State of Kansas v. Manson (Kansas 2019)

No. 119,134 (Kan. Ct. App. 2019)
June 2019

A voluntary acknowledgement of paternity must be revoked before the child turns one otherwise the parent-child relationship is permanent. The state of Kansas filed to establish support against the father for the benefit of a two-year-old child. The father had signed a voluntary acknowledgement at the child’s birth. At the hearing, he produced genetic test results from a home kit that showed he was not the child’s biological father. The district court heard evidence to determine if further testing was in the child's best intersts. After hearing, the district court denied further testing. The father appealed, arguing that the court abused its discretion in finding that additional genetic testing wasn’t in the child’s best interests. The court of appeals upheld the decision. It found that the father didn’t rescind the acknowledgment before the child’s first birthday, as required by statute. Therefore, the acknowledgement become a permanent. Even if the father wasn’t the child’s biological father, he would be obligated for support.