particularity requirement (Kansas) · Go Syfert
← Kansas issues

particularity requirement in Kansas

16 Kansas opinions name it 2 courts 1992–2026 7 in the last five years

The cases below were cited by Kansas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
United States v. Arvle Edgar Medlingreen
ca10 · 1988 · cited in 2 Kansas opinions naming this issue, 2001–2020
2 sentences

2001“When law enforcement officers grossly exceed the scope of a search warrant in seizing property, the particularity requirement is undermined and a valid warrant is transformed into a general warrant thereby requiring suppression of all evidence seized under that warrant.” U.S. v. Medlin (Medlin II), 842 F.2d 1194, 1199 (10th Cir. 1988).

2001"When law enforcement officers grossly exceed the scope of a search warrant in seizing property, the particularity requirement is undermined and a valid warrant is transformed into a general warrant thereby requiring suppression of all evidence seized under that warrant." U.S. v. Medlin (Medlin II), 842 F.2d 1194, 1199 (10th Cir. 1988).

22
Cendant Corp. v. Sheltongreen
ctd · 2007 · cited in 2 Kansas opinions naming this issue, 2009–2010
2 sentences

2010E.D.N.Y. 2008) (‘The particularity requirement of Rule 9[b] applies only if actual, as opposed to constructive, fraud is alleged.’); Cendant Corp. v. Shelton, 474 F. Supp. 2d 377, 380 (D.

2009E.D.N.Y. 2008) (“The particularity requirement of Rule 9[b] applies only if actual, as opposed to constructive, fraud is alleged.”); Cendant Corp. v. Shelton, 474 F. Supp. 2d 377, 380 (D.

22
Rosales v. AT & T Information Systems, Inc.green
cod · 1988 · cited in 2 Kansas opinions naming this issue, 2009–2010
2 sentences

2010Conn. 2007) (‘Courts have not applied Rule 9[b] to claims of constructive, rather than actual, fraud.’); Rosales v. AT&T Information Systems, Inc., 702 F. Supp. 1489, 1498 (D.

2009Conn. 2007) (“Courts have not applied Rule 9[b] to claims of constructive, rather than actual, fraud.”); Rosales v. AT & T Information Systems, Inc., 702 F. Supp. 1489, 1498 (D.

22
Groh v. Ramirezgreen
scotus · 2004 · cited in 2 Kansas opinions naming this issue, 2014–2022
2 sentences

2022See State v. LeFort, 248 Kan. 332, 339 , 806 P.2d 986 (1991) ("where a warrant fails to describe the area to be searched with sufficient particularity, that defect can be cured by the accompanying affidavit if the affidavit is attached to the warrant and the warrant incorporates the affidavit by reference"); see also Groh v. Ramirez, 540 U.S. 551, 557-58 , 124 S. Ct. 1284 , 157 L.

2014The Court emphasized that this particularity requirement was well-established, and went on to emphasize that “even a cursory reading of the warrant in this case—perhaps just a glance—would have revealed a glaring deficiency that any reasonable police officer would have known was constitutionally fatal.” 540 U.S. at 564 .

12
Palmer v. Browngreen
kan · 1988 · cited in 1 Kansas opinions naming this issue, 2026–2026
2 sentences

2026See, e.g., Palmer v. Brown, 242 Kan. 893, 901 , 752 P.2d 685 (1988) (holding that an appellant's petition did not allege fraud with sufficient particularity).

2026See, e.g., Palmer v. Brown, 242 Kan. 893, 901 , 752 P.2d 685 (1988) (holding that an appellant's petition did not allege fraud with sufficient particularity).

11
State v. LeFortgreen
kan · 1991 · cited in 1 Kansas opinions naming this issue, 2022–2022
2 sentences

2022See State v. LeFort, 248 Kan. 332, 339 , 806 P.2d 986 (1991) ("where a warrant fails to describe the area to be searched with sufficient particularity, that defect can be cured by the accompanying affidavit if the affidavit is attached to the warrant and the warrant incorporates the affidavit by reference"); see also Groh v. Ramirez, 540 U.S. 551, 557-58 , 124 S. Ct. 1284 , 157 L.

2022See State v. LeFort, 248 Kan. 332, 339 , 806 P.2d 986 (1991) ("where a warrant fails to describe the area to be searched with sufficient particularity, that defect can be cured by the accompanying affidavit if the affidavit is attached to the warrant and the warrant incorporates the affidavit by reference"); see also Groh v. Ramirez, 540 U.S. 551, 557-58 , 124 S. Ct. 1284 , 157 L.

