multiple violation (Kansas) · Go Syfert
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multiple violation in Kansas

7 Kansas opinions name it 2 courts 1984–2025 1 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 (5)

CaseFollowedCited
State v. Dickeygreen
kan · 2015 · cited in 1 Kansas opinions naming this issue, 2025–2025
2 sentences

2025Multiple defendants shall each pay one fee." (Emphasis added.) • Under K.S.A. 2023 Supp. 32-1049a, regarding failure to comply with a wildlife and parks citation: "(d) Except as provided in subsection (e), when the district court notifies the department of a failure to comply with a wildlife and parks citation or failure to comply with a sentence of the district court imposed on violation of a wildlife and parks law or rule and regulation, the court shall assess a reinstatement fee of $50 for each charge or sentence on which the person failed to make satisfaction, regardless of the disposition

2025Multiple defendants shall each pay one fee." (Emphasis added.) • Under K.S.A. 2023 Supp. 32-1049a, regarding failure to comply with a wildlife and parks citation: "(d) Except as provided in subsection (e), when the district court notifies the department of a failure to comply with a wildlife and parks citation or failure to comply with a sentence of the district court imposed on violation of a wildlife and parks law or rule and regulation, the court shall assess a reinstatement fee of $50 for each charge or sentence on which the person failed to make satisfaction, regardless of the disposition

11
State v. Goellergreen
kan · 2003 · cited in 1 Kansas opinions naming this issue, 2025–2025
2 sentences

2025Multiple defendants shall each pay one fee." (Emphasis added.) • Under K.S.A. 2023 Supp. 32-1049a, regarding failure to comply with a wildlife and parks citation: "(d) Except as provided in subsection (e), when the district court notifies the department of a failure to comply with a wildlife and parks citation or failure to comply with a sentence of the district court imposed on violation of a wildlife and parks law or rule and regulation, the court shall assess a reinstatement fee of $50 for each charge or sentence on which the person failed to make satisfaction, regardless of the disposition

2025Multiple defendants shall each pay one fee." (Emphasis added.) • Under K.S.A. 2023 Supp. 32-1049a, regarding failure to comply with a wildlife and parks citation: "(d) Except as provided in subsection (e), when the district court notifies the department of a failure to comply with a wildlife and parks citation or failure to comply with a sentence of the district court imposed on violation of a wildlife and parks law or rule and regulation, the court shall assess a reinstatement fee of $50 for each charge or sentence on which the person failed to make satisfaction, regardless of the disposition

11
Allen v. Kansas Department of Social & Rehabilitation Servicesgreen
kan · 1987 · cited in 1 Kansas opinions naming this issue, 2019–2019
1 sentence

2019See Allen[ v. Kansas Dept. of S.R.S.], 240 Kan. [620,] 623, [ 731 P.2d 314 (1987)] (employee's action not discretionary when decision on how to clean vomit from floor did 'not invol[ve] any particular skill or training').

11
State v. Catheygreen
kan · 1987 · cited in 1 Kansas opinions naming this issue, 1992–1992
2 sentences

1992See State v. Cathey, 241 Kan. 715, 718-19 , 741 P.2d 738 (1987). *178 In State v. Freeman, 236 Kan. 274, 281-82 , 689 P.2d 885 (1984), this court stated: “K.S.A. 1983 Supp. 21-3107 provides statutory authority where criminal conduct of a defendant, although consisting of a single transaction, may result in a multiple violation of the criminal code, for which the defendant may be severally prosecuted. [Citation omitted.] The prosecution may not split a single offense into separate parts where there is a single wrongful act which does not furnish the basis for more than one criminal prosecution.

1992See State v. Cathey, 241 Kan. 715, 718-19 , 741 P.2d 738 (1987). *178 In State v. Freeman, 236 Kan. 274, 281-82 , 689 P.2d 885 (1984), this court stated: “K.S.A. 1983 Supp. 21-3107 provides statutory authority where criminal conduct of a defendant, although consisting of a single transaction, may result in a multiple violation of the criminal code, for which the defendant may be severally prosecuted. [Citation omitted.] The prosecution may not split a single offense into separate parts where there is a single wrongful act which does not furnish the basis for more than one criminal prosecution.

11
State v. Freemangreen
kan · 1984 · cited in 1 Kansas opinions naming this issue, 1992–1992
2 sentences

1992See State v. Cathey, 241 Kan. 715, 718-19 , 741 P.2d 738 (1987). *178 In State v. Freeman, 236 Kan. 274, 281-82 , 689 P.2d 885 (1984), this court stated: “K.S.A. 1983 Supp. 21-3107 provides statutory authority where criminal conduct of a defendant, although consisting of a single transaction, may result in a multiple violation of the criminal code, for which the defendant may be severally prosecuted. [Citation omitted.] The prosecution may not split a single offense into separate parts where there is a single wrongful act which does not furnish the basis for more than one criminal prosecution.

