Kansas Statutes Annotated

K.S.A. § 60-2403 (2026)

Judgment, when dormant; release of record; child support judgments after July 1, 2007, never dormant; court costs, fees, fines and restitution judgments after July 1, 2015, never dormant

✓ current as of May 2026
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60-2403. Judgment, when dormant; release of record; child support judgments after July 1, 2007, never dormant; court costs, fees, fines and restitution judgments after July 1, 2015, never dormant. (a) (1) Except as provided in subsection (b), if a renewal affidavit is not filed or if execution, including any garnishment proceeding, support enforcement proceeding or proceeding in aid of execution, is not issued, within five years from the date of the entry of any judgment in any court of record in this state, including judgments in favor of the state or any municipality in the state, or within five years from the date of any order reviving the judgment or, if five years have intervened between the date of the last renewal affidavit filed or execution proceedings undertaken on the judgment and the time of filing another renewal affidavit or undertaking execution proceedings on it, the judgment, including court costs and fees therein shall become dormant, and shall cease to operate as a lien on the real estate of the judgment debtor. When a judgment becomes and remains dormant for a period of two years, it shall be the duty of the judge to release the judgment of record when requested to do so. Undisputed payments made prior to a request for a release of judgment are voluntary and not subject to refund or recoupment.

(2) A "renewal affidavit" is a statement under oath, signed by the judgment creditor or the judgment creditor's attorney, filed in the proceedings in which the judgment was entered and stating the remaining balance due and unpaid on the judgment.

(3) A "support enforcement proceeding" means any civil proceeding to enforce any judgment for payment of child support or maintenance and includes, but is not limited to, any income withholding proceeding under the income withholding act, K.S.A. 23-3101 et seq., and amendments thereto, any contempt proceeding and any civil proceeding under the uniform interstate family support act, K.S.A. 23-36,101 et seq., and amendments thereto.

(b) Except for those judgments which have become void as of July 1, 2007, no judgment for the support of a child shall be or become dormant for any purpose except as provided in this subsection. Except for those judgments which have become void as of July 1, 2015, no judgment for court costs, fees, fines or restitution shall be or become dormant for any purpose except as provided in this subsection. If a judgment would have become dormant under the conditions set forth in subsection (a), the judgment shall cease to operate as a lien on the real estate of the judgment debtor as of the date the judgment would have become dormant, but the judgment shall not be released of record pursuant to subsection (a).

(c) The time within which action must be taken to prevent a judgment from becoming dormant does not run during any period in which the enforcement of the judgment by legal process is stayed or prohibited.

History: L. 1963, ch. 303, 60-2403; L. 1973, ch. 238, § 1; L. 1984, ch. 147, § 14; L. 1985, ch. 115, § 54; L. 1988, ch. 218, § 2; L. 1990, ch. 207, § 2; L. 1992, ch. 103, § 1; L. 1995, ch. 257, § 8; L. 2007, ch. 174, § 6; L. 2012, ch. 162, § 80; L. 2015, ch. 53, § 4; L. 2022, ch. 31, § 5; July 1.

Notes of Decisions
Cited in 61 cases (15 in the last 5 years), 1966–2026 · leading case: Associated Wholesale Grocers, Inc. v. Americold Corp., 270 P.3d 1074 (Kan. 2011).
Associated Wholesale Grocers, Inc. v. Americold Corp., 270 P.3d 1074 (Kan. 2011). · cites it 28× “However, the parties also raise jurisdictional issues, one of which is NPIC’s contention that the underlying judgments against Americold were extinguished pursuant to K.S.A. 60-2403, thus depriving the district court of subject matter jurisdiction to proceed with this…”
Bank IV Wichita, Nat'l Ass'n v. Plein, 830 P.2d 29 (Kan. 1992). · cites it 10× “Even if William’s amended answer relates back to his original answer, the amended answer is not an execution, garnishment, or proceeding in aid of execution (the requirements of K.S.A. 1991 Supp. 60-2403[a] to keep the judgment alive).”
