Kansas
Kansas Public Records Laws: The Kansas Open Records Act (KORA) Explained
Independently fact-checked against primary sources (last audited August 4, 2026). · Law checked current as of August 9, 2026. · 6 primary sources cited on this page. How we verify our legal content

The Kansas Open Records Act, K.S.A. 45-215 et seq., opens public records to any person with no residency requirement. Its most distinctive feature is what it does with police video: K.S.A. 45-254 classifies every body camera and vehicle camera recording as a criminal investigation record, then carves out a narrow 20-day viewing right for the people actually in the footage.
Information last verified on 2026-08-04. This article has not yet been reviewed by a licensed lawyer.
This page covers Kansas state law only. For records held by a federal agency, see our guide on how to file a FOIA request. To compare Kansas against other states, start at the public records laws by state hub.
The Kansas Open Records Act
KORA, codified at K.S.A. 45-215 and following, governs access to records held by Kansas state agencies, counties, cities, school districts, universities, and other public agencies. Its core rule is in K.S.A. 45-218(a): all public records shall be open for inspection by any person, except as otherwise provided by the act.
Kansas does not call its law FOIA, and KORA does not reach federal agencies. A request for federal records goes to the federal agency under 5 U.S.C. 552.
Who Can Request Records in Kansas
Any person may request. KORA imposes no residency requirement, no citizenship requirement, and no requirement that you be a Kansas taxpayer. That places Kansas in the majority of states and on the opposite side from resident-only Kentucky.
The act also does not condition access on your explaining what you plan to do with the records for ordinary requests. Certain narrow categories, such as requests for records containing names and addresses that could be used for commercial solicitation, carry their own statutory conditions, but the general rule imposes no purpose test.
Kansas Response Deadlines
KORA actually sets two separate 3-business-day rules, and it is easy to conflate them.
The first is a general response deadline. Under K.S.A. 45-218(d), a public agency must act on every request for access to a public record as soon as possible, but not later than the end of the third business day following the date the request is received. If access is not granted immediately, the custodian must give a detailed explanation of the cause for the delay and the earliest date the record will be available.
The second is a separate, later clock that applies only if you are denied. If an agency denies access to a record in whole or in part, it must furnish, upon request, a written statement of the grounds for denial, citing the specific provision of law relied on, and that statement is due by the end of the third business day following the date the request for that statement is received.
So there are two 3-day windows, not one: the agency's initial 3 business days to act on your request, and a second, independent 3 business days to furnish written grounds for a denial once you specifically ask for that statement. That written statement is valuable regardless. It forces the agency to name the exemption it is relying on, which is what you need to evaluate whether the denial is defensible and what a court would later review. These provisions are current as of August 2026.
When a Custodian Can Refuse Outright
The same statute that creates the right of access also limits it, and this limit sits outside the exemption list most guides stop at. K.S.A. 45-218(e) provides that the custodian may refuse to provide access to a public record, or to permit inspection, if a request places an unreasonable burden in producing public records, or if the custodian has reason to believe that repeated requests are intended to disrupt other essential functions of the public agency.
That is a separate ground from the K.S.A. 45-221 exemptions discussed below. It turns on the shape and volume of the request rather than the content of the record, which is why it can be raised against records nobody claims are confidential.
The check on it is evidentiary: a refusal under this subsection must be sustained by a preponderance of the evidence. An agency has to show the burden or the disruptive intent, not merely assert it. Practically, the fastest answer to a burden objection is to narrow the request by date range, department, or record type, and to ask the custodian in writing what narrowing would make it manageable. That exchange is also what a court would look at later.
What Kansas Records Requests Cost
K.S.A. 45-219 governs fees, and Kansas takes a cost-recovery approach rather than a capped-rate approach.
An agency may charge reasonable fees not to exceed the actual cost of furnishing the requested records, including the cost of staff time necessary to make the records available. Two limits matter. Staff time must be charged at the lowest-cost category of employee reasonably necessary to do the work, so an agency cannot bill a lawyer's rate for photocopying. And employee benefits are excluded from the calculation.