11
United States v. Fostergreen
ca10 · 1996 · cited in 1 Kansas opinions naming this issue, 2001–2001
2 sentences

2001See U.S. v. Foster, 100 F.3d 846, 849-50 (10th Cir. 1996).

2001See U.S. v. Foster, 100 F.3d 846, 849-50 (10th Cir. 1996).

11
State v. Dyegreen
kan · 1992 · cited in 1 Kansas opinions naming this issue, 2001–2001
2 sentences

2001See State v. Dye, 250 Kan. 287, 293 , 826 P.2d 500 (1992).

2001See State v. Dye, 250 Kan. 287, 293 , 826 P.2d 500 (1992).

11
State v. Reedgreen
kan · 1991 · cited in 1 Kansas opinions naming this issue, 1992–1992
2 sentences

1992See State v. Reed, 248 Kan. 792 , 811 P.2d 1163 (1991) (reversal of district court’s invalidation of K.S.A. 1989 Supp. 21-4603(3)(a) as violative of separation of powers doctrine); State v. Zirkle, 15 Kan.

1992See State v. Reed, 248 Kan. 792 , 811 P.2d 1163 (1991) (reversal of district court’s invalidation of K.S.A. 1989 Supp. 21-4603(3)(a) as violative of separation of powers doctrine); State v. Zirkle, 15 Kan.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Kansas. Read the followed side critically anyway.

Also cited on this issue (12)

CaseCitedYears
State v. McFeeters green
kanctapp · 2015
2 sentences

2026App. 2d 45, 48-49 , 362 P.3d 603 (2015), this court held that to satisfy the particularity requirement of the statute, a district 5 court's findings "'must be distinct rather than general, with exactitude of detail, especially in description or stated with attention to or concern with details'" and the district court must "explicitly address how the public's safety would be jeopardized or how the offender's welfare would not be served by imposition of the intermediate sanctions." (Emphases added.) In State v. Duran, 56 Kan.

2022As addressed above, K.S.A. 2017 Supp. 22-3716 and K.S.A. 2019 Supp. 22-3716 both permit the district court to revoke probation without previously imposing a graduated intermediate sanction if "the court finds and sets forth with particularity the reasons for finding that the safety of members of the public will be jeopardized or that the welfare of the offender will not be served by such sanction." (Emphasis added.) To satisfy this particularity requirement, the district court's findings "must be distinct rather than general, with exactitude of detail, especially in description or stated with

42018–2026
State v. Clapp green
kan · 2018
2 sentences

2024The Kansas Supreme Court has held: "The particularity requirement . . . is not met when an appellate court must imply the district court's reasons for finding that the safety of members of the public will be jeopardized or that the welfare of the offender will not be served by the bypassed intermediate sanction." State v. Clapp, 308 Kan. 976 , Syl. ¶ 4, 425 P.3d 605 (2018).

2020The court must give "distinct rather than general" reasons "with exactitude of detail." State v. Clapp, 308 Kan. 976 , Syl. ¶ 4, 425 P.3d 605 (2018).

22020–2024
State v. Ervin green
kan · 2025
1 sentence

2026Jail Time Credit Lastly, Warren seeks an additional eight days of jail time credit in his 2023 case based on State v. Ervin, 320 Kan. 287 , 566 P.3d 481 (2025).

12026–2026
State v. Duran green
kanctapp · 2019
2 sentences

2026App. 2d 45, 48-49 , 362 P.3d 603 (2015), this court held that to satisfy the particularity requirement of the statute, a district 5 court's findings "'must be distinct rather than general, with exactitude of detail, especially in description or stated with attention to or concern with details'" and the district court must "explicitly address how the public's safety would be jeopardized or how the offender's welfare would not be served by imposition of the intermediate sanctions." (Emphases added.) In State v. Duran, 56 Kan.

2026App. 2d 1268, 1275 , 445 P.3d 761 (2019), this court emphasized that particularized findings are more than generalized findings that the defendant is not amenable to probation.

12026–2026
State v. Huskey green
kanctapp · 1992
1 sentence

2024Rather, when a statute requires particularized findings "'it must be distinct rather than general, with exactitude of detail, especially in description or 6 stated with attention to or concern with details.'" 308 Kan. at 989-90 (quoting State v. Huskey, 17 Kan.