State v. Dwyer, 439 P.3d 338 (Kan. Ct. App. 2019). · cites it 16× “The district court also explained the legislative history of K.S.A. 60-2403. Prior to 2015, subsection (d) provided that an individual has 10 years to collect a restitution judgment before it becomes dormant.”
Alexander Constr. Co. v. Weaver, 594 P.2d 248 (Kan. Ct. App. 1979). · cites it 12× “Defendant relied on the argument that foreign judgments are to be governed by the laws of the forum state (Kansas), and therefore under the provisions of K.S.A. 60-2403 and 60-2404, this was a dormant judgment that could not be enforced in Kansas.”
In Re the Marriage of Larimore, 362 P.3d 843 (Kan. Ct. App. 2015). · cites it 13× “” Based on K.S.A. 2014 Supp. 60-2403 and Bank IV Wichita v.”
In re Marriage of Doud & Modrcin, 480 P.3d 800 (Kan. Ct. App. 2020). · cites it 8× “A dormant judgment can be revived if, within two years, a party strictly complies with the procedures set forth in K.S.A. 2019 Supp. 60-2403 and K.S.A. 60-2404.”
State v. Douglas, 279 P.3d 133 (Kan. Ct. App. 2012). · cites it 9× “His basic assertion is that because the State waited so long (19 years) to try and collect the court costs, it should be barred from now doing so because of the passage of time.”
Cyr v. Cyr, 815 P.2d 97 (Kan. 1991). · cites it 6× “60-2401 or garnishment or income withholding proceedings pursuant to K.S.A. 1990 Supp. 60-2403 but were proceedings in aid of execution pursuant to 60-2403, *97 thereby keeping alive the judgments for past due support.”
Gardner v. Gardner, 916 P.2d 43 (Kan. Ct. App. 1996). · cites it 10× “On October 25, 1994, SRS filed a second motion for revivor of all judgments from July 1, 1981, through September 30, 1994.”
In Re the Marriage of Jones, 921 P.2d 839 (Kan. Ct. App. 1996). · cites it 7× “At the hearing on the motion for revivor in 1994, the court ruled that Mary was guilty of laches and that it would be inequitable and inappropriate for her to recover back payments dating back to June 25, 1982. It also denied William’s motions to terminate alimony.”
Summitt v. Summitt, 74 P.3d 584 (Kan. Ct. App. 2003). · cites it 5× “K.S.A. 2002 Supp. 60-2403(a)(3). Generally, a judgment that remains dormant for 2 years is extinguished.”
Martin v. Phillips, 347 P.3d 1033 (Kan. Ct. App. 2015). · cites it 5× “Under the Kansas dormancy statute, K.S.A. 2014 Supp. 60-2403, child-support judgments not void as of July 1, 2007, never become dormant.”
State v. Morrison, 14 P.3d 1189 (Kan. Ct. App. 2000). · cites it 13× “In that case we said that, pursuant to K.S.A. 60-2403, judgments grow dormant in five years, if not enforced by execution, garnishment or proceeding in aid of execution; and, if not revived, as provided in K.”
Vanover v. Cook, 260 F.3d 1182 (10th Cir. 2001). · cites it 2× “See Kan. Stat. Ann. §§ 60-2403 , 60-2404. Cook took no steps to enforce Vanover’s obligation until she filed a renewal notice of the debt in 1993, and then filed her garnishment actions in 1996.”
St. Joseph Dev. Corp. v. Sequenzia, 968 P.2d 682 (Kan. Ct. App. 1998). · cites it 7× “: Bernadette Sequenzia appeals the trial court’s ruling that the lien against her property was not dormant under K.S.A. 1997 Supp. 60-2403. St. Joseph Development Corp.”
State v. Arnett, 496 P.3d 928 (Kan. 2021). “But her preferred remedy goes too far. Although the development of criminal restitution as a full-fledged and unhindered civil judgment is concerning to the validity of any order of restitution, we do not find that it necessitates invalidating every order of restitution made by…”
Warner v. Warner, 668 P.2d 193 (Kan. Ct. App. 1983). · cites it 3× “The issue framed by the parties is based on the assumption that our dormancy statute, K.S.A. 60-2403, determines whether a foreign judgment is enforceable when it is filed in Kansas.”
