K.S.A. » Chapter 22
Kansas Statutes Annotated

K.S.A. § 22-2501 (2026)

✓ current as of May 2026
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22-2501.

History: L. 1970, ch. 129, § 22-2501; Revived and amended, L. 2006, ch. 211, § 8; Repealed, L. 2011, ch. 100, § 22; July 1.

Notes of Decisions
Cited in 60 cases, 1972–2020 · leading case: State v. James, 349 P.3d 457 (Kan. 2015).
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State v. James, 349 P.3d 457 (Kan. 2015). · cites it 28× “In 1970, Kansas codified the scope of a lawful warrantless search incident to arrest at K.S.A. 1970 Supp. 22-2501: “When a lawful arrest is effected a law enforcement officer may reasonably search the person arrested and the area within such person’s immediate presence for the…”
State v. Henning, 209 P.3d 711 (Kan. 2009). · cites it 26× “Chief Justice McFarland then reviewed the language of K.S.A. 22-2501 and addressed the State’s argument that the statute had been intended to codify federal law enunciated in Chimel v.”
State v. Conn, 99 P.3d 1108 (Kan. 2004). · cites it 22× “K.S.A. 22-2501 provides: "When a lawful arrest is effected a law enforcement officer may reasonably search the person arrested and the area within such person's immediate presence for the purpose of "(a) Protecting the officer from attack; "(b) Preventing the person from…”
State v. Davison, 202 P.3d 44 (Kan. Ct. App. 2009). · cites it 59× “Before the district court, the defendant asserted the search was controlled by K.S.A. 22-2501, which is Kansas' provision for searches incident to arrest.”
State v. Dennis, 300 P.3d 81 (Kan. 2013). · cites it 33× “The question is whether an objectively reasonable officer could rely on K.S.A. 22-2501.”
State v. Pettay, 326 P.3d 1039 (Kan. 2014). · cites it 26× “2114 (2011) (allowing evidence obtained based on officer’s objectively reasonable reliance on constitutionality of K.S.A. 22-2501[c]); see also State v. Carlton, 297 Kan.”
State v. Henning, 171 P.3d 660 (Kan. Ct. App. 2007). · cites it 51× “Stevenson testified that he searched Henning’s car as a search incident to arrest under K.S.A. 2006 Supp. 22-2501. Stevenson noted that he knew 22-2501 had been amended effective July 1, 2006, to allow him to search for fruits of a crime in a car where an arrestee had been.”
State v. Oram, 266 P.3d 1227 (Kan. Ct. App. 2011). · cites it 49× “K.S.A. 22-2501 defines the parameters of police authority to conduct a search incident to arrest.”
State v. Karson, 304 P.3d 317 (Kan. 2013). · cites it 16× “The State concedes the search was illegal under Gant but asserts we do not need to decide this case because Karson died while the appeal was pending.”
State v. Schmidt, 385 P.3d 936 (Kan. Ct. App. 2016). · cites it 5× “But Pettay is distinguishable because the law enforcement officer in that case searched the vehicle after the driver had been handcuffed and placed in the backseat of a patrol car.”
State v. Carlton, 304 P.3d 323 (Kan. 2013). · cites it 14× “2d 364 (1987), was misplaced because that case dealt with administrative searches, not criminal *645 searches; and (3) the panel majority should have applied the former version of K.S.A. 22-2501 in light of the Henning decision.”
State v. Anderson, 910 P.2d 180 (Kan. 1996). · cites it 9× “K.S.A. 22-2501 sets forth the circumstances under which a search incident to arrest may be made as follows: “When a lawful arrest is effected a law enforcement officer may reasonably search the person arrested and the area within such person s immediate presence for the purpose…”
Show all 60 citing cases →
— K.S.A. § 22-2501(a) — 2 cases
State v. Box, 17 P.3d 386 (Kan. Ct. App. 2000).
State v. Julian, 333 P.3d 172 (Kan. 2014).
— K.S.A. § 22-2501(b) — 1 case
State v. Vandevelde, 138 P.3d 771 (Kan. Ct. App. 2006).
— K.S.A. § 22-2501(c) — 20 cases
State v. Henning, 209 P.3d 711 (Kan. 2009). “Chief Justice McFarland then reviewed the language of K.S.A. 22-2501 and addressed the State’s argument that the statute had been intended to codify federal law enunciated in Chimel v.”
State v. Dennis, 300 P.3d 81 (Kan. 2013). “The question is whether an objectively reasonable officer could rely on K.S.A. 22-2501.”
State v. Conn, 99 P.3d 1108 (Kan. 2004). “K.S.A. 22-2501 provides: "When a lawful arrest is effected a law enforcement officer may reasonably search the person arrested and the area within such person's immediate presence for the purpose of "(a) Protecting the officer from attack; "(b) Preventing the person from…”
State v. Henning, 171 P.3d 660 (Kan. Ct. App. 2007). “Stevenson testified that he searched Henning’s car as a search incident to arrest under K.S.A. 2006 Supp. 22-2501. Stevenson noted that he knew 22-2501 had been amended effective July 1, 2006, to allow him to search for fruits of a crime in a car where an arrestee had been.”
State v. Karson, 304 P.3d 317 (Kan. 2013). “The State concedes the search was illegal under Gant but asserts we do not need to decide this case because Karson died while the appeal was pending.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.