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Kansas Statutes Annotated

K.S.A. § 21-3209 (2026)

✓ current as of May 2026
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21-3209.

History: L. 1969, ch. 180, § 21-3209; Repealed, L. 2010, ch. 136, § 307; July 1, 2011.

Notes of Decisions
Cited in 36 cases, 1978–2014 · leading case: State v. Ottinger, 264 P.3d 1027 (Kan. Ct. App. 2011).
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State v. Ottinger, 264 P.3d 1027 (Kan. Ct. App. 2011). · cites it 7× “Generally, the compulsion defense is a recognized statutory defense in Kansas under limited circumstances stated in K.S.A. 21-3209: “(1) A person is not guilty of a crime other than murder or voluntary manslaughter by reason of conduct which he performs under the compulsion or…”
State v. Anderson, 197 P.3d 409 (Kan. 2008). · cites it 3× “” The legislature has addressed the defense of compulsion in K.S.A. 21-3209, which states: “(1) A person is not guilty of a crime other than murder or voluntary manslaughter by reason of conduct which he performs under the compulsion or threat of the imminent infliction of death…”
State v. Hunter, 740 P.2d 559 (Kan. 1987). · cites it 3× “K.S.A. 21-3209 provides *640 for the defense of compulsion to crimes other than murder or manslaughter, stating: (1) “A person is not guilty of a crime other than murder or voluntary manslaughter by reason of conduct which he performs under the compulsion or threat of the…”
State v. Davis, 883 P.2d 735 (Kan. 1994). · cites it 4× “21-3209: “(1) A person is not guilty of a crime other than murder or volunta^ manslaughter by reason of conduct which he performs under the compulsion or threat of the imminent infliction of death or great bodily harm, if he reasonably believes that death or great bodily harm…”
State v. Baker, 197 P.3d 421 (Kan. 2008). · cites it 3× “21-3209, which states: “(1) A person is not guilty of a crime other than murder or voluntary manslaughter by reason of conduct which he performs under the compulsion or threat of the imminent infliction of death or great bodily harm, if he reasonably believes that death or great…”
State v. Dunn, 758 P.2d 718 (Kan. 1988). · cites it 2× “K.S.A. 21-3209 provides: “Compulsion. (1) A person is not guilty of a crime other than murder or voluntary manslaughter by reason of conduct which he performs under the compulsion or threat of the imminent infliction of death or great bodily harm, if he reasonably believes that…”
State v. Littlejohn, 316 P.3d 136 (Kan. 2014). · cites it 2× “13, which in turn is based on K.S.A. 21-3209. That statute states: “(1) A person is not guilty of a crime other than murder or voluntary manslaughter by reason of conduct which he performs under the compulsion or threat of the imminent infliction of death or great bodily harm,…”
State v. Schreiner, 264 P.3d 1033 (Kan. Ct. App. 2011). · cites it 2× “See K.S.A. 21-3209. As defined in Kansas, compulsion requires a defendant be found not guilty of a crime other than murder or manslaughter if he or she commits the offense based on a reasonable belief that a threat of imminent physical harm or death will be carried out against…”
State v. Jackson, 118 P.3d 1238 (Kan. 2005). · cites it 2× “21-3209, which provides: “(1) A person is not guilty of a crime other than murder or voluntary manslaughter by reason of conduct which he performs under the compulsion or threat of the imminent infliction of death or great bodily harm, if he reasonably believes that death or…”
State v. Myers, 664 P.2d 834 (Kan. 1983). · cites it 4× “On September 10, 1979, Cristel Watson and her sister, Elke McGuyton, shared an apartment in Manhattan, Kansas, where Cristel was a student at Kansas State University.”
State v. Pichon, 811 P.2d 517 (Kan. Ct. App. 1991). · cites it 4× “The defense of compulsion is set forth at K.S.A. 21-3209. That statute states: “(1) A person is not guilty of a crime other than murder or voluntary manslaughter by reason of conduct which he performs under the compulsion or threat of the imminent infliction of death or great…”
State v. Matson, 921 P.2d 790 (Kan. 1996). · cites it 2× “K.S.A. 21-3209 sets forth the defense of compulsion: “(1) A person is not guilty of a crime other than murder or voluntary manslaughter by reason of conduct which he performs under the compulsion or threat of the imminent infliction of death or great bodily harm, if he…”
Show all 36 citing cases →
— K.S.A. § 21-3209(1) — 7 cases
State v. Ottinger, 264 P.3d 1027 (Kan. Ct. App. 2011). “Generally, the compulsion defense is a recognized statutory defense in Kansas under limited circumstances stated in K.S.A. 21-3209: “(1) A person is not guilty of a crime other than murder or voluntary manslaughter by reason of conduct which he performs under the compulsion or…”
State v. Anderson, 197 P.3d 409 (Kan. 2008). “” The legislature has addressed the defense of compulsion in K.S.A. 21-3209, which states: “(1) A person is not guilty of a crime other than murder or voluntary manslaughter by reason of conduct which he performs under the compulsion or threat of the imminent infliction of death…”
State v. Davis, 883 P.2d 735 (Kan. 1994). “21-3209: “(1) A person is not guilty of a crime other than murder or volunta^ manslaughter by reason of conduct which he performs under the compulsion or threat of the imminent infliction of death or great bodily harm, if he reasonably believes that death or great bodily harm…”
City of Wichita v. Tilson, 855 P.2d 911 (Kan. 1993).
State v. Greene, 623 P.2d 933 (Kan. Ct. App. 1981).
— K.S.A. § 21-3209(2) — 4 cases
State v. Davis, 883 P.2d 735 (Kan. 1994). “21-3209: “(1) A person is not guilty of a crime other than murder or volunta^ manslaughter by reason of conduct which he performs under the compulsion or threat of the imminent infliction of death or great bodily harm, if he reasonably believes that death or great bodily harm…”
State v. Anderson, 197 P.3d 409 (Kan. 2008). “” The legislature has addressed the defense of compulsion in K.S.A. 21-3209, which states: “(1) A person is not guilty of a crime other than murder or voluntary manslaughter by reason of conduct which he performs under the compulsion or threat of the imminent infliction of death…”
State v. Scott, 827 P.2d 733 (Kan. 1992).
State v. Crawford, 861 P.2d 791 (Kan. 1993).
— K.S.A. § 21-3209(a) — 1 case
State v. Jackson, 118 P.3d 1238 (Kan. 2005). “21-3209, which provides: “(1) A person is not guilty of a crime other than murder or voluntary manslaughter by reason of conduct which he performs under the compulsion or threat of the imminent infliction of death or great bodily harm, if he reasonably believes that death or…”
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