State v. Robison, 496 P.3d 892 (Kan. 2021). “But his preferred remedy goes too far. Although the development of criminal restitution as a full-fledged and unhindered civil judgment is concerning to the validity of any order of restitution, we do not find that it necessitates invalidating every order of restitution made by…”
State Ex Rel. Thorne v. Cleland, 213 P.3d 1091 (Kan. Ct. App. 2009). · cites it 29× “First, Cleland argues that the child support arrearages were dormant judg *483 ments under K.S.A. 2008 Supp. 60-2403. The trial court found that the child support arrearages were not dormant judgments under K.”
Johnson Bros. Wholesale Liquor Co. v. Clemmons, 661 P.2d 1242 (Kan. 1983). · cites it 2× “Thereafter, no additional action was taken by plaintiff on that Kansas judgment, and it became dormant under the provisions of K.S.A. 60-2403. Plaintiff failed to revive that judgment within two years after the date the judgment became dormant as required by K.”
Dallas v. Dallas, 689 P.2d 1184 (Kan. 1984). · cites it 3× “” The sole issue on appeal is whether the trial court erred in holding child support payments due before January 21, 1975, were dormant pursuant to K.S.A. 60-2403. Installment payments for child support become final judgments when due.”
Hale v. Hale, 108 P.3d 1012 (Kan. Ct. App. 2005). · cites it 2× “” The duration of an enforceable judgment is normally controlled by our dormancy and revivor statutes, K.S.A. 2004 Supp. 60-2403 and K.S.A. 60-2404.”
Clark v. Glazer, 609 P.2d 1177 (Kan. Ct. App. 1980). · cites it 2× “: The issue in this case is whether equitable estoppel will prevent a judgment from becoming dormant and eventually barred under K.S.A. 60-2403. We hold it will not. The judgment in this case was one for alimony, entered in the parties’ divorce action on June 27, 1968.”
State v. Alderson, 322 P.3d 364 (Kan. 2014). “The application of the dormancy statute, K.S.A. 2013 Supp. 60-2403, to crime restitution orders issued under K.”
Kansas Dep't of Labor v. Singleton (In re Singleton), 553 B.R. 420 (Bankr. D. Kan. 2016). · cites it 4× “The 2004 Overpayment was not reduced to a civil judgment and, even if considered a judgment, it has not been renewed pursuant to K.S.A. § 60-2403(a). Second, laches, waiver, and estoppel bar the 2004 Overpayment because the KDOL had the ability to offset its claim against…”
In Re the Marriage of Williams, 900 P.2d 860 (Kan. Ct. App. 1995). · cites it 2× “K.S.A. 60-2403(a)(l) provides that all judgments become dormant after five years — but that merely prevents the dormant judgment from operating as a lien on the judgment debtor’s real estate.”
State v. Eubanks, 516 P.3d 116 (Kan. 2022). “Alderson filed a motion requesting release from the restitution order based on its dormancy under K.S.A. 2013 Supp. 60-2403(d). We concluded the language in the journal entry was too ambiguous to subject the defendant to restitution collection during imprisonment and the…”
Riney v. Riney, 473 P.2d 77 (Kan. 1970). · cites it 2× “come dormant as herein provided, and shall so remain for a period of two (2) years, it shall be the duty of the clerk of the court to release said judgment of record, and the clerk shall make an entry on the appearance and judgment dockets wherein the judgment appears of record,…”
Riggan v. Dir. of Revenue, 453 P.2d 52 (Kan. 1969). · cites it 10× “By reason thereof the plaintiff contends the Director is barred from collection of the tax by the provisions *130 of K.S.A. 60-2403 — the dormant judgment statute.”
DeKalb Swine Breeders, Inc. v. Woolwine Supply Co., 809 P.2d 1223 (Kan. 1991). · cites it 4× “For the purpose of this section and K.S.A. 60-2403 and amendments thereto, *677 attachment, income withholding or garnishment process shall have the same effect as the issuance of an execution.”
