PETITION FOR JUDICIAL REVIEW OF LICENSING DECISION

CAPTION

DISTRICT COURT OF KANSAS, [COUNTY] COUNTY
[PETITIONER/LICENSEE], Petitioner,
v.
[AGENCY/BOARD NAME], Respondent.
Case No.: [___]

INTRODUCTION

• Petition for judicial review challenging Respondent's [Denial/Discipline/Suspension/Revocation] of [License Type] issued [DATE].

JURISDICTION, VENUE, AND TIMELINESS

• Jurisdiction under the Kansas Judicial Review Act (K.S.A. 77-601 et seq.); venue proper in [County].
• Petition timely under K.S.A. 77-613 (30 days from service of final agency action; check specific statute).
• Administrative remedies exhausted.

PARTIES

• Petitioner [Name], license number [___].
• Respondent [Agency/Board], state agency located in [County/City].

PROCEDURAL HISTORY

• Summary of accusation/notice, hearing date(s), ALJ proposed decision, Board adoption/modification, and service of final decision on [DATE].

STANDARD AND GROUNDS (K.S.A. 77-621)

• Agency action is invalid if: (1) unconstitutional; (2) beyond statutory authority; (3) made upon unlawful procedure; (4) based on erroneous interpretation of law; (5) unsupported by substantial evidence when viewed in light of the record as a whole; (6) arbitrary, capricious, or unreasonable; or (7) otherwise in violation of the law.
• [Tailor to record].

ALLEGATIONS (SUMMARY)

• [Facts showing evidentiary gaps, legal errors, bias, or procedural defects].

RELIEF REQUESTED

• Issue order directing Respondent to vacate the decision and [reinstate license/issue license/remand].
• Stay enforcement pending review (K.S.A. 77-616).
• Costs and other relief as just.

RECORD AND PREPARATION

• Request preparation/certification of the administrative record per K.S.A. 77-619; Petitioner will arrange for record filing and pay costs as required.

VERIFICATION AND SIGNATURE

• Verification per applicable Kansas rules; signature of Petitioner/counsel; proof of service on Respondent and Attorney General.