Kansas does not set a statutory per-page copy cap the way Georgia, Illinois, and Florida do. If you have seen a figure such as 25 cents per page described as automatically reasonable under Kansas law, treat it with caution; that language does not appear in the current text of K.S.A. 45-219. Individual agencies do publish their own fee schedules under their KORA policies, and those published rates are the practical figure for any given agency. Ask for the agency's fee schedule and an estimate before authorizing work.
K.S.A. 45-219(e) then adds a cost-mitigation step with a deadline attached, and the deadline is the part that catches requesters. When the staff time needed to respond will exceed five hours, or the estimated actual cost for staff time needed to fill the request exceeds $200, the agency must make reasonable efforts to contact you, using the means of communication you gave it for responses, and engage in interactive communication about mitigating the cost.
You are not required to reduce your request. You are required to answer. If the agency has made those reasonable efforts and you have not responded by the end of the third business day, the request is deemed withdrawn until a subsequent contact has been made by you to the agency. Nothing is denied, so there is no denial to appeal and no written statement of grounds to demand; the request simply stops, and it stops quietly.
Two habits prevent this. Give the agency an address you actually monitor, and on any large request treat the first three business days after filing as live. Even a reply saying you want the request to proceed as written keeps it open.
Kansas gives you something most states do not: a route to challenge a fee without going to court. A person requesting records within the executive branch may appeal the reasonableness of the fees charged to the Secretary of Administration, whose decision is final. That is a fee-specific remedy. It resolves whether the charge is reasonable, not whether the record should have been released, so it does not substitute for the denial remedies below.
KORA does not include a federal-style public-interest fee waiver you can claim as of right. The cost-recovery ceiling and the fee-reasonableness appeal are the protections instead.
How to File a Kansas Open Records Request
Kansas has no central portal. Requests go to the individual agency's freedom of information officer or records custodian. Kansas agencies are required to designate a local freedom of information officer, and the contact is usually published on the agency website.
- Identify the agency and its freedom of information officer.
- Put the request in writing, by email or letter. Writing establishes the dates you will need for any denial statement or court action.
- Describe the records specifically. Because Kansas bills actual staff time, narrowing a request by date, department, or record type has a direct effect on the price.
- Ask for the agency's fee schedule and a cost estimate before it begins work.
- If you are denied, immediately request the written statement of grounds under K.S.A. 45-218(d). Do this in writing so the third-business-day clock is documented.
- Keep everything.
Our free FOIA request generator produces a Kansas-specific request letter citing KORA. Nothing typed into it is stored or transmitted.
Exemptions Under KORA
KORA's exemptions appear principally in K.S.A. 45-221, which lists records an agency is not required to disclose. The list is long and includes personnel records, medical records, records of an ongoing criminal investigation, notes and preliminary drafts, attorney work product, certain security information, and information that other state or federal law makes confidential.
Two features of Kansas practice are worth knowing. Most exemptions are permissive rather than mandatory, meaning the statute says the agency is not required to disclose rather than that it must not. An agency therefore often has discretion to release, and asking it to exercise that discretion is a legitimate request. And when only part of a record is exempt, the agency should redact and release the remainder rather than withholding the whole document.
Police Records and Body Camera Footage
This is where Kansas departs most sharply from its neighbors, and where getting the mechanics right matters most.
Ordinary police records are subject to the criminal investigation records exemption while a matter is active. But K.S.A. 45-254 goes further with video. It provides that every audio or video recording made and retained by law enforcement using a body camera or a vehicle camera shall be considered a criminal investigation record.
That classification is categorical. It does not depend on whether a particular recording captured anything investigative. A traffic stop, a welfare check, a routine call, all of it is a criminal investigation record by definition, which places it outside ordinary KORA disclosure to the general public.
Against that backdrop, the statute creates a narrow but real access right for the people with the strongest stake in the footage. The following may request to listen to a requested audio recording or view a requested video recording:
- The person depicted in the recording.
- A parent or legal guardian of a minor depicted in the recording.
- An heir at law of a deceased person depicted in the recording.
- An attorney representing any of the people above.
When such a request is made, the agency must allow that person to listen to or view the recording within 20 days after the request. Reasonable fees may apply.