Wichita Fed. Sav. & Loan Ass'n v. North Rock Road Ltd. P'ship, 779 P.2d 442 (Kan. Ct. App. 1989). “Columbian Title finally argues that, since execution or other legal process for collection was not commenced within five years of the entry of the divorce decree, the judgment lien became dormant and unenforceable under K.S.A. 1988 Supp. 60-2403, which in applicable part…”
Nat'l Sur. Corp. v. Shoemaker, 195 N.W.2d 134 (S.D. 1972). “These defenses are based on K.S.A. 60-2403, which provides in effect that if execution is not *307 sued out within five years from the date of the judgment it shall be dormant, and if not revived within two years after ihat as provided in K.”
Long v. Brooks, 636 P.2d 242 (Kan. Ct. App. 1981). “In that case we said that, pursuant to K.S.A. 60-2403, judgments grow dormant in five years, if not enforced by execution, garnishment or proceeding in aid of execution; and, if not revived, as provided in K.”
Nat'l Union Fire Ins. v. Nicholas, 651 A.2d 1111 (Pa. Super. Ct. 1994). “Once the foreign judgment has been filed in accord with the Uniform Enforcement of Foreign Judgments Act now applicable in Kansas, that foreign judgment shall have the same force and effect for enforcement as a domestic judgment under K.S.A. 60-2403 and 60-2404. The same result…”
In re Marriage of Strom, 435 P.3d 583 (Kan. Ct. App. 2019). · cites it 40× “K.S.A. 2017 Supp. 60-2403(a) applies to judgments in divorce actions.”
Tanner v. Hancock, 619 P.2d 1177 (Kan. Ct. App. 1980). “Once the foreign judgment has been filed in accord with the Uniform Enforcement of Foreign Judgments Act now applicable in Kansas, that foreign judgment shall have the same force and effect for enforcement as a domestic judgment under K.S.A. 60-2403 and 60-2404.” Syllabus ¶ 2…”
State v. Robards, 78 P.3d 825 (Kan. Ct. App. 2003). · cites it 4× “K.S.A. 2002 Supp. 60-2403(d) provides that a renewal affidavit must be filed or an execution must be issued within 10 years of a restitution order, otherwise the order will become dormant.”
Brieger v. Brieger, 421 P.2d 1 (Kan. 1966). “The record reflects that on August 3, 1965, when the order was made, some support payments had been delinquent for more than five *761 years and the judgments accruing thereon had thus become dormant by virtue of K.S.A. 60-2403. While those dormant judgments were subject to…”
Castle v. Castle, 642 S.W.2d 709 (Mo. Ct. App. 1982). · cites it 2× “The appellant argues that the amount of child support found due by the computations of the Kansas District Court was in error because of the Court’s total disregard for the Kansas Statute of Limitations as stated in K.S.A. 60-2403. The Kansas Statute provides that if execution,…”
In re Marriage of Bates (Kan. Ct. App. 2026). · cites it 17× “In March 2023, David filed a motion to terminate his obligations, arguing the original judgment was dormant under K.S.A. 2022 Supp. 60-2403. The district court ruled in favor of Barbara, treating the payments David owed each month as installments, and finding that each…”
State v. McCoy (Kan. Ct. App. 2021). · cites it 15×
Dir. of Prop. Valuation v. Golden Plains Express, Inc., 760 P.2d 1227 (Kan. Ct. App. 1988). · cites it 2×
State v. Copridge (Kan. Ct. App. 2020). · cites it 14×
Casey v. PLAKE, 244 P.3d 689 (Kan. Ct. App. 2010). · cites it 14×
Citizens Bank v. Gaskins (Kan. Ct. App. 2025). · cites it 5×
State v. Ebihara (Kan. Ct. App. 2026). · cites it 5×
O'CONNOR v. Midwest Pipe Fabricators, Inc., 198 F. Supp. 2d 1275 (D. Kan. 2002). · cites it 8×
Dekalb Swine Breeders v. Woolwine Supply, 809 P.2d 1223 (Kan. 1991). · cites it 4×
In re Marriage of Holliday (Kan. Ct. App. 2022). · cites it 4×
FDIC v. Greif (D. Kan. 2020). · cites it 4×
Centrinex, LLC v. Darkstar Grp., LTC (D. Kan. 2022). · cites it 4×
City of Topeka Mun. Court v. Lister (Kan. Ct. App. 2020). · cites it 3×
Arch Roofing & Restoration Co. v. Garcia (Kan. Ct. App. 2022). · cites it 3×
In re Marriage of Shafer (Kan. Ct. App. 2022). · cites it 3×
M & I Marshall & Ilsley Bank v. Higdon, 556 P.3d 498 (Kan. 2024).
