Kansas Statutes Annotated

K.S.A. § 9-103 (2026)

Repealed

✓ current as of May 2026
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9-103.

History: L. 1897, ch. 47, § 3; R.S. 1923, § 9-103; Repealed, L. 1947, ch. 102, § 143; June 30.

Notes of Decisions
Cited in 12 cases (2 in the last 5 years), 1973–2024 · leading case: In Re Ford, 387 B.R. 827 (Bankr. D. Kan. 2008).
In Re Ford, 387 B.R. 827 (Bankr. D. Kan. 2008). · cites it 6× “As noted in Meyer’s Primer, Kansas did not adopt the uniform version of revised section 9-103(h) [limiting § 9-103(e), (f), and (g) to commercial transactions] in its revision to Article 9 and did not adopt all of the uniform version of revised section 9-103(f).”
Citifinancial Auto v. Hernandez-Simpson, 369 B.R. 36 (D. Kan. 2007). · cites it 3× “of the Official Comment to § 9-103, the foregoing language of sub-paragraph (f) approves what courts have referred to as the “dual-status rule.”
In Re Vega, 344 B.R. 616 (Bankr. D. Kan. 2006). · cites it 2× “This matter has now been settled by the Kansas legislature’s decision to statutorily reject certain parts of the revised § 9-103 of Article 9 adopted by the National Conference of Commissioners on Uniform State Laws (NCCUSL).”
Am. State Bank v. White, 535 P.2d 424 (Kan. 1975). · cites it 4× “) In contrast with this, the four-month period provided in subsection (3) of section 9-103 of the Uniform Commercial Code is not a grace period for filing; it is an absolute period of protection of the vendors security interest designed to give him adequate time to make an…”
In Re Trotter, 264 B.R. 216 (Bankr. D. Kan. 2001). · cites it 2× “As the Stinnett court noted, The majority of courts similarly hold that the section 9-103 governs the perfection and legal effect of perfection of a security interest despite the co-existence of state statutes requiring registration and licensing in the state of the owners…”
In Re Dobbins, 371 F. Supp. 141 (D. Kan. 1973). · cites it 2× “§ 9-103(2), was in Oklahoma City, Oklahoma, where Hahn’s home office was located, and therefore that Oklahoma law controlled perfection of its security interest.”
Morris v. Gen. Motors Acceptance Corp. (In re Ball), 281 B.R. 706 (Bankr. D. Kan. 2002). · cites it 2× “§ 84 — 9—103(2)(c) directs us to subsection (l)(d) of section 9-103 for the perfection rules. A reading of subsections (2)(c) and (l)(d) together requires this Court to determine whether GMAC’s lien was perfected under Oklahoma law even though no certificate of title was issued…”
Schnuelle v. C & C Auto Sales, Inc., 99 F. Supp. 2d 1294 (D. Kan. 2000). “§ 9-103. Therefore, any damages pled by plaintiffs relating to the truck’s title arose from SAS’s actions in wrongfully repossessing the truck, not from C & C’s alleged misrepresentations.”
Morris v. Boeing Wichita Credit Union (In Re Moddelmog), 291 B.R. 545 (D. Kan. 2003). · cites it 4× “The Official UCC Comment to § 9-103 explains that under this provision “[t]he security interest perfected by notation on a certificate of title will be recognized without limit as to time; but .”
Andrew Heath Alexander & Jennifer Lynn Alexander (Bankr. D. Kan. 2024). · cites it 2× “Former Section 9-103(2)(b) provided that the law of the jurisdiction issuing the certificate ceases to apply upon “surrender” of the certificate.”
In Re Townsend, 387 B.R. 817 (Bankr. D. Kan. 2008). · cites it 2× “” 9 The Court therefore starts its analysis by examining Article 9 of the Missouri Uniform Commercial Code, section 9-103, which defines purchase-money security interest.”
United States v. Dunn (D. Kan. 2023). “35 See UCC §§ 9-103(b)(1), -309(1), -310(b)(2). 36 Stanley Bank, 264 P.”
— K.S.A. § 9-103(2) — 2 cases
In Re Dobbins, 371 F. Supp. 141 (D. Kan. 1973). “§ 9-103(2), was in Oklahoma City, Oklahoma, where Hahn’s home office was located, and therefore that Oklahoma law controlled perfection of its security interest.”
Morris v. Boeing Wichita Credit Union (In Re Moddelmog), 291 B.R. 545 (D. Kan. 2003). “The Official UCC Comment to § 9-103 explains that under this provision “[t]he security interest perfected by notation on a certificate of title will be recognized without limit as to time; but .”
— K.S.A. § 9-103(2)(b) — 1 case
Andrew Heath Alexander & Jennifer Lynn Alexander (Bankr. D. Kan. 2024). “Former Section 9-103(2)(b) provided that the law of the jurisdiction issuing the certificate ceases to apply upon “surrender” of the certificate.”
— K.S.A. § 9-103(4) — 1 case
In Re Dobbins, 371 F. Supp. 141 (D. Kan. 1973). “§ 9-103(2), was in Oklahoma City, Oklahoma, where Hahn’s home office was located, and therefore that Oklahoma law controlled perfection of its security interest.”
— K.S.A. § 9-103(b) — 1 case
In Re Vega, 344 B.R. 616 (Bankr. D. Kan. 2006). “This matter has now been settled by the Kansas legislature’s decision to statutorily reject certain parts of the revised § 9-103 of Article 9 adopted by the National Conference of Commissioners on Uniform State Laws (NCCUSL).”
— K.S.A. § 9-103(b)(1) — 1 case
United States v. Dunn (D. Kan. 2023). “35 See UCC §§ 9-103(b)(1), -309(1), -310(b)(2). 36 Stanley Bank, 264 P.”
— K.S.A. § 9-103(e) — 1 case
In Re Ford, 387 B.R. 827 (Bankr. D. Kan. 2008). “As noted in Meyer’s Primer, Kansas did not adopt the uniform version of revised section 9-103(h) [limiting § 9-103(e), (f), and (g) to commercial transactions] in its revision to Article 9 and did not adopt all of the uniform version of revised section 9-103(f).”
— K.S.A. § 9-103(f) — 2 cases
In Re Ford, 387 B.R. 827 (Bankr. D. Kan. 2008). “As noted in Meyer’s Primer, Kansas did not adopt the uniform version of revised section 9-103(h) [limiting § 9-103(e), (f), and (g) to commercial transactions] in its revision to Article 9 and did not adopt all of the uniform version of revised section 9-103(f).”
Citifinancial Auto v. Hernandez-Simpson, 369 B.R. 36 (D. Kan. 2007). “of the Official Comment to § 9-103, the foregoing language of sub-paragraph (f) approves what courts have referred to as the “dual-status rule.”
— K.S.A. § 9-103(h) — 1 case
In Re Ford, 387 B.R. 827 (Bankr. D. Kan. 2008). “As noted in Meyer’s Primer, Kansas did not adopt the uniform version of revised section 9-103(h) [limiting § 9-103(e), (f), and (g) to commercial transactions] in its revision to Article 9 and did not adopt all of the uniform version of revised section 9-103(f).”
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