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

K.S.A. § 22-2603 (2026)

Crime committed in more than one county

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22-2603. Crime committed in more than one county. Where two or more acts are requisite to the commission of any crime and such acts occur in different counties the prosecution may be in any county in which any of such acts occur.

History: L. 1970, ch. 129, § 22-2603; July 1.

Notes of Decisions
Cited in 36 cases (5 in the last 5 years), 1978–2025 · leading case: State v. Hillard, 511 P.3d 883 (Kan. 2022).
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State v. Hillard, 511 P.3d 883 (Kan. 2022). · cites it 8× “And under K.S.A. 22-2603, where two or more acts are requisite to the commission of any crime and such acts occur in different counties the prosecution may be in any county in which any of such acts occur.”
State v. Robinson, 363 P.3d 875 (Kan. 2015). · cites it 8× “Relevant to this case is K.S.A. 22-2603, which provides "[w]here two or more acts are requisite to the commission of any crime and such acts occur in different counties the prosecution may be in any county in which any of such acts occur," and K.”
State v. Schroeder, 105 P.3d 1237 (Kan. 2005). · cites it 8× “The court discussed three venue statutes: K.S.A. 22-2603, which governs crimes committed in more than one county and provides for prosecution of such crimes in any county in which a constituent criminal act or element of the crime had occurred; K.”
State v. Calderon, 661 P.2d 781 (Kan. 1983). · cites it 6× “An exception to this rule appears in K.S.A. 22-2603, which states: "Where two or more acts are requisite to the commission of any crime and such acts occur in different counties the prosecution may be in any county in which any of such acts occur.”
Kansas v. McElroy, 130 P.3d 100 (Kan. 2006). · cites it 3× “, Shawnee County, and no acts requisite to the commission of the crime occurred in Sedgwick County under K.S.A. 22-2603 (“Where two or more acts are requisite to the commission of any crime and such acts occur in different counties the prosecution may be in any county in which…”
State v. Boorigie, 41 P.3d 764 (Kan. 2002). · cites it 3× “Counts 9 and 10 of the amended complaint charged Boorigie, while in custody for the Montgomery County crime, with criminally soliciting Thomas and Espe in Elk County, Kansas. Generally, venue lies in the county where a criminal act occurs.”
State v. Castleberry, 339 P.3d 795 (Kan. 2014). · cites it 2× “” Under K.S.A. 22-2603, “[w]here two or more acts are requisite to the commission of any crime and such acts occur in different counties the prosecution may be in any county in which any of such acts occur.”
State v. Duvaul, 576 P.2d 653 (Kan. 1978). · cites it 5× “His principal contentions on appeal concern the constitutionality of the venue statute (K.S.A. 22-2603) and alleged misconduct by the prosecutors during the trial and closing argument.”
State v. Kendall, 331 P.3d 763 (Kan. 2014). · cites it 2× “But, when two or more acts are requisite to the commission of the crime charged and such acts occur in different counties, K.S.A. 22-2603 authorizes the State to prosecute the crime “in any county in which any of such acts occur.”
State v. Cuezze, Houston & Faltico, 589 P.2d 626 (Kan. 1979). · cites it 2× “The State contends venue of Count III lay in either Wyandotte or Shawnee County under K.S.A. 22-2603, which provides: "Where two or more acts are requisite to the commission of any crime and such acts occur in different counties the prosecution may be in any county in which any…”
State v. Grissom, 840 P.2d 1142 (Kan. 1992). “” A broad interpretation of the territorial jurisdiction statute is consistent with our venue statutes. Although jurisdiction and venue are different, an analogy can be made to the venue statutes.”
State v. Womelsdorf, 274 P.3d 662 (Kan. Ct. App. 2012). · cites it 2× “” Based on the evidence, Womelsdorf argues that the proper venue for the offense of committing a fraudulent insurance act was only in Johnson County and not Anderson County. Under K.”
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