Kansas Statutes Annotated
K.S.A. § 7-108 (2026)
Attorney's lien; notice
✓ current as of May 2026
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7-108. Attorney's lien; notice. An attorney has a lien for a general balance of compensation upon any papers of his or her client which have come into the attorney's possession in the course of his or her professional employment, upon money in the attorney's hands belonging to the client, and upon money due to the client and in the hands of the adverse party, in any matter, action or proceeding in which the attorney was employed, from the time of giving notice of the lien to the party; such notice must be in writing, and may be served in the same manner as a summons, and upon any person, officer or agent upon whom a summons under the laws of this state may be served, and may also be served upon a regularly employed salaried attorney of the party.
History: G.S. 1868, ch. 11, § 8; L. 1905, ch. 68, § 1; March 21; R.S. 1923, § 7-108.
Notes of Decisions
Cited in 21
cases (4 in the last 5 years), 1981–2025 · leading case: In re the Marriage of Comley, 32 P.3d 1128 (Kan. 2001).
In re the Marriage of Comley, 32 P.3d 1128 (Kan. 2001). “” The district court held that TW&G’s Hen did not attach to monies paid by MAA directly to the clerk of the district court pursuant to the income withholding order “since these funds do not constitute ‘money due to the client and in the hands of the adverse party’ as required by…”
Nazar v. Allstate Ins. (In Re Veazey), 272 B.R. 486 (Bankr. D. Kan. 2002). “See Kan. Stat. Ann. § 7-108 . Additionally, Allstate claims a lien against the settlement proceeds in the amount of $44,520.”
Rajala v. Hodes (In Re Hodes), 289 B.R. 5 (D. Kan. 2003). “…to and approval by the bankruptcy court under 11 U.S.C. §§ 329 and 330; (3) the statutory retaining lien provided by K.S.A. § 7-108 did not bestow upon Appel-lees Zeldin and Grimes the right to use funds from the retainers without prior court approval under §§ 329 and 330;…”
Leathers v. Leathers, 856 F.3d 729 (10th Cir. 2017). “In the district court, Izen asserted he was entitled to a superpriority award of attorney fees under § 6323(b)(8) on the basis of both a contingency fee contract and a statutory lien under Kansas Statutes Annotated § 7-108.”
Mohr v. State Bank of Stanley, 770 P.2d 466 (Kan. 1989). “The attorneys for Tri-County had previously filed a notice of attorney’s lien with the court, pursuant to K.S.A. 7-108 and no objection had been raised.”
Excel Corp. v. Jimenez, 7 P.3d 1118 (Kan. 2000). “K.S.A. 7-108. The attorney lien statute provides: "An attorney has a lien for a general balance of compensation upon any papers of his or her client which have come into the attorney's possession in the course of his or her professional employment, upon money in the attorney's…”
In Re Hodes, 239 B.R. 239 (Bankr. D. Kan. 1999). “In Kansas, there are two types of attorney’s hens, both created by K.S.A. 7-108, which states: Attorney’s hen; notice.”
Carson v. Chevron Chem. Co., 635 P.2d 1248 (Kan. Ct. App. 1981). “K.S.A. 7-108 reads in part: “An attorney has a lien for a general balance of compensation upon any papers of his or her client which have come into the attorney’s possession in the course of his or her professional employment, upon money in the attorney’s hands belonging to the…”
Redmond v. Lentz & Clark, P.A. (In Re Wagers), 340 B.R. 391 (Bankr. D. Kan. 2006). “On appeal, the district court declined to review the holding that the retainer was property of the estate because the debtors had not filed a cross appeal.”
Lehecka v. Tier Tech., Inc., 109 P.3d 1212 (Kan. 2005). “Our analysis begins with the language of the attorney’s hen statute, K.S.A. 7-108, which reads: *285 “An attorney has a lien for a general balance of compensation upon any papers of his or her client which have come into the attorney’s possession in the course of his or her…”
In Re the Marriage of Wageman, 968 P.2d 1114 (Kan. Ct. App. 1998). “While the foregoing authorities are not directly applicable here, Wageman argues that they support a public policy which generally *685 protects child support funds from creditors.”
Carlson v. United States of Am. (D. Kan. 2020). “, (WHM) before it was formally allowed to withdraw as Carlson’s counsel.”
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