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

K.S.A. § 22-3203 (2026)

Consolidation for trial of separate indictments or informations

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22-3203. Consolidation for trial of separate indictments or informations. The court may order two or more complaints, informations or indictments against a single defendant to be tried together if the crimes could have been joined in a single complaint, information or indictment.

History: L. 1970, ch. 129, § 22-3203; July 1.

Notes of Decisions
Cited in 66 cases (22 in the last 5 years), 1977–2026 · leading case: State v. McCurry, 105 P.3d 1247 (Kan. 2005).
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State v. McCurry, 105 P.3d 1247 (Kan. 2005). · cites it 8× “2d 880 (1976), for the following proposition: “ ‘When two or more complaints, informations or indictments against a single de *121 fendant are tried together under K.S.A. 22-3203, the procedure should be the same as if the prosecution were under a single complaint, information…”
State v. Dixon, 492 P.3d 455 (Kan. Ct. App. 2021). · cites it 5× “Before proceeding with further analysis, we observe that the Kansas Supreme Court has held that under the language of the statute, the double rule does not apply to separate cases that are consolidated for trial under K.”
State v. Paredes, 118 P.3d 708 (Kan. Ct. App. 2005). · cites it 14× “Paredes’ sole argument on appeal is that his defense counsel was ineffective for failing to request consolidation of his cases under K.S.A. 22-3203. Nevertheless, we determine that Paredes’ argument lacks merit *347 because he has failed to meet either prong of the test for…”
State v. Smith-Parker, 340 P.3d 485 (Kan. 2014). · cites it 3× “” In a journal entry summarizing the hearing, the district judge stated: “After hearing arguments of counsel, the Court finds that pursuant to K.S.A. 22-3203, tire above-captioned cases should be tried together.”
State v. Arculeo, 36 P.3d 305 (Kan. Ct. App. 2001). · cites it 6× “All the cases in 97CR350 and 97CR180 were felonies occurring in Lyon County and could have been charged in the same complaint under K.S.A. 22-3202.”
State v. Shipley, 510 P.3d 1194 (Kan. Ct. App. 2022). · cites it 5× “Under that statute, "[a] prior conviction is any conviction, other than another count in the current case, which was brought in the same information or complaint or which was joined for trial with other counts in the current case pursuant to K.S.A. 22-3203 . . . which occurred…”
State v. Myers, 509 P.3d 563 (Kan. Ct. App. 2022). · cites it 4× “" K.S.A. 22-3203. Crimes can be joined in a single charging document when the crimes charged "are of the same or similar character or are based on the same act or transaction or on two or more acts or transactions connected together or constituting parts of a common scheme or…”
State v. Crosby, 479 P.3d 167 (Kan. 2021). “K.S.A. 22-3203. Two or more crimes may be charged in separate counts of the same complaint, information, or indictment if the crimes: (1) are of the same or similar character; or (2) are based on the same act or transaction; or (3) are based on two or more acts or transactions…”
State v. Timley, 875 P.2d 242 (Kan. 1994). · cites it 2× “K.S.A. 22-3203 provides that two or more separate cases may be consolidated for trial if the crimes could have been properly joined in the same complaint or information.”
State v. Keel, 357 P.3d 251 (Kan. 2015). “21-4710(a) defines “prior conviction” as “any conviction, other than another count in the current case which was brought in the same information or complaint or which was joined for trial with other counts in the current case pursuant to K.S.A. 22-3203 and amendments thereto,…”
State v. Carter, 466 P.3d 1180 (Kan. 2020). · cites it 3× “Under K.S.A. 22-3203, multiple complaints against a defendant can be tried together if the State could have brought the charges in a single complaint under K.”
State v. Arnett, 223 P.3d 780 (Kan. 2010). “21-4710(a) defines “prior convictions” as “any conviction, other than another count in the current case which was brought in the same information or complaint or which was joined for trial with other counts in die current case pursuant to K.S.A. 22-3203 and amendments thereto,…”
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K.S.A. § 22-3203(1): 2 cases
State v. Arculeo, 36 P.3d 305 (Kan. Ct. App. 2001). “All the cases in 97CR350 and 97CR180 were felonies occurring in Lyon County and could have been charged in the same complaint under K.S.A. 22-3202.”
State v. Anthony, 898 P.2d 1109 (Kan. 1995).
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