State v. Bailey (Kan. 2017). · cites it 2×
In re Marriage of Clark (Kan. Ct. App. 2022). · cites it 2×
Cessna Fin. Corp. v. VYWB, LLC (D. Kan. 2019). · cites it 2×
State v. Willis (Kan. Ct. App. 2021).
State ex rel. Jackson v. Jackson, 110 So. 3d 597 (La. Ct. App. 2013).
— K.S.A. § 60-2403(a) — 19 cases
Bank IV Wichita, Nat'l Ass'n v. Plein, 830 P.2d 29 (Kan. 1992). “Even if William’s amended answer relates back to his original answer, the amended answer is not an execution, garnishment, or proceeding in aid of execution (the requirements of K.S.A. 1991 Supp. 60-2403[a] to keep the judgment alive).”
Associated Wholesale Grocers, Inc. v. Americold Corp., 270 P.3d 1074 (Kan. 2011). “However, the parties also raise jurisdictional issues, one of which is NPIC’s contention that the underlying judgments against Americold were extinguished pursuant to K.S.A. 60-2403, thus depriving the district court of subject matter jurisdiction to proceed with this…”
State v. Douglas, 279 P.3d 133 (Kan. Ct. App. 2012). “His basic assertion is that because the State waited so long (19 years) to try and collect the court costs, it should be barred from now doing so because of the passage of time.”
Cyr v. Cyr, 815 P.2d 97 (Kan. 1991). “60-2401 or garnishment or income withholding proceedings pursuant to K.S.A. 1990 Supp. 60-2403 but were proceedings in aid of execution pursuant to 60-2403, *97 thereby keeping alive the judgments for past due support.”
Kansas Dep't of Labor v. Singleton (In re Singleton), 553 B.R. 420 (Bankr. D. Kan. 2016). “The 2004 Overpayment was not reduced to a civil judgment and, even if considered a judgment, it has not been renewed pursuant to K.S.A. § 60-2403(a). Second, laches, waiver, and estoppel bar the 2004 Overpayment because the KDOL had the ability to offset its claim against…”
Martin v. Phillips, 347 P.3d 1033 (Kan. Ct. App. 2015). “Under the Kansas dormancy statute, K.S.A. 2014 Supp. 60-2403, child-support judgments not void as of July 1, 2007, never become dormant.”
In Re the Marriage of Jones, 921 P.2d 839 (Kan. Ct. App. 1996). “At the hearing on the motion for revivor in 1994, the court ruled that Mary was guilty of laches and that it would be inequitable and inappropriate for her to recover back payments dating back to June 25, 1982. It also denied William’s motions to terminate alimony.”
State Ex Rel. Thorne v. Cleland, 213 P.3d 1091 (Kan. Ct. App. 2009). “First, Cleland argues that the child support arrearages were dormant judg *483 ments under K.S.A. 2008 Supp. 60-2403. The trial court found that the child support arrearages were not dormant judgments under K.”
DeKalb Swine Breeders, Inc. v. Woolwine Supply Co., 809 P.2d 1223 (Kan. 1991). “For the purpose of this section and K.S.A. 60-2403 and amendments thereto, *677 attachment, income withholding or garnishment process shall have the same effect as the issuance of an execution.”
FDIC v. Greif (D. Kan. 2020).
State v. McCoy (Kan. Ct. App. 2021).
In re Marriage of Strom, 435 P.3d 583 (Kan. Ct. App. 2019). “K.S.A. 2017 Supp. 60-2403(a) applies to judgments in divorce actions.”
