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Kansas Statutes Annotated

K.S.A. § 60-451 (2026)

Subsequent remedial conduct

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60-451. Subsequent remedial conduct. When after the occurrence of an event remedial or precautionary measures are taken, which, if taken previously would have tended to make the event less likely to occur, evidence of such subsequent measures is not admissible to prove negligence or culpable conduct in connection with the event.

History: L. 1963, ch. 303, 60-451; January 1, 1964.

Notes of Decisions
Cited in 18 cases (1 in the last 5 years), 1972–2025 · leading case: Siruta v. Hesston Corp., 659 P.2d 799 (Kan. 1983).
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Siruta v. Hesston Corp., 659 P.2d 799 (Kan. 1983). · cites it 8× “Simply stated, it is the position of defendant that evidence of design changes and the installation of guards or shields on Hesston balers manufactured after the accident in this case constituted evidence of subsequent remedial or precautionary measures and was inadmissible…”
Griffin v. Suzuki Motor Corp., 124 P.3d 57 (Kan. 2005). · cites it 5× “2d 90 (1970) (Under K.S.A. 60-451, evidence of subsequent remedial conduct inadmissible to prove negligence or culpable conduct in connection with specific event.”
Schmeck v. City of Shawnee, 651 P.2d 585 (Kan. 1982). · cites it 4× “KCPL next argues the admission of evidence regarding the date the new signalization equipment was ordered, July 13, 1976, and the date it was finally installed, March 24, 1977, was error in violation of K.S.A. 60-451. K.S.A. 60-451 prohibits the introduction of subsequent…”
Kleibrink v. Missouri-Kansas-Texas R.R. Co., 581 P.2d 372 (Kan. 1978). · cites it 4× “The appellant argues error was committed when the trial court refused to give an instruction on remedial measures based upon K.S.A. 60-451. This argument overlooks the fact K.”
DiPietro v. Cessna Aircraft Co., 16 P.3d 986 (Kan. Ct. App. 2000). · cites it 7× “The trial court ruled at the pretrial stage and again during trial that the subsequent erection of the fence was inadmissible pursuant to K.S.A. 60-451. The case was submitted to a jury, and the jury returned a defendant’s verdict, finding Cessna 20 percent at fault and DiPietro…”
Patton v. Hutchinson Wil-Rich Mfg. Co., 861 P.2d 1299 (Kan. 1993). · cites it 2× “K.S.A. 60-451 (evidence of subsequent remedial measures is inadmissible) supports the view that the legislature intended that product defects be judged at the time when the product leaves the manufacturer’s control.”
Blackburn, Inc. v. Harnischfeger Corp., 773 F. Supp. 296 (D. Kan. 1991). · cites it 4× “Blackburn argues that such evidence would be admissible under K.S.A. 60-451, since the evidence would relate to remedial measures prior to the accident, even though after the sale of the crane.”
Bullock v. BNSF Ry. Co., 399 P.3d 148 (Kan. 2017). · cites it 41× “K.S.A. 60-451 prohibits the admission of subsequent remedial measures to prove negligence or culpable conduct.”
Stephen Brent WHEELER v. JOHN DEERE Co., 862 F.2d 1404 (10th Cir. 1988). “At the time of the accident in question, Kan. Stat.Ann. § 60-451 (1983) stated: “When after the occurrence of an event remedial or precautionary measures are taken, which, if taken previously would have tended to make the event less likely to occur, evidence of such subsequent…”
Jenkins v. Amchem Prods., Inc., 886 P.2d 869 (Kan. 1994). “The defendant argued such evidence was of subsequent remedial measures inadmissible under K.S.A. 60-451. 232 Kan. at 666 . This court disagreed, stating: “In products liability cases, the plaintiff in sustaining its burden to prove that a product is defectively designed may…”
Wichita Eagle & Beacon Publ'g Co. v. Simmons, 50 P.3d 66 (Kan. 2002). “60-426 (lawyer-client privilege), K.S.A. 60-451 (subsequent remedial measures), and K.”
Rood v. Kansas City Power & Light Co., 755 P.2d 502 (Kan. 1988). · cites it 2× “However, a question by plaintiff's counsel tending to show that KCPL had taken remedial measures subsequent to the accident to prove negligence would have been inadmissible under K.S.A. 60-451. In view of the fact the problem was brought about as the result of the defendant's…”
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