Kansas Family Law Appeals 2026

Supreme Court

January 29, 2026

Published

129332 – In re Common Law Marriage of Kelley – Wyandotte – Affirmed. [Common law marriage, marriage, elements, appellate jurisdiction, federal income tax law, name change, holding out, capacity to marry, present intent]

January 16, 2026

Published

128161 – In the Interest of K.R. – Reno – Review of the judgment of the Court of Appeals in an unpublished opinion filed July 25, 2025. Judgment of the Court of Appeals affirming the district court is reversed. Judgment of the district court is reversed. Case is remanded with directions. [CINC, required elements, clear and convincing evidence, required findings. K.S.A. 38-2269 permits a district court to terminate parental rights only after first finding by clear and convincing evidence that the parent is unfit and that the conduct or condition of unfitness is unlikely to change in the foreseeable future. Absent these statutorily required findings, the district court lacks authority to terminate parental rights.]

Court of Appeals

July 17, 2026

Unpublished

129907 – In the Interests of A.C., I.P., and K.C. – Leavenworth – Affirmed. [CINC, parent termination, sufficiency of evidence, appellate standards, clear and convincing evidence, proffer of evidence, constitutional right to parent]

128915 – State ex rel. Secretary of DCF v. A.J.C. – Wyandotte – Reversed and remanded with directions. District court allowed revocation of voluntary acknowledgement of parentage outside the 12 month required period to institute the revocation. Trial court erred by granting exception without any legal basis or authoriation. [Parentage, voluntary acknowledgment of parentage, VAP, revocation of voluntary acknowledgment of parentage, time limitations, appellate standards, issue of law, child support enforcement]

July 10, 2026

Unpublished

128983 – In re Adoption of Baby Boy C. – Sedgwick – Affirmed. [Adoption, agency adoption, unfitness, failure to support child, failure to provide support during pregnancy, sufficiency of evidence, clear and convincing evidence]

June 26, 2026

Unpublished

129560 – In the Interests of N.R. and E.R. – Reno – Affirmed. [CINC, parent termination, appellate standards, mental health treatment, continued dangerous drug use, failure to provide stable environment, clear and convincing evidence, sufficiency of evidence]

June 18, 2026

Unpublished

128779 – B.M. v. K.J. – Johnson – Affirmed. [PFA, Attorneys fees against petitioner, appellate standards, judicial discretion, failure to appear for trial, non-frivolous allegations]

June 12, 2026

Published

129334 – Allison v. Sabin-Mitchell et al. – Elk – Affirmed. [Estates, probate, homestead rights, premarital agreement, uniform premarital agreement act, UPAA, whether homestead rights may be waived in premarital agreement, waiver of homestead rights in premarital agreement does not violate Kansas Constitution]

June 5, 2026

Unpublished

129747 – N.D. v. J.D. – Sumner – Affirmed. [PFA, protection from abuse, appellate standards, sufficiency of evidence, fear of imminent harm, separated parties, harassment at home of parents]

129431 – In the Interests of O.O – Wyandotte – Affirmed. [CINC, parent termination, sufficiency of evidence, appellate standards, clear and convincing evidence, addition impacting children, previous terminations, constitutional right to parent, failure of consistent communications]

May 29, 2026

Unpublished

129500 – In the Interest of M.K. – Norton – Affirmed. [CINC, parent termination, denial of new counsel request on day of trial, abuse of discretion, failure to consider permanent guardianship, appellate standards, clear and convincing evidence, judicial discretion, drug use, ongoing domestic violence, ongoing concerns]

May 22, 2026

Unpublished

127422 – In re Marriage of Gracey and Albawardi – Sedgwick – Affirmed. [Marriage, common law marriage, divorce, jurisdiction, subject matter jurisdiction, personal jurisdiction, international family law, appellate standards, substantial competent evidence, common law marriage as mixed question of law and fact, presumed validity of subsequnt marriage, continuous marriage despite divorce, elements of common law marriage, Islamic law, out of state process service, lived in marital relationship in Kansas, Kansas property ownership]

May 8, 2026

129407 – S.S. v. T.S. – Hodgeman – Affirmed. [Protection from abuse, PFA, appellate standards, substantial competent evidence, abuse of discretion, physical injury, threat of physical injury, parental discipline]

April 10, 2026

Unpublished

129203 – J.M.D. v. L.G.H. – Linn – Appeal Dismissed as moot. [Protection from Stalking, PFS, Mootness, expired orders, appellate jurisdiction, advisory opinions]

April 3, 2026

Unpublished

127849 – In re Marriage of Castillo and Alvarado – Wyandotte – Affirmed. [Divorce, self-representation, judicial warnings, alleged error by judge allowing party to self-represent, judicial bias, abuse of discretion, self-represented parties are presumed to know and understand the law, alleged violations of procedural due process, failure to timely raise issues, appellate jurisdiction, judicial recusal]

127499 – Diosdado v. H.G. – Johnson – Affirmed in part, reversed in part, and remanded with directions. [Defamation, Protection from Stalking, PFS, alleged rape, Kansas Public Speech Protection Act, KPSPA, false light invasion of privacy, intentional infliction of emotional distress, free speech, right to petition, statutory interpretation, anti-SLAPP, public issue, PFS as protected speech, public official, allegations of criminal conduct, protected statements include public and private statements, absolute privilege, elements of absolute privilege, failure to raise issue to district court, appellate attorneys fees]

February 27, 2026

Unpublished

128485 – Duran v. Christena – Sedgwick – Affirmed. [Marriage, common law marriage, elements of common law marriage, appellate standards, fact determinations, substantial competent evidence, no common law marriage]

February 6, 2026

Unpublished

128647 – In the Interests of J.N.N. and J.P.N. – Shawnee – Affirmed. [CINC, parent termination, appellate standards, claimed insufficient evidence, clear and convincing evidence, unstable parenting, lack of mental health therapy, failure to complete dependency tasks, child’s best interests, inability to care without assistance]

January 23, 2026

Unpublished

128929 – In the Interests of J.A.S.P. and J.D.P. – Sumner – Affirmed. [CINC, parent termination, appellate standards, claimed insufficient evidence, clear and convincing evidence, substance abuse, repeated incarcerations, failure to complete dependency tasks, child’s best interests]

128950 – In the Interests of G.R.H. and S.J.H. – Sedgwick – Affirmed. [CINC, parent termination, appellate standards, multiple criminal convictions, unsuitable environment, clear and convincing evidence, failure to complete tasks, child’s best interests]

January 16, 2026

Unpublished

127613 – In re Marriage of Bates – Johnson – Affirmed. [Divorce, military retirement benefits, 10/10 Rule, DFAS, direct pay, dormant and expired judgments, new judgment each due date, periodic payments on judgment]

January 9, 2026

Unpublished

128991 – In the Interests of L.X.-Y. and G.R.-X. – Ford – Reversed and remanded with directions. [CINC, reliance on a proffer alone cuts against the mandate imposed by K.S.A. 38-2269(a) that clear and convincing evidence must support a district court’s unfitness findings. As a result, while a proffer can be used at an evidentiary termination hearing, a party “will need to present more to establish unfitness.” Mother involuntarily deported from the United States did not “wilfully abandon” her children.]