Matson v. Kan. Dep’t of Corr.Annotate this Case
Plaintiff, an inmate in the custody of the Kansas Department of Corrections (DOC), took advantage of a statutorily created inmate trust fund to place money in the custody of the DOC for his use while serving his sentence. Plaintiff filed suit in Leavenworth District Court pursuant to the Kansas Uniform Trust Code (KUTC) alleging that Defendants were in breach of trust by charging various fees against the balance held in his inmate fund. Defendants successfully moved to transfer venue to Norton District Court. Plaintiff filed a motion to transfer venue back to Leavenworth District court, claiming that because the inmate trust fund was administered at the Lansing Correctional Facility in Leavenworth County, his claims under the KUTC could only be brought in Leavenworth District Court pursuant to Kan. Stat. Ann. 58a-204. The Norton District Court denied Plaintiff’s motion and granted summary judgment to Defendants on all of Plaintiff’s claims. The Court of Appeals affirmed, concluding that Plaintiff could have filed his suit in Norton County under Kan. Stat. Ann. 60-602(2). The Supreme Court reversed, holding (1) the inmate trust is a trust subject to the KUTC; and (2) the KUTC establishes exclusive venue in the county were the inmate trust fund is administered - i.e., in Leavenworth County.