review, supplemented by any additional evidence received by the court under this act; or "(8) the agency action is otherwise unreasonable, arbitrary or capricious." K.S.A. 77-621(c).

To the extent resolution of this issue requires statutory interpretation, this presents a question of law over which we have unlimited review. Nicholson v. Mercer, 319 Kan. 712, 714, 559 P.3d 350 (2024).

Discussion

On appeal, Plain argues that a suspension and a revocation are two different statutes which fall under different sections of Article V of the Driver License Compact. He questions whether one can be both suspended and revoked at the same time.

In contrast, KDOR asserts an individual cannot have any pending suspensions, must serve any required revocation period (or meet an exception), and must surrender any out-of-state licenses before a Kansas license may be issued. It contends that Article V of the Driver License Compact requires compliance with all three sections before a license can be issued.

4 Neither Plain nor KDOR cite to caselaw supporting their respective positions. Indeed, both acknowledge that whether one's driving privileges can simultaneously be suspended and revoked is an issue of first impression.

"The most fundamental rule of statutory construction is that the intent of the Legislature governs if that intent can be ascertained." Johnson v. U.S. Food Service, 312 Kan. 597, 600, 478 P.3d 776 (2021). An appellate court must first attempt to ascertain legislative intent through the statutory language enacted, "'giving common words their ordinary meaning.'" Bruce v. Kelly, 316 Kan. 218, 224, 514 P.3d 1007 (2022).

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Related

In re Adoption of T.M.M.H. – Per Curiam
416 P.3d 999 (Supreme Court of Kansas, 2018)
Bruce v. Kelly
514 P.3d 1007 (Supreme Court of Kansas, 2022)
Nicholson v. Mercer
559 P.3d 350 (Supreme Court of Kansas, 2024)

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Plain v. Kansas Dept. of Revenue, Counsel Stack Legal Research, https://law.counselstack.com/opinion/plain-v-kansas-dept-of-revenue-kanctapp-2026.