Payment of claims based upon implied contracts, when

46-903. Payment of claims based upon implied contracts, when. No money or funds shall be disbursed from the state treasury or any special fund of the state of Kansas in part or full satisfaction or payment of any claim or judgment based in whole or in part on an implied contract, unless the payment of such claim or judgment has been specifically authorized by act of the legislature. History: L. 1970, ch. 200, § 3; L. 1979, ch. 186, § 23; July 1. Law Review and Bar Journal References: "Survey of Kansas Law: Municipal Corporations," Richard H. Seaton, 27 K.L.R. 269, 270 (1979). "Immunity From Suit on Implied Contract: Isn't It Time Kansas Entered the 20th Century?" Mark A. Shaiken, 20 W.L.J. 557 (1981). CASE ANNOTATIONS 1. Immunity does not extend to public officers acting outside scope of authority; summary judgment denied. Kern v. Miller, 216 Kan. 724, 725, 533 P.2d 1244. 2. Filing of claim under K.S.A. 46-907 condition precedent to maintaining action for claim based on implied contract. Wheat v. Finney, 230 Kan. 217, 220, 221, 222, 630 P.2d 1160 (1981). 3. Unconstitutionality of indigent defense services act (K.S.A. 22-4501 et seq.) before July 1, 1988, does not warrant monetary damages; equitable relief only. Sharp v. State, 245 Kan. 749, 754, 783 P.2d 343 (1989). 4. District court properly dismissed claims against the state based on implied contracts when the plaintiffs did not first file the claims with joint committee on special claims. Minjarez-Almeida v. Kan. Bd. of Regents, 63 Kan. App. 2d 225, 237-238, 528 P.3d 931 (2023). 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