In re Marriage of Bates (Kan. Ct. App. 2026). “In March 2023, David filed a motion to terminate his obligations, arguing the original judgment was dormant under K.S.A. 2022 Supp. 60-2403. The district court ruled in favor of Barbara, treating the payments David owed each month as installments, and finding that each…”
Dekalb Swine Breeders v. Woolwine Supply, 809 P.2d 1223 (Kan. 1991).
State v. Willis (Kan. Ct. App. 2021).
State v. Ebihara (Kan. Ct. App. 2026).
Casey v. PLAKE, 244 P.3d 689 (Kan. Ct. App. 2010).
— K.S.A. § 60-2403(a)(1) — 15 cases
In re Marriage of Doud & Modrcin, 480 P.3d 800 (Kan. Ct. App. 2020). “A dormant judgment can be revived if, within two years, a party strictly complies with the procedures set forth in K.S.A. 2019 Supp. 60-2403 and K.S.A. 60-2404.”
Summitt v. Summitt, 74 P.3d 584 (Kan. Ct. App. 2003). “K.S.A. 2002 Supp. 60-2403(a)(3). Generally, a judgment that remains dormant for 2 years is extinguished.”
State v. Morrison, 14 P.3d 1189 (Kan. Ct. App. 2000). “In that case we said that, pursuant to K.S.A. 60-2403, judgments grow dormant in five years, if not enforced by execution, garnishment or proceeding in aid of execution; and, if not revived, as provided in K.”
State Ex Rel. Thorne v. Cleland, 213 P.3d 1091 (Kan. Ct. App. 2009). “First, Cleland argues that the child support arrearages were dormant judg *483 ments under K.S.A. 2008 Supp. 60-2403. The trial court found that the child support arrearages were not dormant judgments under K.”
In re Marriage of Strom, 435 P.3d 583 (Kan. Ct. App. 2019). “K.S.A. 2017 Supp. 60-2403(a) applies to judgments in divorce actions.”
In re Marriage of Clark (Kan. Ct. App. 2022).
Citizens Bank v. Gaskins (Kan. Ct. App. 2025).
State v. Copridge (Kan. Ct. App. 2020).
State v. McCoy (Kan. Ct. App. 2021).
In re Marriage of Shafer (Kan. Ct. App. 2022).
In re Marriage of Holliday (Kan. Ct. App. 2022).
In re Marriage of Bates (Kan. Ct. App. 2026). “In March 2023, David filed a motion to terminate his obligations, arguing the original judgment was dormant under K.S.A. 2022 Supp. 60-2403. The district court ruled in favor of Barbara, treating the payments David owed each month as installments, and finding that each…”
State v. Ebihara (Kan. Ct. App. 2026).
— K.S.A. § 60-2403(a)(3) — 2 cases
Summitt v. Summitt, 74 P.3d 584 (Kan. Ct. App. 2003). “K.S.A. 2002 Supp. 60-2403(a)(3). Generally, a judgment that remains dormant for 2 years is extinguished.”
State Ex Rel. Thorne v. Cleland, 213 P.3d 1091 (Kan. Ct. App. 2009). “First, Cleland argues that the child support arrearages were dormant judg *483 ments under K.S.A. 2008 Supp. 60-2403. The trial court found that the child support arrearages were not dormant judgments under K.”
— K.S.A. § 60-2403(a)(l) — 10 cases
Associated Wholesale Grocers, Inc. v. Americold Corp., 270 P.3d 1074 (Kan. 2011). “However, the parties also raise jurisdictional issues, one of which is NPIC’s contention that the underlying judgments against Americold were extinguished pursuant to K.S.A. 60-2403, thus depriving the district court of subject matter jurisdiction to proceed with this…”
In Re the Marriage of Larimore, 362 P.3d 843 (Kan. Ct. App. 2015). “” Based on K.S.A. 2014 Supp. 60-2403 and Bank IV Wichita v.”