12024–2024
State v. Gordon neutral
kan · 1977
2 sentences

2022He cites State v. Gordon, 221 Kan. 253, 259 , 559 P.2d 312 (1977), which held that "a search warrant directed against a multiple occupancy structure generally will be held invalid if it fails to describe the particular room or subunit to be searched with sufficient definiteness to preclude a search of other units." But Hillard's reliance on Gordon is misplaced because 1310 S. Meridian Street is not a multiple occupancy structure—that is, it is not "'a structure divided into more than 44 one occupancy unit such as a hotel, apartment house, or similar multiunit dwelling.'" 221 Kan. at 259 .

2022He cites State v. Gordon, 221 Kan. 253, 259 , 559 P.2d 312 (1977), which held that "a search warrant directed against a multiple occupancy structure generally will be held invalid if it fails to describe the particular room or subunit to be searched with sufficient definiteness to preclude a search of other units." But Hillard's reliance on Gordon is misplaced because 1310 S. Meridian Street is not a multiple occupancy structure—that is, it is not "'a structure divided into more than 44 one occupancy unit such as a hotel, apartment house, or similar multiunit dwelling.'" 221 Kan. at 259 .

12022–2022
State v. Patterson green
kan · 2016
1 sentence

2022To satisfy the Fourth Amendment's particularity requirement, "'the search warrant must describe the premises to be searched with sufficient particularity to permit the executing officer to locate the same from the face of the warrant.'" Patterson, 304 Kan. at 275 .

12022–2022
Stanford v. Texas green
scotus · 1965
2 sentences

1992Stanford v. Texas, 379 U.S. 476 , 13 L.

1992Stanford v. Texas, 379 U.S. 476 , 13 L.

11992–1992
State v. Zirkle green
kanctapp · 1991
1 sentence

1992See State v. Reed, 248 Kan. 792 , 811 P.2d 1163 (1991) (reversal of district court’s invalidation of K.S.A. 1989 Supp. 21-4603(3)(a) as violative of separation of powers doctrine); State v. Zirkle, 15 Kan.

11992–1992
United States v. Ludger Vance Clement green
ca8 · 1984
2 sentences

1992In United States v. Clement, 747 F.2d 460 (8th Cir. 1984), the search warrant described the premises to be searched as “ ‘apartment of Vance Clements, No. 4 at 3300 Irvine Avenue.’ ” 747 F.2d at 461 .

1992In United States v. Clement, 747 F.2d 460 (8th Cir. 1984), the search warrant described the premises to be searched as “ ‘apartment of Vance Clements, No. 4 at 3300 Irvine Avenue.’ ” 747 F.2d at 461 .

11992–1992
State v. Grimsley green
kanctapp · 1991
1 sentence

1992App. 2d 441 , 808 P.2d 1387 (1991), we applied K.S.A. 1990 Supp. 21-4603(4)(a) without expressly discussing the particularity requirement.

11992–1992
State v. Kyles green
la · 1987
1 sentence

1992The court said: “Under these circumstances, there was little probability that the wrong place would be searched, and there was no violation of the particularity requirement.” 513 So. 2d at 270 .

11992–1992

Statutes the citing opinions construe

KS § K.S.A. § 22-3716 (7) KS § K.S.A. § 60-209 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

CA 108 (1925–2026) WA 73 (1980–2025) NC 72 (1972–2026) OH 71 (1987–2026) TX 63 (1991–2026) OR 53 (1979–2026) PA 49 (1982–2026) FL 48 (1983–2024) DE 47 (1990–2026) NY 43 (1985–2025) MA 42 (1976–2026) WI 37 (1975–2025) GA 35 (1907–2026) MI 33 (1988–2026) CO 29 (1982–2026) TN 25 (1998–2021) IL 24 (1978–2025) MD 23 (1983–2024) IN 23 (1984–2026) CT 23 (1986–2026) MO 21 (1980–2021) NJ 20 (1976–2026) MN 20 (1989–2026) UT 19 (1990–2026) NM 18 (1960–2025) LA 17 (1977–2020) IA 17 (1981–2025) KS 16 (1992–2026) ID 13 (1987–2017) ND 13 (1984–2021) AZ 13 (1985–2022) RI 11 (1983–2023) AL 10 (1985–2018) HI 9 (1980–2020) MT 9 (1991–2021) AK 8 (1973–2025) VA 8 (1992–2026) NE 8 (2014–2025) WY 6 (1974–2025) KY 6 (2007–2015) NV 5 (2015–2025) NH 5 (1990–2019) SC 5 (2005–2023) OK 5 (1990–2015) VI 4 (1980–2026) DC 4 (1992–2026) VT 4 (1985–2024) AR 3 (2019–2026) WV 3 (1988–2026) MS 3 (2011–2020) SD 2 (2000–2008) ME 2 (2020–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

← Caselaw search · G Cite Topics · Brief Check