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

K.S.A. § 22-2604 (2026)

Crime committed on or near county boundary

✓ current as of May 2026
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22-2604. Crime committed on or near county boundary. Where a crime is committed on or so near the boundary of two or more counties that it cannot be readily determined in which county the crime was committed, the prosecution may be in any of such counties.

History: L. 1970, ch. 129, § 22-2604; July 1.

Notes of Decisions
Cited in 10 cases (3 in the last 5 years), 1992–2026 · leading case: State v. Rivera, 219 P.3d 1231 (Kan. Ct. App. 2009).
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State v. Rivera, 219 P.3d 1231 (Kan. Ct. App. 2009). · cites it 12× “So the State asked the district court to give the jury an instruction based on K.S.A. 22-2604, which provides that when a crime is committed so near the boundary between two counties that it can't be readily determined in which county the crime occurred, the State may prosecute…”
State v. Grissom, 840 P.2d 1142 (Kan. 1992). “For example, if a crime is committed in two counties, either county has venue. K.S.A. 22-2603. If a crime is committed on or so near the boundary of two counties that it cannot be determined in which county the crime occurred, either county has venue.”
State v. Voyles, 116 P.3d 720 (Kan. Ct. App. 2005). · cites it 2× “22-2603, K.S.A. 22-2604, or K.S.A. 22-2608. We conclude that posttrial arguments challenging venue as to some of the acts alleged do not establish a legally separate defense for purposes of requiring that a unanimity instruction be given.”
State v. Lundberg, 391 P.3d 49 (Kan. Ct. App. 2017). “K.S.A. 22-2604. If the cause of death is inflicted in one county and the victim dies in another county, either county has venue.”
State v. Barnes, 563 P.3d 1255 (Kan. 2025). “Proper venue does not establish jurisdiction, and improper venue does not defeat jurisdiction. On the other hand, venue can only be proper where jurisdiction already exists.”
In re J.W.S., 825 P.2d 125 (Kan. 1992). “” K.S.A. 22-2604: “Where a crime is committed on or so near the boundary of two or more counties that it cannot be readily determined in which county the crime was committed, the prosecution may be in any of such counties.”
State v. Merrill, 551 P.3d 202 (Kan. Ct. App. 2024). “K.S.A. 22-2604." 251 Kan. at 889 . Here, the district court was faced with the question of whether Merrill's criminal conduct occurred in Kansas, in Missouri, or in both states.”
State v. Prickett (Kan. Ct. App. 2026). · cites it 3× “" The State argues that venue was proper in Sedgwick County because Cheney Lake borders multiple counties and K.S.A. 22-2604 and K.S.A. 22-2605 make venue proper in any county where the crime is committed on or near a boundary of multiple counties.”
In Re Jws, 825 P.2d 125 (Kan. 1992). “" K.S.A. 22-2604: "Where a crime is committed on or so near the boundary of two or more counties that it cannot be readily determined in which county the crime was committed, the prosecution may be in any of such counties.”
State v. Lundberg ( (Kan. Ct. App. 2017). “K.S.A. 22-2604. If the cause of death is inflicted in one county and the victim dies in another county, either county has venue.”
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.