Read the verb carefully, because this is the single most common Kansas misunderstanding. The statutory right is to listen or view. It is not automatically a right to be handed a copy of the file. In practice this often means an appointment at the agency to watch the footage rather than a download link in your inbox. You can certainly ask for a copy, and agencies sometimes provide one, but the enforceable 20-day obligation under this provision is the viewing.
Two practical consequences. If you are in the footage, say so explicitly and identify which of the four categories you fall into, because the right depends on that status. And if litigation is realistic, the discovery process, not KORA, is usually how a copy is obtained.
For 911 audio and dispatch records, which are not body camera recordings and are analyzed separately, see our page on whether 911 calls are public records.
Appealing a Denial in Kansas
Kansas has no records ombudsman that issues binding decisions on disclosure. There is no equivalent of the Illinois Public Access Counselor's binding opinion. Kansas instead gives you two enforcement channels.
The Attorney General
The Kansas Attorney General has independent investigative and enforcement authority under K.S.A. 45-251. The Attorney General may investigate an alleged violation and may issue a finding of violation or enter into a consent order with the agency before any court action is filed. Filing a complaint with the Attorney General costs nothing and is the sensible first step for many requesters, particularly where the dispute is about an agency's blanket practice rather than a single judgment call.
District Court
Under K.S.A. 45-222, a civil action may be brought in the district court of the county where the records are located, seeking an injunction, mandamus, or other appropriate order. Any person may bring it, and so may the Attorney General or a county or district attorney.
The procedural rules favor requesters in two important ways. The court reviews the matter de novo, meaning it decides the question fresh rather than deferring to the agency's judgment. And the burden of proof rests on the public agency to justify withholding, not on you to justify access.
On fees, the court shall award costs and reasonable attorney fees to the plaintiff if it finds the agency's denial was not in good faith and without a reasonable basis in fact or law. That is a meaningful standard but not an automatic one; an agency that loses a close, honestly argued call may not have to pay your fees.
Fee-shifting under K.S.A. 45-222 runs both ways, and the second direction is the one requesters rarely hear about. Subsection (e) is the mirror image of the provision above: where the defendant is the prevailing party, the court shall award to the defendant costs and a reasonable sum as an attorney's fee if it finds that the plaintiff maintained the action not in good faith and without a reasonable basis in fact or law. The verb is shall in both directions.
Losing a KORA suit does not by itself put you on the hook for the agency's legal bill, because the same good-faith and reasonable-basis test has to fail on your side of the case. But a requester deciding whether to sue is deciding under a two-way mandatory fee-shift, not a one-way one. Be able to point to the specific statutory basis for the access you are asking a court to order, and treat a suit filed to make a point rather than to obtain a record as carrying real financial exposure.
Records KORA Does Not Reach
Birth, death, and marriage certificates are vital records held by the Kansas Department of Health and Environment under a separate statutory scheme with eligibility limits on who may receive a certified copy. They are not KORA records. Our Kansas death records guide explains who qualifies and how to order.
Deeds and land records are county register of deeds records, covered in our Kansas property records guide. Court case files and warrants are court records rather than agency records; see Kansas warrant search.
Related articles
Disclaimer
This article provides general legal information about the Kansas Open Records Act as of August 2026. It is not legal advice and does not create an attorney-client relationship. Statutes, agency fee schedules, and procedures change. If a public records dispute affects your legal rights, consult an attorney licensed in Kansas about your specific situation.
Last updated: 2026-08-04.
Frequently Asked Questions
Do I have to live in Kansas to request public records?
No. K.S.A. 45-218(a) opens all public records to inspection by any person, with no residency or citizenship requirement.
Does Kansas have a 3-day deadline for public records requests?
Yes, for acting on the request. Under K.S.A. 45-218(d), an agency must act on a request as soon as possible, and no later than the end of the third business day after it is received. That deadline is about acting, not necessarily producing the records immediately; if access is not granted right away, the custodian must explain the delay and give the earliest available date. A separate 3-day clock applies if you are denied: on request, the agency's written statement of the grounds for denial is due by the end of the third business day after that request for the statement is received.
Can a Kansas agency refuse my request as too burdensome?
