Baker v. Hayden


IN THE SUPREME COURT OF THE STATE OF KANSAS No. 117,989 LINUS BAKER, Appellant, v. CALVIN HAYDEN, et al., Defendants, and LAURA BREWER, in Her Capacity as Official Custodian of Records for the Tenth Judicial District, Appellee. SYLLABUS BY THE COURT 1. While standing is a requirement for a case or controversy, i.e., justiciability, it is also a component of subject matter jurisdiction that may be raised at any time. 2. Courts have the duty to determine whether they have subject matter jurisdiction. And the parties cannot vest a court with jurisdiction by agreement, failing to object, or waiver. 3. Standing can be raised for the first time on appeal. And a court can generally determine the issue when it arises during an appeal related to a motion to dismiss, because it presents a question of law. 1 4. When a question of standing is raised, the party asserting the claim has the burden to establish standing requirements. 5. A plaintiff making a claim under the Kansas Open Records Act (KORA), K.S.A. 45-215 et seq., must establish both (1) any statutory standing requirements imposed by KORA and (2) the traditional requirements of standing. 5. A party can have standing as a lawsuit begins but lose it before the case is resolved if circumstances change. 6. To establish traditional standing, a plaintiff must establish a personal interest in a court's decision and that he or she personally suffers some actual or threatened injury because of the challenged conduct. The injury must be particularized, meaning it must affect the plaintiff in a personal and individual way. Review of the judgment of the Court of Appeals in 55 Kan. App. 2d 473, 419 P.3d 31 (2018). Appeal from Johnson District Court; ROBERT W. FAIRCHILD, judge. Opinion filed July 2, 2021. Appeal dismissed. Linus L. Baker, appellant, argued the cause, and was on the briefs, pro se. Joseph R. Colantuono, of Colantuono Bjerg Guinn Keppler LLC, of Overland Park, argued the cause, and Richard G. Guinn and Isaac Keppler, of the same firm, Stephen Phillips, assistant attorney general, and Derek Schmidt, attorney general, were with him on the briefs for appellee Laura Brewer. 2 Stephen Douglas Bonney, of ACLU Foundation of Kansas, of Overland Park, and Nolan Wright, legal intern, of the same foundation, were on the brief for amicus curiae American Civil Liberties Union Foundation of Kansas. PER CURIAM: The parties ask us to answer whether the Kansas Open Records Act (KORA), K.S.A. 45-215 et seq., requires a Kansas district court to make audio records of open court proceedings available for public inspection. But we cannot reach this question because we conclude Linus Baker lost a stake in resolving that question at a point after he filed his petition in this case and thus lost standing. Standing is a component of appellate courts' jurisdiction. When a party loses standing, courts lose jurisdiction. And without jurisdiction, we must dismiss the appeal. FACTUAL AND PROCEDURAL BACKGROUND Baker, an attorney, made a written request to listen …

Original document
Source: All recent Immigration Decisions In All the U.S. Courts of Appeals