State v. Dwyer, 439 P.3d 338 (Kan. Ct. App. 2019). “The district court also explained the legislative history of K.S.A. 60-2403. Prior to 2015, subsection (d) provided that an individual has 10 years to collect a restitution judgment before it becomes dormant.”
Hale v. Hale, 108 P.3d 1012 (Kan. Ct. App. 2005). “” The duration of an enforceable judgment is normally controlled by our dormancy and revivor statutes, K.S.A. 2004 Supp. 60-2403 and K.S.A. 60-2404.”
Summitt v. Summitt, 74 P.3d 584 (Kan. Ct. App. 2003). “K.S.A. 2002 Supp. 60-2403(a)(3). Generally, a judgment that remains dormant for 2 years is extinguished.”
Gardner v. Gardner, 916 P.2d 43 (Kan. Ct. App. 1996). “On October 25, 1994, SRS filed a second motion for revivor of all judgments from July 1, 1981, through September 30, 1994.”
In Re the Marriage of Williams, 900 P.2d 860 (Kan. Ct. App. 1995). “K.S.A. 60-2403(a)(l) provides that all judgments become dormant after five years — but that merely prevents the dormant judgment from operating as a lien on the judgment debtor’s real estate.”
State v. Morrison, 14 P.3d 1189 (Kan. Ct. App. 2000). “In that case we said that, pursuant to K.S.A. 60-2403, judgments grow dormant in five years, if not enforced by execution, garnishment or proceeding in aid of execution; and, if not revived, as provided in K.”
State Ex Rel. Thorne v. Cleland, 213 P.3d 1091 (Kan. Ct. App. 2009). “First, Cleland argues that the child support arrearages were dormant judg *483 ments under K.S.A. 2008 Supp. 60-2403. The trial court found that the child support arrearages were not dormant judgments under K.”
Casey v. PLAKE, 244 P.3d 689 (Kan. Ct. App. 2010).
— K.S.A. § 60-2403(b) — 11 cases
State v. Dwyer, 439 P.3d 338 (Kan. Ct. App. 2019). “The district court also explained the legislative history of K.S.A. 60-2403. Prior to 2015, subsection (d) provided that an individual has 10 years to collect a restitution judgment before it becomes dormant.”
State v. Arnett, 496 P.3d 928 (Kan. 2021). “But her preferred remedy goes too far. Although the development of criminal restitution as a full-fledged and unhindered civil judgment is concerning to the validity of any order of restitution, we do not find that it necessitates invalidating every order of restitution made by…”
State v. Robison, 496 P.3d 892 (Kan. 2021). “But his preferred remedy goes too far. Although the development of criminal restitution as a full-fledged and unhindered civil judgment is concerning to the validity of any order of restitution, we do not find that it necessitates invalidating every order of restitution made by…”
Martin v. Phillips, 347 P.3d 1033 (Kan. Ct. App. 2015). “Under the Kansas dormancy statute, K.S.A. 2014 Supp. 60-2403, child-support judgments not void as of July 1, 2007, never become dormant.”
In Re the Marriage of Jones, 921 P.2d 839 (Kan. Ct. App. 1996). “At the hearing on the motion for revivor in 1994, the court ruled that Mary was guilty of laches and that it would be inequitable and inappropriate for her to recover back payments dating back to June 25, 1982. It also denied William’s motions to terminate alimony.”
State Ex Rel. Thorne v. Cleland, 213 P.3d 1091 (Kan. Ct. App. 2009). “First, Cleland argues that the child support arrearages were dormant judg *483 ments under K.S.A. 2008 Supp. 60-2403. The trial court found that the child support arrearages were not dormant judgments under K.”
Gardner v. Gardner, 916 P.2d 43 (Kan. Ct. App. 1996). “On October 25, 1994, SRS filed a second motion for revivor of all judgments from July 1, 1981, through September 30, 1994.”
State v. Copridge (Kan. Ct. App. 2020).
State v. McCoy (Kan. Ct. App. 2021).
State v. Ebihara (Kan. Ct. App. 2026).