Yes. K.S.A. 45-218(e) lets a custodian refuse to provide access, or to permit inspection, if a request places an unreasonable burden in producing public records, or if the custodian has reason to believe that repeated requests are intended to disrupt other essential functions of the public agency. That is separate from the K.S.A. 45-221 exemptions, and it is not automatic: a refusal on this ground must be sustained by a preponderance of the evidence. Narrowing the request by date range, department, or record type is usually the fastest way past it.
How much can a Kansas agency charge for records?
KORA limits fees to the actual cost of furnishing the records, including staff time charged at the lowest-cost category of employee reasonably necessary to do the work, with employee benefits excluded. There is no statutory per-page cap in Kansas the way there is in Illinois, Georgia, or Florida, so individual agencies set published rates. Ask for the agency's fee schedule and an estimate before work begins.
Can my Kansas request be closed just because I did not reply?
Yes. Under K.S.A. 45-219(e), once the staff time needed will exceed five hours or the estimated actual cost for staff time exceeds $200, the agency must make reasonable efforts to contact you and discuss mitigating the cost. If it has made those efforts and you have not responded by the end of the third business day, the request is deemed withdrawn until you contact the agency again. You are not obligated to narrow the request, but you do have to answer, so monitor the address you gave the agency.
What if I think the fee is too high?
For records within the executive branch, a requester may appeal the reasonableness of the fees charged to the Secretary of Administration, whose decision is final. That remedy decides whether the charge is reasonable, not whether the record should be released, so it is separate from challenging a denial.
Is there a public-interest fee waiver in Kansas?
KORA does not create one you can claim as of right. The cost-recovery limit and the fee-reasonableness appeal to the Secretary of Administration are the cost protections instead. An agency may reduce or waive charges at its discretion, so asking costs nothing.
Can I get police body camera footage in Kansas?
Not as a member of the general public. K.S.A. 45-254 classifies every audio or video recording made and retained by law enforcement using a body camera or vehicle camera as a criminal investigation record, which puts it outside ordinary KORA disclosure. A narrow group has a statutory viewing right: the person depicted, a parent or guardian of a depicted minor, heirs at law of a depicted deceased person, and attorneys representing any of them.
If I am in the video, do I get a copy?
The enforceable right under K.S.A. 45-254 is to listen to or view the recording, and the agency must allow that within 20 days of the request. Reasonable fees may apply. It is not automatically a right to receive a copy of the file, which often means viewing it at the agency. You can ask for a copy, and agencies sometimes provide one, but if a copy is essential, litigation discovery is usually the realistic route.
How long does the agency have to let me view the footage?
Within 20 days after the request is made, for a requester who falls into one of the four categories K.S.A. 45-254 names.
Can I appeal a Kansas records denial to a state board?
There is no Kansas board that issues binding disclosure decisions. Your options are a complaint to the Attorney General, who has investigative and enforcement authority under K.S.A. 45-251 and may issue a finding of violation or enter a consent order, or a civil action under K.S.A. 45-222 in the district court of the county where the records are located.
Who has to prove the record should be withheld?
The agency. In a K.S.A. 45-222 action the court reviews the matter de novo and the burden of proof rests on the public agency. Fees, however, shift in both directions. The court shall award costs and reasonable attorney fees to the plaintiff if the denial was not in good faith and lacked a reasonable basis in fact or law, and under subsection (e) shall award costs and a reasonable attorney fee to a prevailing defendant if it finds the plaintiff maintained the action not in good faith and without a reasonable basis in fact or law.
Are Kansas exemptions mandatory?
Most of the exemptions in K.S.A. 45-221 are written as records an agency is not required to disclose, which leaves the agency discretion to release them anyway. Asking an agency to exercise that discretion is a legitimate request, and it is a different argument from claiming the record is not exempt at all.
Can I use KORA to get a Kansas death certificate?
No. Vital records are held by the Kansas Department of Health and Environment under a separate statutory scheme with eligibility limits on who may obtain a certified copy. A KORA request will not produce one.
Updates
Added the limits and risks Kansas requesters were not being shown: the custodian’s power under K.S.A. 45-218(e) to refuse an unreasonably burdensome or disruptive repeat request, the K.S.A. 45-219(e) rule that a request is deemed withdrawn if you do not answer a cost-mitigation contact within three business days, and the fact that K.S.A. 45-222 fee-shifting runs in both directions rather than only in the requester’s favor.