1992See State v. Cathey, 241 Kan. 715, 718-19 , 741 P.2d 738 (1987). *178 In State v. Freeman, 236 Kan. 274, 281-82 , 689 P.2d 885 (1984), this court stated: “K.S.A. 1983 Supp. 21-3107 provides statutory authority where criminal conduct of a defendant, although consisting of a single transaction, may result in a multiple violation of the criminal code, for which the defendant may be severally prosecuted. [Citation omitted.] The prosecution may not split a single offense into separate parts where there is a single wrongful act which does not furnish the basis for more than one criminal prosecution.

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 (4)

CaseCitedYears
State v. Pencek green
kan · 1978
2 sentences

1998State v. Pencek, 224 Kan. 725 , Syl. ¶ 2, 585 P.2d 1052 (1978).

1998State v. Pencek, 224 Kan. 725 , Syl. ¶ 2, 585 P.2d 1052 (1978).

21984–1998
State v. Russell green
kan · 1980
1 sentence

2020(Emphases added.) Russell, 227 Kan. at 900 .

12020–2020
Wagner v. Edmondson green
kan · 1955
2 sentences

2006The Freeman court stated the test for multiplicity, citing as authority for the test State v. Chears, 231 Kan. 161 , 643 P.2d 154 (1982) (postdating enactment of K.S.A. 21-3107), which cited to Wagner v. Edmondson, 178 Kan. 554 , 290 P.2d 98 (1955) (predating enactment of K.S.A. 21-3107): “K.S.A. 1983 Supp. 21-3107 provides statutory authority where criminal conduct of a defendant, although consisting of a single transaction, may result in a multiple violation of the criminal code, for which tire defendant may be severally prosecuted. [Citation omitted].

2006The Freeman court stated the test for multiplicity, citing as authority for the test State v. Chears, 231 Kan. 161 , 643 P.2d 154 (1982) (postdating enactment of K.S.A. 21-3107), which cited to Wagner v. Edmondson, 178 Kan. 554 , 290 P.2d 98 (1955) (predating enactment of K.S.A. 21-3107): “K.S.A. 1983 Supp. 21-3107 provides statutory authority where criminal conduct of a defendant, although consisting of a single transaction, may result in a multiple violation of the criminal code, for which tire defendant may be severally prosecuted. [Citation omitted].

12006–2006
State v. Chears green
kan · 1982
2 sentences

2006The Freeman court stated the test for multiplicity, citing as authority for the test State v. Chears, 231 Kan. 161 , 643 P.2d 154 (1982) (postdating enactment of K.S.A. 21-3107), which cited to Wagner v. Edmondson, 178 Kan. 554 , 290 P.2d 98 (1955) (predating enactment of K.S.A. 21-3107): “K.S.A. 1983 Supp. 21-3107 provides statutory authority where criminal conduct of a defendant, although consisting of a single transaction, may result in a multiple violation of the criminal code, for which tire defendant may be severally prosecuted. [Citation omitted].

2006The Freeman court stated the test for multiplicity, citing as authority for the test State v. Chears, 231 Kan. 161 , 643 P.2d 154 (1982) (postdating enactment of K.S.A. 21-3107), which cited to Wagner v. Edmondson, 178 Kan. 554 , 290 P.2d 98 (1955) (predating enactment of K.S.A. 21-3107): “K.S.A. 1983 Supp. 21-3107 provides statutory authority where criminal conduct of a defendant, although consisting of a single transaction, may result in a multiple violation of the criminal code, for which tire defendant may be severally prosecuted. [Citation omitted].

12006–2006

Statutes the citing opinions construe

KS § K.S.A. § 21-3107 (4)

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

IA 20 (1991–2024) CA 16 (1971–2026) IL 13 (2015–2025) NC 11 (1979–2010) OH 9 (1990–2026) TX 8 (2012–2025) PA 8 (1979–2025) MI 8 (1983–2023) KS 7 (1984–2025) NJ 7 (1995–2021) WA 7 (1996–2026) DC 6 (1982–2025) IN 5 (1999–2017) MN 5 (1986–2017) MD 5 (1997–2012) DE 5 (1967–2020) ID 5 (1984–2020) NM 4 (1988–2015) HI 4 (1966–2014) FL 4 (1994–2018) CT 4 (1988–2008) LA 4 (2011–2022) NY 4 (1976–2004) WY 3 (1979–2007) AR 3 (2005–2025) RI 2 (2012–2012) AK 2 (1975–1991) NV 2 (2020–2022) VT 2 (1999–1999) KY 2 (1981–2024) SD 2 (1977–1985) GA 2 (2008–2009) CO 2 (1998–2012) ND 2 (1970–1975)

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.

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