K.S.A. » Chapter 75
Kansas Statutes Annotated

K.S.A. § 75-4351 (2026)

Interpreters appointed for deaf, hard of hearing, speech impaired and persons whose primary language is other than English; proceeding in which appointment authorized

✓ current as of May 2026
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75-4351. Interpreters appointed for deaf, hard of hearing, speech impaired and persons whose primary language is other than English; proceeding in which appointment authorized. A qualified interpreter shall be appointed in the following cases for persons whose primary language is one other than English, or who is a deaf, hard of hearing or speech impaired person: (a) In any grand jury proceeding, when such person is called as a witness;

(b) in any court proceeding involving such person and such proceeding may result in the confinement of such person or the imposition of a penal sanction against such person;

(c) in any civil proceeding, whether such person is the plaintiff, defendant or witness in such action;

(d) in any proceeding before a board, commission, agency, or licensing authority of the state or any of its political subdivisions, when such person is the principal party in interest;

(e) prior to any attempt to interrogate or take a statement from a person who is arrested for an alleged violation of a criminal law of the state or any city ordinance.

History: L. 1972, ch. 341, § 1; L. 1973, ch. 364, § 1; L. 1993, ch. 223, § 5; July 1.

Notes of Decisions
Cited in 28 cases (5 in the last 5 years), 1984–2025 · leading case: Khalil-Alsalaami v. State, 486 P.3d 1216 (Kan. 2021).
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Khalil-Alsalaami v. State, 486 P.3d 1216 (Kan. 2021). · cites it 21× “K.S.A. 75-4351 does not create new constitutional protections.”
State v. Ngan Pham, 136 P.3d 919 (Kan. 2006). · cites it 5× “They authorize the expenditure of public funds for that purpose. The statutes do not contain any sanctions for violations thereof.”
State v. Bishop, 957 P.2d 369 (Kan. 1998). · cites it 8× “8-1001; because an interpreter had not been properly provided to Bishop, as required by K.S.A. 75-4351; and because there had not been a proper evidentiaiy foundation laid for the test.”
State v. Calderon, 13 P.3d 871 (Kan. 2000). · cites it 4× “To ensure that individuals whose primary language is not English receive a fair trial, K.S.A. 75-4351 provides, in part: "A qualified interpreter shall be appointed .”
State v. Giang Nguyen, 133 P.3d 1259 (Kan. 2006). · cites it 3× “75-4353 sets forth the required qualifications for interpreters: “(a) No one shall be appointed to serve as an interpreter for a person pursuant to the provisions of K.S.A. 75-4351, and amendments thereto, if such interpreter is married to that person, related to that person…”
State v. Pham, 675 P.2d 848 (Kan. 1984). · cites it 3× “K.S.A. 75-4351 directs a qualified interpreter shall be appointed for a person whose primary language is one other than English in any court proceeding involving such person where such proceeding may result in the confinement of such person or the imposition of a penal sanction…”
State v. Nguyen, 833 P.2d 937 (Kan. 1992). · cites it 4× “He was sentenced to two concurrent life sentences for the felony murders and three 5-20 year terms for the other charges, to run concurrently to each other and consecutively to the life sentences. I. SUPPRESSION ISSUE The defendant claims he did not voluntarily and knowingly…”
State v. Zuniga, 703 P.2d 805 (Kan. 1985). · cites it 4× “He raises five issues, contending that his post-arrest statement to a detective should have been suppressed because the State did not comply with K.S.A. 75-4351; that the trial court erred in excluding from evidence the results of a pregnancy test; that the court erred in…”
State v. Salcido-Corral, 940 P.2d 11 (Kan. 1997). · cites it 3× “While neither party cites it, K.S.A. 1996 Supp. 75-4351 governs the appointment of interpreters for persons whose primaiy language is not English.”
In the Interest of Doe, 57 P.3d 447 (Haw. 2002). “”); Kan. Stat. Ann. § 75-4351 (2000) ("A qualified interpreter shall be appointed .”
State v. Montano, 855 P.2d 979 (Kan. Ct. App. 1993). · cites it 8× “K.S.A. 75-4351 K.S.A. 75-4351 requires the appointment of an interpreter under certain circumstances for a person whose primary language is not English.”
State v. Garcia, 763 P.2d 585 (Kan. 1988). · cites it 2× “First, he contends that the State has failed to establish that the statements were voluntarily made, or made in compliance with K.S.A. 75-4351. That statute provides in part: “A qualified interpreter shall be appointed in the following cases for persons whose primary language is…”
Show all 28 citing cases →
— K.S.A. § 75-4351(b) — 3 cases
State v. Tran (Kan. Ct. App. 2020).
Franco-Monserrate v. State (Kan. Ct. App. 2022).
Khalil-Alsalaami v. State (Kan. Ct. App. 2017).
— K.S.A. § 75-4351(e) — 11 cases
State v. Ngan Pham, 136 P.3d 919 (Kan. 2006). “They authorize the expenditure of public funds for that purpose. The statutes do not contain any sanctions for violations thereof.”
State v. Nguyen, 833 P.2d 937 (Kan. 1992). “He was sentenced to two concurrent life sentences for the felony murders and three 5-20 year terms for the other charges, to run concurrently to each other and consecutively to the life sentences. I. SUPPRESSION ISSUE The defendant claims he did not voluntarily and knowingly…”
State v. Giang Nguyen, 133 P.3d 1259 (Kan. 2006). “75-4353 sets forth the required qualifications for interpreters: “(a) No one shall be appointed to serve as an interpreter for a person pursuant to the provisions of K.S.A. 75-4351, and amendments thereto, if such interpreter is married to that person, related to that person…”
State v. Zuniga, 703 P.2d 805 (Kan. 1985). “He raises five issues, contending that his post-arrest statement to a detective should have been suppressed because the State did not comply with K.S.A. 75-4351; that the trial court erred in excluding from evidence the results of a pregnancy test; that the court erred in…”
State v. Garcia, 763 P.2d 585 (Kan. 1988). “First, he contends that the State has failed to establish that the statements were voluntarily made, or made in compliance with K.S.A. 75-4351. That statute provides in part: “A qualified interpreter shall be appointed in the following cases for persons whose primary language is…”
— K.S.A. § 75-4351(h) — 1 case
State v. Pham, 675 P.2d 848 (Kan. 1984). “K.S.A. 75-4351 directs a qualified interpreter shall be appointed for a person whose primary language is one other than English in any court proceeding involving such person where such proceeding may result in the confinement of such person or the imposition of a penal sanction…”
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