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Kansas Statutes Annotated

K.S.A. § 60-2415 (2026)

Sheriff's return of sale

✓ current as of May 2026
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60-2415. Sheriff's return of sale. (a) Certificate of purchase. The sheriff shall at once make a return of all sales made under this article to the court. All taxes due or delinquent shall be noted on the sheriff's return. If the court finds the proceedings regular and in conformity with law and equity, it shall confirm the same, direct the clerk to make such entry upon the journal and order the sheriff to make to the purchaser the certificate of sale or deed provided for in this article.

(b) Equity powers of court. The court may decline to confirm the sale where the bid is substantially inadequate, or in ordering a sale or a resale, may, in its discretion, if conditions or circumstances warrant and after a proper hearing, fix a minimum or upset price at which the property must be bid in if the sale is to be confirmed; or the court may, upon application for the confirmation of the sale, if it has not theretofore fixed an upset price, conduct a hearing to establish the value of the property, and as a condition to confirmation require the fair value of the property be credited upon the judgment, interest, taxes and costs. A sale for the full amount of the judgment, taxes, interest and costs shall be deemed adequate.

History: L. 1963, ch. 303, 60-2415; L. 1988, ch. 219, § 2; July 1.

Notes of Decisions
Cited in 16 cases, 1987–2020 · leading case: Olathe Bank v. Mann, 845 P.2d 639 (Kan. 1993).
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Olathe Bank v. Mann, 845 P.2d 639 (Kan. 1993). · cites it 30× “Following the sheriff's sale of the mortgaged property where the mortgagee bank was the purchaser, the trial court confirmed the sale pursuant to K.S.A. 1991 Supp. 60-2415. The Manns appealed to the Court of Appeals, which reversed the trial court.”
Citifinancial Mortg. Co., Inc. v. Clark, 177 P.3d 986 (Kan. Ct. App. 2008). · cites it 25× “Citifinancial argues the district court failed to exercise its equity powers under K.S.A. 60-2415 as construed by controlling caselaw.”
All. Mortg. Co. v. Pastine, 136 P.3d 457 (Kan. 2006). · cites it 4× “60-2414, arguing only that K.S.A. 60-2415 prevented the district court from allowing a redemption or any other equitable remedy once the sale was confirmed.”
All. Mortg. Co. v. Pastine, 104 P.3d 405 (Kan. Ct. App. 2005). · cites it 16× “K.S.A. 60-2415(a) states that the trial court shall confirm the foreclosure sale "[i]f the court finds the proceedings regular and in conformity with law and equity.”
Nancy & Stjepan Sostaric v. Sally Marshall, 766 S.E.2d 396 (W. Va. 2014). · cites it 3× “, Kan. Stat. Ann. § 60-2415 ; Me. Rev. Stat.”
Fed. Land Bank of Wichita v. Cummings, 735 P.2d 1110 (Kan. Ct. App. 1987). · cites it 8× “The value of the collateral is immaterial insofar as the debt represented by the note is concerned.”
Reverse Mortg. Solutions, Inc. v. Goldwyn, 425 P.3d 617 (Kan. Ct. App. 2018). · cites it 6× “The district court's review of the sale of foreclosed property on court order by a sheriff is governed by K.S.A. 60-2415. It provides that the court "shall confirm" the sale "[i]f the court finds the proceedings regular and in conformity with law and equity.”
Farm Credit Bank of Wichita v. Zerr, 915 P.2d 137 (Kan. Ct. App. 1996). · cites it 6× ““Judicial discretion is abused when judicial action is arbitrary, fanciful or unreasonable, which is another way of saying that discretion is abused only where no reasonable [person] would take the view adopted by the trial court.”
Barnett v. Oliver, 858 P.2d 1228 (Kan. Ct. App. 1993). “351 (1993); K.S.A. 1992 Supp. 60-2415. Recently, in Olathe Bank v.”
Olathe Bank v. Mann, 834 P.2d 1365 (Kan. Ct. App. 1992). “K.S.A. 1991 Supp. 60-2415 governs the confirmation of a sheriff’s sale and provides: “(a) Certificate of purchase.”
Cimarron Feeders v. Bolle, 17 P.3d 957 (Kan. Ct. App. 2001). “K.S.A. 60-2415 controls the confirmation of a sheriff s sale and provides: “(a) The sheriff shall at once make a return of all sales made under this article to the court.”
G S Capital Mgmt. (Kan. Ct. App. 2020). · cites it 8× “60-2415(a) states that once a sheriff has reported to the court the outcome at the sale, "[i]f the court finds the proceedings regular and in conformity with law and equity, it shall confirm the same." The Whites point to this provision, arguing the district court here should…”
Show all 16 citing cases →
— K.S.A. § 60-2415(a) — 7 cases
All. Mortg. Co. v. Pastine, 136 P.3d 457 (Kan. 2006). “60-2414, arguing only that K.S.A. 60-2415 prevented the district court from allowing a redemption or any other equitable remedy once the sale was confirmed.”
All. Mortg. Co. v. Pastine, 104 P.3d 405 (Kan. Ct. App. 2005). “K.S.A. 60-2415(a) states that the trial court shall confirm the foreclosure sale "[i]f the court finds the proceedings regular and in conformity with law and equity.”
Olathe Bank v. Mann, 845 P.2d 639 (Kan. 1993). “Following the sheriff's sale of the mortgaged property where the mortgagee bank was the purchaser, the trial court confirmed the sale pursuant to K.S.A. 1991 Supp. 60-2415. The Manns appealed to the Court of Appeals, which reversed the trial court.”
Fed. Land Bank of Wichita v. Cummings, 735 P.2d 1110 (Kan. Ct. App. 1987). “The value of the collateral is immaterial insofar as the debt represented by the note is concerned.”
Reverse Mortg. Solutions, Inc. v. Goldwyn, 425 P.3d 617 (Kan. Ct. App. 2018). “The district court's review of the sale of foreclosed property on court order by a sheriff is governed by K.S.A. 60-2415. It provides that the court "shall confirm" the sale "[i]f the court finds the proceedings regular and in conformity with law and equity.”
— K.S.A. § 60-2415(b) — 6 cases
Olathe Bank v. Mann, 845 P.2d 639 (Kan. 1993). “Following the sheriff's sale of the mortgaged property where the mortgagee bank was the purchaser, the trial court confirmed the sale pursuant to K.S.A. 1991 Supp. 60-2415. The Manns appealed to the Court of Appeals, which reversed the trial court.”
Citifinancial Mortg. Co., Inc. v. Clark, 177 P.3d 986 (Kan. Ct. App. 2008). “Citifinancial argues the district court failed to exercise its equity powers under K.S.A. 60-2415 as construed by controlling caselaw.”
All. Mortg. Co. v. Pastine, 104 P.3d 405 (Kan. Ct. App. 2005). “K.S.A. 60-2415(a) states that the trial court shall confirm the foreclosure sale "[i]f the court finds the proceedings regular and in conformity with law and equity.”
Reverse Mortg. Solutions, Inc. v. Goldwyn, 425 P.3d 617 (Kan. Ct. App. 2018). “The district court's review of the sale of foreclosed property on court order by a sheriff is governed by K.S.A. 60-2415. It provides that the court "shall confirm" the sale "[i]f the court finds the proceedings regular and in conformity with law and equity.”
Farm Credit Bank of Wichita v. Zerr, 915 P.2d 137 (Kan. Ct. App. 1996). ““Judicial discretion is abused when judicial action is arbitrary, fanciful or unreasonable, which is another way of saying that discretion is abused only where no reasonable [person] would take the view adopted by the trial court.”
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