Kansas Statutes Annotated

K.S.A. § 22-2521 (2026)

Limitations on strip searches; probable cause requirement; report

✓ current as of May 2026
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22-2521. Limitations on strip searches; probable cause requirement; report. (a) No person detained or arrested solely for the violation of a statute, resolution or ordinance involving a traffic, regulatory or nonviolent misdemeanor offense shall be strip searched unless there is probable cause to believe that the individual is concealing a weapon or controlled substance.

(b) Every strip search conducted by law enforcement officers or employees of a law enforcement agency or department shall be conducted by persons of the same sex as the person being searched and shall be conducted so that the search cannot be observed by any person other than the persons conducting the search, unless the right to privacy is waived by the person being searched.

(c) Every law enforcement officer or employee of a law enforcement agency or department conducting a strip search shall prepare a report of the strip search. The report shall include:

(1) The name and sex of the person searched;

(2) the name and sex of the persons conducting the search;

(3) the time, date and place of the search; and

(4) a statement of the results of the search.

History: L. 1981, ch. 149, § 2; July 1.

Notes of Decisions
Cited in 10 cases (2 in the last 5 years), 1991–2025 · leading case: McCormick v. City of Lawrence, 104 P.3d 991 (Kan. 2005).
McCormick v. City of Lawrence, 104 P.3d 991 (Kan. 2005). · cites it 14× “McCormick sued the City of Lawrence (City) and various police officers for violating the strip and body caviiy search statutes, K.S.A. 22-2521 and K.S.A. 22-2522, which are made actionable by K.”
Cook v. Olathe Med. Ctr., Inc., 773 F. Supp. 2d 990 (D. Kan. 2011). · cites it 9× “Plaintiff asserts that her battery claims are based on K.S.A. §§ 22-2521 and 22-2522. Those statutes set forth requirements for strip searches and body cavity searches.”
Florence v. Bd. of Chosen Freeholders of Cnty. of Burlington, 132 S. Ct. 1510 (2012). “or contraband”); Kan. Stat. Ann. §22-2521 (a) (2007) (similar); Iowa Code §804.”
State v. Thomas, 12 P.3d 420 (Kan. Ct. App. 2000). · cites it 8× “22-2524(b), which states: “The provisions of this act relating to strip searches other than subsection (b) of K.S.A. 22-2521 [requiring strip searches be conducted by members of the same sex as tire person being searched] shall not apply when a person accused of a crime is…”
Allen v. Bd. of Com'rs of Cnty. of Wyandotte, 773 F. Supp. 1442 (D. Kan. 1991). · cites it 4× “19, 1990) (violation of K.S.A. 22-2521 does not establish strip search was unconstitutional).”
Burnett v. Sw. Bell Tel., L.P., 151 P.3d 837 (Kan. 2007). “There, the court considered whether a violation of the strip and body search statutes, K.S.A. 22-2521 through 22-2523, was subject to the 3-year statute of limitations under K.”
Eastman v. Coffeyville Resources Refining & Mktg. LLC, 284 P.3d 1049 (Kan. 2012). “at 804, 806-07 (concluding K.S.A. 22-2521 and K.S.A. 22-2522 created substantive rights not recognized at common law because “although one can imagine several common-law tort claims which might be brought based upon tire facts alleged in this case .”
McCormick v. City of Lawrence, 89 P.3d 657 (Kan. Ct. App. 2004). · cites it 4× “McCormick presents this court with a detailed argument concerning the applicable statute of limitations.”
Wood v. Wichita Police Dep't (D. Kan. 2025). “22-2302(b); and K.S.A. 22-2521. (Doc. 1, p. 4.) He claims that the WPD issued him a citation without probable cause and arrested him; the Municipal Court issued a warrant without probable cause and denied him due process; the SCSO arrested him without a lawful warrant; and the…”
Wood (D. Kan. 2025). “22-2302(b); and K.S.A. 22-2521. (Doc. 1, p. 4.) He claims that the WPD issued him a citation without probable cause and arrested him; the Municipal Court issued a warrant without probable cause and denied him due process; the SCSO arrested him without a lawful warrant; and the…”
— K.S.A. § 22-2521(a) — 2 cases
Allen v. Bd. of Com'rs of Cnty. of Wyandotte, 773 F. Supp. 1442 (D. Kan. 1991). “19, 1990) (violation of K.S.A. 22-2521 does not establish strip search was unconstitutional).”
State v. Thomas, 12 P.3d 420 (Kan. Ct. App. 2000). “22-2524(b), which states: “The provisions of this act relating to strip searches other than subsection (b) of K.S.A. 22-2521 [requiring strip searches be conducted by members of the same sex as tire person being searched] shall not apply when a person accused of a crime is…”
— K.S.A. § 22-2521(b) — 1 case
McCormick v. City of Lawrence, 104 P.3d 991 (Kan. 2005). “McCormick sued the City of Lawrence (City) and various police officers for violating the strip and body caviiy search statutes, K.S.A. 22-2521 and K.S.A. 22-2522, which are made actionable by K.”
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