— K.S.A. § 60-2403(b)(2) — 1 case
Gardner v. Gardner, 916 P.2d 43 (Kan. Ct. App. 1996). “On October 25, 1994, SRS filed a second motion for revivor of all judgments from July 1, 1981, through September 30, 1994.”
— K.S.A. § 60-2403(b)(l) — 3 cases
Summitt v. Summitt, 74 P.3d 584 (Kan. Ct. App. 2003). “K.S.A. 2002 Supp. 60-2403(a)(3). Generally, a judgment that remains dormant for 2 years is extinguished.”
Gardner v. Gardner, 916 P.2d 43 (Kan. Ct. App. 1996). “On October 25, 1994, SRS filed a second motion for revivor of all judgments from July 1, 1981, through September 30, 1994.”
In Re the Marriage of Williams, 900 P.2d 860 (Kan. Ct. App. 1995). “K.S.A. 60-2403(a)(l) provides that all judgments become dormant after five years — but that merely prevents the dormant judgment from operating as a lien on the judgment debtor’s real estate.”
— K.S.A. § 60-2403(c) — 8 cases
Associated Wholesale Grocers, Inc. v. Americold Corp., 270 P.3d 1074 (Kan. 2011). “However, the parties also raise jurisdictional issues, one of which is NPIC’s contention that the underlying judgments against Americold were extinguished pursuant to K.S.A. 60-2403, thus depriving the district court of subject matter jurisdiction to proceed with this…”
In Re the Marriage of Larimore, 362 P.3d 843 (Kan. Ct. App. 2015). “” Based on K.S.A. 2014 Supp. 60-2403 and Bank IV Wichita v.”
In re Marriage of Doud & Modrcin, 480 P.3d 800 (Kan. Ct. App. 2020). “A dormant judgment can be revived if, within two years, a party strictly complies with the procedures set forth in K.S.A. 2019 Supp. 60-2403 and K.S.A. 60-2404.”
In re Marriage of Strom, 435 P.3d 583 (Kan. Ct. App. 2019). “K.S.A. 2017 Supp. 60-2403(a) applies to judgments in divorce actions.”
In re Marriage of Bates (Kan. Ct. App. 2026). “In March 2023, David filed a motion to terminate his obligations, arguing the original judgment was dormant under K.S.A. 2022 Supp. 60-2403. The district court ruled in favor of Barbara, treating the payments David owed each month as installments, and finding that each…”
Casey v. PLAKE, 244 P.3d 689 (Kan. Ct. App. 2010).
In re Marriage of Holliday (Kan. Ct. App. 2022).
Citizens Bank v. Gaskins (Kan. Ct. App. 2025).
— K.S.A. § 60-2403(d) — 8 cases
State v. Dwyer, 439 P.3d 338 (Kan. Ct. App. 2019). “The district court also explained the legislative history of K.S.A. 60-2403. Prior to 2015, subsection (d) provided that an individual has 10 years to collect a restitution judgment before it becomes dormant.”
State v. Douglas, 279 P.3d 133 (Kan. Ct. App. 2012). “His basic assertion is that because the State waited so long (19 years) to try and collect the court costs, it should be barred from now doing so because of the passage of time.”
State v. Morrison, 14 P.3d 1189 (Kan. Ct. App. 2000). “In that case we said that, pursuant to K.S.A. 60-2403, judgments grow dormant in five years, if not enforced by execution, garnishment or proceeding in aid of execution; and, if not revived, as provided in K.”
State v. Eubanks, 516 P.3d 116 (Kan. 2022). “Alderson filed a motion requesting release from the restitution order based on its dormancy under K.S.A. 2013 Supp. 60-2403(d). We concluded the language in the journal entry was too ambiguous to subject the defendant to restitution collection during imprisonment and the…”
State v. Robards, 78 P.3d 825 (Kan. Ct. App. 2003). “K.S.A. 2002 Supp. 60-2403(d) provides that a renewal affidavit must be filed or an execution must be issued within 10 years of a restitution order, otherwise the order will become dormant.”
State v. Copridge (Kan. Ct. App. 2020).
State v. McCoy (Kan. Ct. App. 2021).
State v. Ebihara (Kan. Ct. App. 2026).
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