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

K.S.A. § 22-4509 (2026)

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22-4509. Transcripts. Whenever it is determined that a transcript of all or some part of the trial or other proceeding is necessary to enable a person who is entitled to appeal, or to pursue another post-conviction remedy, to present such person's cause adequately and it is further determined that the appellant or petitioner or movant is financially unable to pay for the preparation of such transcript, the district court shall order that the transcript be supplied to the appellant or petitioner or movant by the official reporter of the district court.

History: L. 1969, ch. 291, § 9; L. 1976, ch. 163, § 25; L. 1982, ch. 142, § 19; July 1.

Notes of Decisions
Cited in 14 cases (3 in the last 5 years), 1972–2025 · leading case: State v. McCloud, 891 P.2d 324 (Kan. 1995).
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State v. McCloud, 891 P.2d 324 (Kan. 1995). · cites it 2× “22-4505 and K.S.A. 22-4509. Several requests were made by the Appellate Defender's office for transcripts of certain proceedings and corresponding certificates of completion.”
State v. Andrews, 614 P.2d 447 (Kan. 1980). “script stating that a transcript of the trial record is necessary to enable said defendant to prosecute the appeal and that said defendant is not financially able to pay the cost of procuring such transcript, and if the court finds that the statements contained therein are true…”
State v. Griffen, 734 P.2d 1089 (Kan. 1987). “K.S.A. 1986 Supp. 22-4509 provides: “Whenever it is determined that a transcript of all or some part of the trial or other proceeding is necessary to enable a person who is entitled to appeal, or to pursue another post-conviction remedy, to present such person’s cause adequately…”
State v. Brown, 973 P.2d 773 (Kan. 1999). “Brown’s request for a transcript of the preliminary hearing was denied, but an audio tape of the preliminary hearing was made available.”
State v. Kelley, 498 P.2d 87 (Kan. 1972). “K.S.A. 1971 Supp. 22-4509 makes that preparation conditional upon a determination by the trial court that such transcript is necessary for the indigent to present his cause adequately.”
State v. Duckett, 764 P.2d 134 (Kan. Ct. App. 1988). · cites it 3× “22-4505(b), if defendant filed a verified motion stating that a sentencing hearing transcript was “necessary to enable [him] to prosecute the appeal” and if the trial court found that to be true, the trial court was to order that “such transcript be supplied to [him] as provided…”
Morrow v. State, 849 P.2d 1004 (Kan. Ct. App. 1993). “The next issue to be addressed is whether the court erred in finding, without an evidentiary hearing, that had an appropriate motion pursuant to K.S.A. 22-4509 been filed the request for a transcript would have been denied.”
Landrum v. Goering (Kan. 2017). · cites it 2× “10 First, Morrow deals with a different statutory provision (K.S.A. 22-4509 rather than 22-4508) and different statutory language.”
State v. Tran (Kan. Ct. App. 2020). · cites it 2× “On November 17, 2016, Tran filed his first pro se "Motion for Transcripts (Pursuant to K.S.A. 22-4509)." In response, the district court summarily denied the motion finding that it was moot because Tran's case was on appeal and his appointed appellate defender had requested the…”
State v. Koop (Kan. Ct. App. 2020). · cites it 2× “About two months after this court's mandate, Koop moved the district court for transcripts and court records under K.S.A. 22-4509. The district court denied Koop's motion, ruling that Koop failed to present a substantial question of law or fact and that he was not entitled to a…”
Koop v. State (Kan. Ct. App. 2022). “About two months later, Koop filed a motion seeking free transcripts and court records pursuant to K.S.A. 22-4509. The district court denied this motion, and Koop timely appealed.”
State v. McNellis, 444 P.3d 1017 (Kan. Ct. App. 2019). “K.S.A. 22-4509 provides for that access: "Whenever it is determined that a transcript of all or some part of the trial or other proceeding is necessary to enable a person who is entitled to appeal, or to pursue another post-conviction remedy, to present such person's cause…”
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