Rural Water District No. 3 v. Rural Water District No. 8

CourtCourt of Appeals of Kansas
DecidedJanuary 16, 2026
Docket128762
StatusPublished

This text of Rural Water District No. 3 v. Rural Water District No. 8 (Rural Water District No. 3 v. Rural Water District No. 8) 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
Rural Water District No. 3 v. Rural Water District No. 8, (kanctapp 2026).

Opinion

No. 128,762

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

RURAL WATER DISTRICT NO. 3, Douglas County, Appellant,

v.

RURAL WATER DISTRICT NO. 8, Shawnee County, RURAL WATER DISTRICT NO. 5, Osage County, and TRI-DISTRICT WATER AUTHORITY, Appellees.

SYLLABUS BY THE COURT

1. An injunction is a district court order directing a party to do or to refrain from doing a particular act.

2. A temporary injunction preserves the relative positions of the parties in a lawsuit until a full decision on the merits can be made by the court.

3. An appellate court reviews the grant of an injunction for an abuse of discretion. The party asserting that a temporary injunction was granted in error bears the burden to establish an abuse of discretion. A judicial action constitutes an abuse of discretion if (1) it is arbitrary, fanciful, or unreasonable; (2) it is based on an error of law; or (3) it is based on an error of fact.

1 4. A party seeking injunctive relief must show: (1) a substantial likelihood of success on the merits; (2) a reasonable probability of irreparable future injury to the movant; (3) an action at law will not provide an adequate remedy; (4) the threatened injury to the movant outweighs whatever damage the proposed injunction may cause an opposing party; and (5) the injunction, if issued, would not be against public interest.

Appeal from Douglas District Court; CARL FOLSOM III, judge. Oral argument held November 18, 2025. Opinion filed January 16, 2026. Affirmed.

Steven Massey Harris, pro hac vice, of Doyle Harris Davis & Haughey, of Tulsa, Oklahoma, Samuel A. Green, of Fisher Patterson Sayler & Smith LLP, of Topeka, and John W. Nitcher, of Riling, Burkhead & Nitcher, Chtd., of Lawrence, for appellant.

Christopher F. Burger and Bradley R. Finkeldei, of Stevens & Brand, LLP, of Lawrence, for appellees Rural Water District No. 8 and Rural Water District No. 5.

No appearance by appellee Tri-District Water Authority.

Before GARDNER, P.J., HILL, J., and JOAN M. LOWDON, District Judge, assigned.

HILL, J.: There are truths in life that are self-evident. One such truth is: If a rural water district has no water to sell, then it must go out of business; after all, its customers aren't going to pay for air. Recognizing this truth, the district court here granted two defendants, both water districts, a temporary injunction barring the plaintiff—another water district—from turning off the water coming from the Tri-District Water Treatment Facility. Basically, the court ruled that the plaintiff could not turn off the tap while the three districts spar in court. The plaintiff, Rural Water District No. 3, Douglas County, which we will refer to as Douglas 3, appealed that injunction. We view this injunction as

2 an exercise of sound judgment by the district court, and we will not disturb the court's ruling.

During litigation between three public water authorities, this appeal arises.

This action began when Douglas 3 sought a declaratory judgment against two neighboring water districts—Rural Water District No. 8, Shawnee County, and Rural Water District No. 5, Osage County, which we will refer to as Shawnee 8 and Osage 5. In its petition, Douglas 3 requested a declaratory judgment regarding the rights of Douglas 3, Shawnee 8, and Osage 5 to the Tri-District Water Treatment Facility. Douglas 3 claimed it was the sole owner of the facility and asked that a declaratory judgment sever any rights that Shawnee 8 and Osage 5 have to the facility.

Douglas 3 also claimed a breach of contract, requesting the recovery of contractual debts owed by Shawnee 8 and Osage 5. Specifically, Douglas 3 alleged that Osage 5 failed to pay for contracted-for water, resulting in an outstanding debt to Douglas 3 in the sum of $282,429.08. It also claimed that shortfall will continue to increase as more water is supplied. Douglas 3 alleged the same failure to pay by Shawnee 8 with a shortfall of $403,814.83, and that shortage will continue to accrue. Douglas 3 asked the district court to enter judgment against both rural water districts and to award the alleged outstanding balances with interest as contract damages.

One water treatment facility with three rural water districts needing water had led to several courtroom struggles.

A brief history of the interactions of these three rural water districts provides a context for understanding the rulings of the district court and the reasons for the court's proper application of the extraordinary equitable relief of imposing a temporary injunction.

3 In 1979, Douglas 3 contracted with Shawnee 8 and Osage 5 for water from Clinton Lake reservoir. The contract provided that the parties would jointly construct a water treatment plant, referred to as the Tri-District Water Treatment Plant. The contract's term was set for 40 years, beginning June 1983, and provided an extension for another 40 years if requested by Shawnee 8 or agreed to by the parties.

In 2014, all three districts entered into an Interlocal Cooperation Agreement to create the Tri-District Water Authority, which concerned the ownership and management of the water treatment facility, now referred to as the Tri-District Facility. According to the Agreement, its purpose was to keep potable water flowing to all three districts by:

"(a) cooperating to operate, manage, maintain and continue to provide a joint public water supply utility to serve each Participant, and (b) to create a separate legal entity to conduct the joint and cooperative undertakings of managing, operating, maintaining and constructing a public water supply utility, all pursuant to the [Interlocal Cooperation] Act, [K.S.A. 12-2901 et seq.]."

The Agreement stated that the Authority would have the power to "acquire, construct, receive, own, manage, lease and sell real property, personal property, intangible property and other Water Supply Assets." The Authority also was given the power to "operate and maintain facilities," "enter into contracts," "sue and be sued," and "take and hold any property, real or personal, in fee simple or otherwise."

Under the Agreement's terms, "'Water Supply Assets'" were defined as the

"tangible and intangible assets usable in connection with providing water supply, including without limitation, real and personal property, physical facilities (e.g., intake facilities, water treatment plants, dams, wells, pump stations, reservoirs and other storage facilities, and transmission lines), water rights, water purchase contracts, capacity and/or contractual rights in facilities or resources owned by other entities. The Water Supply

4 Assets transferred to the Authority under this Agreement are identified on Exhibit A to this Agreement."

The Agreement also defined "'System'" as

"the Water Supply Assets and System owned and operated by the Authority, including particularly the assets and facilities described on Exhibit A currently owned and operated by [Douglas 3] and supplying water to [Douglas 3], [Shawnee 8] and [Osage 5] pursuant to various existing agreements among the Founding Participants."

We read this Agreement to mean that the parties expressed a willingness to cooperate and work together to the benefit of all of their water customers. This cooperation, though, has experienced some snags over time.

In a 2019 lawsuit, Shawnee 8 and Osage 5 alleged that Douglas 3 had locked them out of the Tri-District facilities. After an evidentiary hearing and an order denying Shawnee 8 and Osage 5's motion for a temporary injunction, the parties entered into a settlement agreement.

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