Governing law re-checked for recent changes
Corrected the response-deadline section, a KeyTakeaways bullet, and an FAQ answer: K.S.A. 45-218(d) sets two distinct 3-business-day clocks (act on every request; furnish written denial grounds on request), not a single denial-only deadline as the article previously said.
Governing law re-checked for recent changes
Independently fact-checked against the cited primary sources
The Law Behind This Article
This article rests on the statutory provisions below, held in our own legal record and retrieved from the official source. Tap a section to read the operative text.
Kansas Statutes Annotated, Chapter 45: PUBLIC RECORDS, DOCUMENTS AND INFORMATION
§ 45-218Inspection of records; request; response; refusal, when; fees.In forcecited in 3 of our articles
(a) All public records shall be open for inspection by any person, except as otherwise provided by this act, and suitable facilities shall be made available by each public agency for this purpose. No person shall removal* original copies of public records from the office of any public agency without the written permission of the custodian of the record. (b) Upon request in accordance with procedures adopted under K.S.A. 45-220, any person may inspect public records during the regular office hours of the public agency and during any additional hours established by the public agency pursuant to K.S.A. 45-220. (c) If the person to whom the request is directed is not the custodian of the public record requested, such person shall so notify the requester and shall furnish the name and location of the custodian of the public record, if known to or readily ascertainable by such person. (d) Each request for access to a public record shall be acted upon as soon as possible, but not later than the end of the third business day following the date that the request is received.
Official text (excerpt) · last checked 2026-09-02 · Read the full text in our law library · Verify at ksrevisor.gov
Cited in 31 court opinions in our collectionLatest citing opinion in our collection: 2025
In the courts (editorial summary, independently checked):Telegram Publishing Co. v. Kansas Department of Transportation (2003) held an agency's failures to respond within three business days violated K.S.A. 45-218(d). Baker v. Hayden (2021) read 45-218(a) as letting any person seek records without stating a purpose, but dismissed on standing without reaching the merits.
Opinions citing this section in our collection:
- Baker v. Hayden (Supreme Court of Kansas 2021, 490 P.3d 1164)✓An attorney was denied audio recordings of two open court hearings and later obtained them. The court held section 45-218(a) gave him statutory standing as any person, but he lost traditional standing once he had the recordings, so it dismissed without reaching the merits.
- Telegram Publishing Co. v. Kansas Department of Transportation (Supreme Court of Kansas 2003, 275 Kan. 779)✓A newspaper made three records requests for railroad crossing hazard rankings and got late or hollow responses. The court held each response violated section 45-218(d)'s three-business-day requirement and that the agency acted in bad faith, awarding prelitigation attorney fees.
- Clark v. Unified Sch. Dist. No. 287 (Court of Appeals of Kansas 2018, 55 Kan. App. 2d 402)✓A man requested a school district letter banning someone from its property, plus related policies. The court held the letter was an open record because it gave notice of regulatory action, and that missing section 45-218(d)'s three-day deadline was a violation but not bad faith.
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Public Records Laws by State: FOIA Guide for All 50 States (2026), Kansas Court Records: How to Search the District Court Public Access Portal
§ 45-254Law enforcement recordings using body camera or vehicle camera; criminal investigation records; disclosure.In forcecited in 9 of our articles
(a) Every audio or video recording made and retained by law enforcement using a body camera or a vehicle camera shall be considered a criminal investigation record as defined in K.S.A. 45-217, and amendments thereto. (b) In addition to any disclosure authorized pursuant to the open records act, K.S.A. 45-215 et seq., and amendments thereto, a person described in subsection (c) may make a request in accordance with procedures adopted under K.S.A. 45-220, and amendments thereto, to listen to an audio recording or to view a video recording made by a body camera or a vehicle camera. The law enforcement agency shall allow the person to listen to the requested audio recording or to view the requested video recording within 20 days after making the request, and may charge a reasonable fee for such services provided by the law enforcement agency.
