23-451. History: L. 1970, ch. 132, § 1; Repealed, L. 1994, ch. 301, § 86; July 1, 1995. CASE ANNOTATIONS 1. Noted; action for past due child support payments distinguished from action under this statute. Hicks v. Hefner, 210 Kan. 79, 84, 499 P.2d 1147. 2. Purpose of act to provide expeditious way for enforcing duties without involvement in collateral issues. Thompson v. Kite, 214 Kan. 700, 703, 522 P.2d 327. 3. Judge in responding state without jurisdiction to condition disbursement of payments on visitation rights. Patterson v. Patterson, 2 Kan. App. 2d 447, 581 P.2d 824. 4. Noted in action upholding jurisdiction of trial court to enforce defaulting parent's common law duty of child support. Keller v. Guernsey, 227 Kan. 480, 485, 487, 488, 608 P.2d 896. 5. Determination of duty to support is made by responding state not initiating state; method of proof discussed. Mossburg v. Coffman, 6 Kan. App. 2d 428, 429, 629 P.2d 745 (1981). 6. Mentioned; not applicable to petition for reduction of support payments granted in another state. Dipman v. Dipman, 6 Kan. App. 2d 844, 845, 635 P.2d 1279 (1981). 7. Cited; obligor cannot assert counterclaim in proceeding under K.S.A. 60-3001 et seq. to enforce support order. Landon v. Artz, 6 Kan. App. 2d 617, 618, 631 P.2d 1237 (1981). 8. Cited in action for recovery of support under K.S.A. 39-718a and 39-755; absent parent considered; no denial of due process. State ex rel. Secretary of SRS v. Castro, 235 Kan. 704, 713, 714, 684 P.2d 379 (1984). 9. Cited; relationship between URESA child support order and prior divorce decree child support awarded examined. Wornkey v. Wornkey, 12 Kan. App. 2d 506, 749 P.2d 1045 (1988). 10. Common-law and statutory duty to support, subject matter jurisdiction, comity, full faith and credit examined. Boyce v. Boyce, 13 Kan. App. 2d 585, 776 P.2d 1204 (1989). 11. Facts constituting unenforceable order, judgment, or decree in action brought on behalf of foreign country examined. Federal Republic of Germany v. Nelsen, 247 Kan. 461, 799 P.2d 1038 (1990). 12. Kansas law no longer imposes a duty upon parents to provide support for an adult incompetent child. In re Marriage of Risley, 41 Kan. App. 2d 294, 201 P.3d 770 (2009). Previous | Next LEGISLATIVE COORDINATING COUNCIL General Policies 2026 Archived LCC Documents Archived LCC Meetings REVISOR OF STATUTES Archived Session Documents Archived School Finance Documents USEFUL LINKS Session Laws Kansas Administrative Regulations OTHER LEGISLATIVE SITES Kansas Legislature Administrative Services Division of Post Audit Research Department Contact Us PDF Help www.ksrevisor.gov 2026