Kansas Statutes Annotated

K.S.A. § 20-1201 (2026)

Two classes of contempts

✓ current as of May 2026
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20-1201. Two classes of contempts. That contempts of court are divided into two classes, direct and indirect, and shall be proceeded against only as hereinafter prescribed.

History: L. 1897, ch. 106, § 1; May 8; R.S. 1923, 20-1201.

Notes of Decisions
Cited in 21 cases (1 in the last 5 years), 1983–2021 · leading case: State v. Jenkins, 950 P.2d 1338 (Kan. 1997).
State v. Jenkins, 950 P.2d 1338 (Kan. 1997). · cites it 15× “Johnson’s sanctions were entered under what the district court characterized as its inherent power, not under K.S.A. 20-1201 et seq., the statutory contempt procedure.”
State v. Delacruz, 411 P.3d 1207 (Kan. 2018). · cites it 2× “"No inherent power to punish for contempt exists independent of K.S.A. 20-1201 et seq ." State v. Jenkins , 263 Kan.”
In the Interest of M.R., 38 P.3d 694 (Kan. 2002). · cites it 7× “There, this court considered the inherent power to punish for contempt of court as an alternative to the statutory authority of a court to initiate contempt proceedings granted in K.S.A. 20-1201 et seq., and stated: “The power to punish for contempt of court does not arise from…”
Pork Motel, Corp. v. Kansas Dep't of Health & Env't, 673 P.2d 1126 (Kan. 1983). · cites it 2× “The statutory direction for finding one in contempt in this case is found in K.S.A. 20-1201 et seq. The procedure followed to obtain valid service must conform with that procedure prescribed in Chapter 20.”
In re Interest of J.T.R., 271 P.3d 1262 (Kan. Ct. App. 2012). · cites it 3× “This inherent authority has now been procedurally regulated in Kansas by the enactment of K.S.A. 20-1201 et seq. In fact, our Supreme Court has ruled, “If the district court imposes sanctions for contempt of court, the procedure under K.”
In re Care & Treatment of Saiz, 492 P.3d 484 (Kan. Ct. App. 2021). · cites it 2× “K.S.A. 20-1201 et seq. A court may sanction the failure to comply with an order in a civil case through the indirect contempt of court procedure set out in K.”
Byrd v. Kansas Dep't of Revenue, 221 P.3d 1168 (Kan. Ct. App. 2010). · cites it 2× “60-204), K.S.A. 20-1201 et seq. contained no similar provisions.”
Am. Trust Administrators, Inc. v. Sebelius, 981 P.2d 248 (Kan. 1999). · cites it 2× “Contempt orders are governed by K.S.A. 20-1201 et seq.; K.S.A. 20-1205, which governs appeals, provides: "The testimony taken on the trial of any accusation of contempt shall be preserved.”
Sramek v. Sramek, 840 P.2d 553 (Kan. Ct. App. 1992). “2d 1126 (1983), the Kansas Supreme Court ruled: “The statutory direction for finding one in contempt in this casé is found in K.S.A. 20-1201 et seq. The procedure followed to obtain valid service must conform with that procedure prescribed in Chapter 20 of the Kansas Statutes…”
State v. Flanagan, 873 P.2d 195 (Kan. Ct. App. 1994). “” K.S.A. 20-1201 divides contempt in two classes, “direct” and “indirect.”
State v. Delacruz, 364 P.3d 557 (Kan. Ct. App. 2015). · cites it 2× “K.S.A. 20-1201 et seq. governs contempt. In fact, “[n]o inherent power to punish for contempt exists independent of K.”
State v. Miller, 811 P.2d 1256 (Kan. Ct. App. 1991). “K.S.A. 20-1201 et seq. Under the present language found in K.”
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