Official text (excerpt) · last checked 2026-08-31 · Read the full text in our law library · Verify at ksrevisor.gov
Cited in 1 court opinions in our collectionLatest citing opinion in our collection: 2022
Opinions citing this section in our collection:
- McRoberts v. Overland Park, Kansas, City of (District Court, D. Kansas 2022)“…aintiff he would respond further by March 4, 2022.12 Under Kan. Stat. Ann. § 45-254(b), however, the custodian has twenty d…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Kansas Police Body Camera Laws: Access & K.S.A. 45-254, Kansas Recording Laws (2026): One-Party Consent Rules, Kansas Laws on Recording Police
§ 45-219Copies of public records; fees and costs for inspection or copies; remittance of fees and costs by agency.In forcecited in 2 of our articles
(a) Any person may make abstracts or obtain copies of any public record to which such person has access under this act. If copies are requested, the public agency may require a written request and advance payment of the prescribed fee. A public agency shall not be required to provide copies of radio or recording tapes or discs, video tapes or films, pictures, slides, graphics, illustrations or similar audio or visual items or devices, unless such items or devices were shown or played to a public meeting of the governing body thereof, except that the public agency shall not be required to provide such items or devices that are copyrighted by a person other than the public agency. (b) Copies of public records shall be made while the records are in the possession, custody and control of the custodian or a person designated by the custodian and shall be made under the supervision of such custodian or person. Whenever practicable, copies shall be made in the place where the records are kept. If it is not practicable to do so, the custodian shall allow arrangements to be made for use of other facilities.
Official text (excerpt) · last checked 2026-07-29 · Read the full text in our law library · Verify at ksrevisor.gov
Cited in 12 court opinions in our collectionLatest citing opinion in our collection: 2024
Opinions citing this section in our collection:
- Data Tree, LLC v. Meek (Supreme Court of Kansas 2005, 279 Kan. 445)“…No attorneys fees are to be awarded. “6. Pursuant to K.S.A. 45-219, all costs of producing records includi…”
- Roe v. Phillips County Hospital (Supreme Court of Kansas 2023)“…1 4. The plain language of K.S.A. 45-219(a) requires a public agency, upon reque…”
- Attorney General Opinion No. (Kansas Attorney General Reports 2010)“…izes the rights belonging to a copyright owner by virtue of K.S.A. 45-219 (a) which provides that an agency " sha…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Kansas Police Reports: Crash Reports, Records Requests, and Bodycam Footage
§ 45-221Certain records not required to be disclosed; separation of open and closed information required; disclosure of statistical information; records over 70 years old open, exceptions.In forcecited in 9 of our articles
(a) Except to the extent disclosure is otherwise required by law, a public agency shall not be required to disclose: (1) Records the disclosure of which is specifically prohibited or restricted by federal law, state statute or rule of the Kansas supreme court or rule of the senate committee on confirmation oversight relating to information submitted to the committee pursuant to K.S.A. 75-4315d, and amendments thereto, or the disclosure of which is prohibited or restricted pursuant to specific authorization of federal law, state statute or rule of the Kansas supreme court or rule of the senate committee on confirmation oversight relating to information submitted to the committee pursuant to K.S.A. 75-4315d, and amendments thereto, to restrict or prohibit disclosure. (2) Records that are privileged under the rules of evidence, unless the holder of the privilege consents to the disclosure. (3) Medical, psychiatric, psychological or alcoholism or drug dependency treatment records that pertain to identifiable patients.
Official text (excerpt) · last checked 2026-09-02 · Read the full text in our law library · Verify at ksrevisor.gov
Cited in 46 court opinions in our collectionLatest citing opinion in our collection: 2025
In the courts (editorial summary, independently checked):Kansas courts construe the K.S.A. 45-221 exceptions narrowly, and the exceptions permit withholding rather than require it. In Telegram Publishing Co. v. Kansas Department of Transportation (2003) the agency carried the burden and lost an (a)(1) claim. Harris Enterprises, Inc. v. Moore (1987) affirmed a denial under (a)(10).
Opinions citing this section in our collection:
- State, Department of Social & Rehabilitation Services v. Public Employee Relations Board of the Kansas Department of Human Resources (Supreme Court of Kansas 1991, 249 Kan. 163)✓A state hospital gave a certified union its employees' names but withheld home addresses; the Kansas Supreme Court held K.S.A. 45-221 does not prohibit disclosure but leaves it discretionary with the records custodian, so the agency could not refuse the disclosure order.
