In a decision involving a Salina case, the Kansas Supreme Court reversed a Court of Appeals’ decision and ruled that under Kansas law, courts may assess only a single $400 Children’s Advocacy Center fee per criminal case rather than per conviction count.
The decision reversed a trial court order that had charged the defendant $2,400 across six counts, clarifying that the statutory language caps the fee obligation at one assessment per defendant per case regardless of the number of convictions.
The case centered on Jack Rex Mildfelt Jr., who was convicted by a Saline County jury of six child-sex crimes involving two minor victims. The Saline District Court sentenced Mildfelt to life imprisonment without the possibility of parole for 100 years.
As part of the sentencing, the district court ordered Mildfelt to pay a Children’s Advocacy Center assessment fee. Because he had been convicted of six separate crimes, the court multiplied the standard fee, ordering him to pay $400 for each count for a total of $2,400.
Mildfelt appealed the fee structure, arguing that Kansas law authorized the court to assess only one $400 fee per case, regardless of how many counts or convictions were charged. The Kansas Court of Appeals initially disagreed, affirming the district court’s per-conviction assessment. Mildfelt then petitioned the Kansas Supreme Court for review.
The Supreme Court vacated the $2,400 fee order and remanded the case back to the district court with instructions to enter an amended journal entry reflecting a single $400 fee.
The ruling establishes a clear precedent across Kansas for how trial courts must assess Children’s Advocacy Center fees. Moving forward, defendants convicted of multiple offenses involving minor victims will face only one $400 fee per case, curbing stacked administrative fees during sentencing.
