Kansas Statutes Annotated

K.S.A. § 60-471 (2026)

✓ current as of May 2026
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60-471.

History: L. 1976, ch. 247, § 1; Repealed, L. 1985, ch. 197, § 5; July 1.

Notes of Decisions
Cited in 15 cases, 1981–2012 · leading case: Wentling v. Med. Anesthesia Servs., 701 P.2d 939 (Kan. 1985).
Wentling v. Med. Anesthesia Servs., 701 P.2d 939 (Kan. 1985). · cites it 38× “The second issue raised on appeal is whether the trial court erred in ruling K.S.A. 60-471 unconstitutional. That statute, first enacted in 1976, abrogates certain elements of the common-law collateral source rule.”
Farley v. Engelken, 740 P.2d 1058 (Kan. 1987). · cites it 10× “60-3403 is the successor to K.S.A. 60-471, which was found unconstitutional by this court in Wentling v.”
Samsel v. Wheeler Transp. Servs., Inc., 789 P.2d 541 (Kan. 1990). · cites it 6× “The Kansas Legislature and Governor took the following actions: In 1976, the Health Care Provider Insurance Availability Act, which created the Health Care Stabilization Fund, was enacted (K.”
Coburn by & Through Coburn v. Agustin, 627 F. Supp. 983 (D. Kan. 1985). · cites it 8× “§ 60-471, which modified the collateral source rule as follows: (a) In any action for damages for personal injuries or death arising out of the rendering of or the failure to render professional services by any health care provider, evidence of any reimbursement or…”
Doran v. Priddy, 534 F. Supp. 30 (D. Kan. 1981). · cites it 8× “As a part of its response to what has come to be called the medical malpractice crisis, the Kansas legislature enacted K.S.A. § 60-471, which provides: “(a) In any action for damages for personal injuries or death arising out of the rendering of or the failure to render…”
Crowe by & Through Crowe v. Wigglesworth, 623 F. Supp. 699 (D. Kan. 1985). · cites it 15× “At the time plaintiff filed her complaint, the modified collateral source rule contained in K.S.A. 60-471 governed the admissibility of evidence of reimbursement or indemnification received by a party injured by the negligence of a health care provider.”
Stephens v. Snyder Clinic Ass'n, 631 P.2d 222 (Kan. 1981). · cites it 2× “40-3403); (4) modification *119 of the Collateral Source rule in health provider cases (K.S.A. 60-471; and (5) reduction of the "discovery period" of the statute of limitations in medical malpractice actions and a redefining of the point of time when such actions accrue (K.”
Miller v. Johnson, 289 P.3d 1098 (Kan. 2012). “\ (4) allowance of evidence of collateral source benefits in medical malpractice cases, K.S.A. 60-471 (Weeks 1976); and (5) shortening of the statute of repose in medical malpractice actions from 10 years to 4 years, K.”
Stephenson v. Sugar Creek Packing & Hartford Ins., 830 P.2d 41 (Kan. 1992). · cites it 2× “The statute, K.S.A. 60-471, abrogated for certain medical malpractice plaintiffs elements of the common-law rule precluding evidence of compensation from a source other than tortfeasors.”
Ferguson v. Garmon, 643 F. Supp. 335 (D. Kan. 1986). · cites it 3× “60-3403 and its predecessor, K.S.A. 60-471, have been examined by four of the judges from this district.”
Fretz v. Keltner, 109 F.R.D. 303 (D. Kan. 1985). · cites it 2× “The collateral source rule basically states that benefits conferred on an injured party from other sources are not credited against the tortfeasor’s liability although they cover all or a part of the harm for which the tortfeasor is liable.”
Thompson v. KFB Ins., 850 P.2d 773 (Kan. 1993). “2d 939 (1985), this court held that K.S.A. 60-471 violated the equal protection provisions of the federal and Kansas Constitutions, and in 1985 the statute was repealed.”
— K.S.A. § 60-471(a) — 1 case
Wentling v. Med. Anesthesia Servs., 701 P.2d 939 (Kan. 1985). “The second issue raised on appeal is whether the trial court erred in ruling K.S.A. 60-471 unconstitutional. That statute, first enacted in 1976, abrogates certain elements of the common-law collateral source rule.”
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