- Wichita Eagle & Beacon Publishing Co. v. Simmons (Supreme Court of Kansas 2002, 274 Kan. 194)✓A newspaper sought corrections records on parolees charged with murder; the Kansas Supreme Court held the K.S.A. 45-221(a)(20) exemption covers proposed policies, not actions already taken, and that subsection (d) required the agency to furnish redacted records.
- Harris Enterprises, Inc. v. Moore (Supreme Court of Kansas 1987, 241 Kan. 59)✓A newspaper sued for the Duffield murder investigation files; applying K.S.A. 45-221(a)(10), the Kansas Supreme Court put the public-interest burden on the requester and the other four findings on the agency, and affirmed the discretionary denial after in camera review.
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: Are Autopsy Reports Public in Kansas? (2026 Guide), Vital Records Explained: Are birth certificates public records?, License Plate Reader Laws by State: 2026 Comparison
§ 45-222Civil remedies to enforce act; attorney fees.In forcecited in 3 of our articles
(a) The district court of any county in which public records are located shall have jurisdiction to enforce the purposes of this act with respect to such records, by injunction, mandamus, declaratory judgment or other appropriate order, in an action brought by any person, the attorney general or a county or district attorney. The district court may require a defendant to complete training approved by the attorney general concerning the requirements of the open records act. (b) In any action hereunder, the court shall determine the matter de novo. The court on its own motion, or on motion of either party, may view the records in controversy in camera before reaching a decision. (c) In any action hereunder, or under K.S.A. 45-251, and amendments thereto, the burden of proof shall be on the public agency to sustain its action.
Official text (excerpt) · last checked 2026-07-29 · Read the full text in our law library · Verify at ksrevisor.gov
Cited in 19 court opinions in our collectionLatest citing opinion in our collection: 2025
Opinions citing this section in our collection:
- Wichita Eagle & Beacon Publishing Co. v. Simmons (Supreme Court of Kansas 2002, 274 Kan. 194)“…an in-camera inspection of five sample records pursuant to K.S.A. 45-222(b). After reviewing a sample of…”
- Telegram Publishing Co. v. Kansas Department of Transportation (Supreme Court of Kansas 2003, 275 Kan. 779)“…e district court in holding that a “denial of access” under K.S.A. 45-222(c) refers only to the agency’s prelitig…”
- Data Tree, LLC v. Meek (Supreme Court of Kansas 2005, 279 Kan. 445)“…Data Tree contends it was entitled to attorney fees under K.S.A. 45-222(c) because the denial of access by the…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
§ 45-251Civil remedies to enforce act by attorney general; consent order; finding of violation.In force
(a) The attorney general may determine by a preponderance of the evidence after an investigation that a public agency has violated K.S.A. 45-215 et seq., and amendments thereto, and may, at any time prior to the filing of an action pursuant to K.S.A. 45-222, and amendments thereto, either enter into a consent order with the public agency or issue a finding of violation to the public agency. (1) If the attorney general enters into a consent order with the public agency, the consent order: (A) May contain admissions of fact and any or all of the following: (i) Require completion of training approved by the attorney general concerning the requirements of K.S.A. 45-215 et seq., and amendments thereto; (ii) impose a civil penalty as provided for in K.S.A. 45-223, and amendments thereto, in an amount not to exceed $250 for each violation; and (iii) set forth the public agency's agreement that it will comply with the requirements of the open records act, K.S.A. 45-215 et seq., and amendments thereto; and (B) shall bear the signature of the head of the public agency, of any officer found to have violated the provisions of K.S.A.
Official text (excerpt) · last checked 2026-07-29 · Read the full text in our law library · Verify at ksrevisor.gov
§ 45-215Title of act.In forcecited in 6 of our articles
K.S.A. 45-215 through 45-223 shall be known and may be cited as the open records act.
