Kaelter v. Sokol (Kansas 2019)

No. 119,333 (Kan. Ct. App. 2019)
March 2019

An order requiring a response to post-judgment discovery requests is not a final decision for purposes of appeal. The collateral order doctrine also doesn’t apply. The mother sent the father post-judgment discovery to determine his income and assets to aid in collecting child support arrears. The father didn’t answer the discovery, and the mother requested an order from the court. After hearing, the trial court ordered the father comply with the discovery requests. The father appealed. The court of appeals found that the order requiring compliance was not a final order and dismissed the appeal. It didn’t end the collection process. The father argued that the collateral order doctrine should apply. The court disagreed. It found that the order could be a ground on appeal once a final order is entered.