Official text (excerpt) · last checked 2026-07-29 · Read the full text in our law library · Verify at ksrevisor.gov
Cited in 69 court opinions in our collectionLatest citing opinion in our collection: 2024
Opinions citing this section in our collection:
- State v. Myers (Supreme Court of Kansas 1996, 260 Kan. 669)“…e subject to the provisions of the Kansas Open Records Act, K.S.A. 45-215 et seq. Myers asserts,…”
- Wichita Eagle & Beacon Publishing Co. v. Simmons (Supreme Court of Kansas 2002, 274 Kan. 194)“…996 through 1999, under the Kansas Open Records Act (KORA), K.S.A. 45-215 et seq. The district court…”
- Harris Enterprises, Inc. v. Moore (Supreme Court of Kansas 1987, 241 Kan. 59)“…e exempt from disclosure under the Kansas Open Records Act, K.S.A. 45-215 et seq. This case aros…”
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
United States Code Title 5
§ 552Public information; agency rules, opinions, orders, records, and proceedingsIn forcecited in 38 of our articles
Each agency shall make available to the public information as follows: Each agency shall separately state and currently publish in the Federal Register for the guidance of the public— descriptions of its central and field organization and the established places at which, the employees (and in the case of a uniformed service, the members) from whom, and the methods whereby, the public may obtain information, make submittals or requests, or obtain decisions; statements of the general course and method by which its functions are channeled and determined, including the nature and requirements of all formal and informal procedures available; rules of procedure, descriptions of forms available or the places at which forms may be obtained, and instructions as to the scope and contents of all papers, reports, or examinations; substantive rules of general applicability adopted as authorized by law, and statements of general policy or interpretations of general applicability formulated and adopted by the agency; and each amendment, revision, or repeal of the foregoing.
Official text (excerpt) · last checked 2026-09-02 · Read the full text in our law library · Verify at uscode.house.gov
Cited in 11,434 court opinions in our collectionLatest citing opinion in our collection: 2026
In the courts (editorial summary, independently checked):United States Department of Justice v. Reporters Committee for Freedom of the Press (1989) held categorically that releasing a private citizen's FBI rap sheet to a third party is an unwarranted privacy invasion under Exemption 7(C). Consumer Product Safety Commission v. GTE Sylvania, Inc. (1980) applied Exemption 3, 552(b)(3).
Opinions citing this section in our collection:
- Alyeska Pipeline Service Co. v. Wilderness Society (Supreme Court of the United States 1975, 421 U.S. 240)“…Pub. L. 93-502, § 1 (b) (2), 88 Stat. 1561 (amending 5 U. S. C. § 552 (a)); Packers and Stockyards Act, 42…”
- Consumer Product Safety Commission v. GTE Sylvania, Inc. (Supreme Court of the United States 1980, 447 U.S. 102)✓Consumer groups filed FOIA requests for accident reports manufacturers had given the CPSC as confidential; the Court held that the Consumer Product Safety Act's section 6(b)(1) applies to FOIA requests and that its standards fall within Exemption 3, 5 U.S.C. § 552(b)(3).
- Taylor v. Sturgell (Supreme Court of the United States 2008, 553 U.S. 880)✓An aircraft enthusiast made a FOIA request for FAA records after a friend's identical suit failed; the Court disapproved preclusion by 'virtual representation' and read § 552(a)(3)(A) as directing agencies to release records to the requesting person, not the public at large.
Identified automatically from the court opinions citing this section — not a ranking of which case controls.
Also relied on in: How to File a FOIA Request (Step by Step, 2026), Virginia Freedom of Information Act: Who Can Request and How (2026), West Virginia Freedom of Information Act: Requests and Fees (2026)
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Sources and References
- K.S.A. 45-218, inspection of public records, the 3-business-day response deadline, and the separate written statement of grounds for denial(ksrevisor.gov).gov
- K.S.A. 45-219, fees for copies and appeal of fee reasonableness to the Secretary of Administration(ksrevisor.gov).gov
- K.S.A. 45-254, body camera and vehicle camera recordings as criminal investigation records(ksrevisor.gov).gov
- K.S.A. 45-222, civil enforcement of the Kansas Open Records Act(ksrevisor.gov).gov
- K.S.A. 45-221, records not required to be disclosed(ksrevisor.gov).gov
- K.S.A. 45-251, Attorney General investigative and enforcement authority(ksrevisor.gov).gov