CHIEF JUDGE MERYL WILSON
21ST JUDICIAL DISTRICT, KANSAS

There has never been an adjudication of paternity in this case. I have never signed a Voluntary Acknowledgment of Paternity (VAP) as defined under Kansas law. I have never submitted to genetic testing. The Rush County Clerk of Court has confirmed in writing that no adjudication of paternity exists in the court file. No court in Rush County or elsewhere has entered a valid paternity order. Under K.S.A. 23-2208, paternity may only be established through a properly executed and filed Voluntary Acknowledgment of Paternity pursuant to K.S.A. 23-2204 or through a judicial adjudication following lawful proceedings. Kansas courts have repeatedly held that parental obligations cannot attach without lawful establishment of paternity, including In re Marriage of Welliver, 257 Kan. 259 (1994), and State ex rel. SRS v. Castro, 253 Kan. 754 (1993). A judgment entered without subject-matter jurisdiction is void ab initio, is a legal nullity, and may be attacked at any time. Despite the absence of any adjudication of paternity, Rush County has continued to enforce custody directives, parenting-time orders, child-support obligations, sanctions, and coercive enforcement actions without jurisdiction.

Throughout these proceedings, every substantive motion I filed was denied without a hearing, including motions supported by sworn evidence, medical records, police reports, and constitutional arguments. Each filing required payment of a $62 filing fee, which the court retained, while denying oral argument, evidentiary hearings, written findings, and meaningful review. Orders were routinely issued summarily and without explanation, denying me due process and the right to be heard. This pattern constitutes a systemic deprivation of procedural due process in violation of the Fourteenth Amendment and Kansas precedent requiring a meaningful opportunity to be heard on jurisdictional and constitutional issues.

On at least two occasions, the presiding judge referenced information that was not presented in open court, not part of the docket, not disclosed to the parties, and not subject to adversarial testing. I filed a Motion Addressing Ex Parte Communication under Rule 2.9 of the Kansas Code of Judicial Conduct, which prohibits judges from receiving or relying on information outside the presence of the parties. That motion has never been heard. I also filed a Motion to Recuse under Rule 2.11, citing the refusal to address jurisdictional defects, enforcement of void orders, and the appearance of bias. Instead of setting a hearing or issuing a properly filed judicial order, the motion was denied by email, outside the docket and without procedural safeguards.

I filed three separate motions requesting disclosure of my children’s residential address. Despite Kansas law requiring parents to keep the court and the other parent informed of the children’s residence, the court denied disclosure, denied hearings, and issued no findings. This occurred after I disclosed in open court that the mother was residing with a known felon convicted of manufacturing methamphetamine. The court’s refusal prevented me from knowing where my children lived, ensuring their safety, and exercising my parental rights.

On September 2, 2025, during a court proceeding, I disclosed that I had knowledge of ongoing abuse by the mother dating back to 2020. Despite this disclosure, the judge ordered me to return the children to Kansas, requiring a three-day round-trip drive, without any investigation or protective action. Less than one week after returning the children, my son disclosed to me via text messages that his mother was hitting him and his sister, drinking and driving with him in the car, and that he was scared. I possess these text messages.

My son later disclosed to me in a recorded phone conversation that he told his school teacher about the abuse, including fear and physical harm. Under K.S.A. 38-2223, teachers are mandatory reporters and are legally required to report suspected abuse or neglect immediately. The teacher later denied that any disclosure occurred. However, I possess a recorded phone call and transcript in which my son clearly states that he told his teacher about the abuse and that he was scared. No report was made.

I purchased iPhones for my children under a family-sharing plan and allowed them to take the phones to Kansas so I could maintain communication with them. The mother smashed both phones and terminated contact. I have not had contact with my children since mid-October 2025.

I have documented forty-one instances in which the mother denied my parenting time and parental rights. The court took no corrective action, denied motions, and permitted continued parental alienation.

I also documented instances in which the Rush County Clerk refused to file exhibits, claiming technical deficiencies not supported by law. Under Kansas law, clerks perform ministerial functions only and lack authority to reject filings based on discretion. This obstruction altered the official record, denied access to justice, and compounded due-process violations.

Kansas child-support enforcement operates under Title IV-D of the Social Security Act, which provides federal funding tied to child-support collections. In this case, I am the parent with stable income and the greatest demonstrated ability to pay support, while the mother has multiple child-endangerment charges and limited earning capacity. Despite documented safety concerns, abuse allegations, and the absence of adjudicated paternity, residential custody was awarded to the mother and enforcement actions continued. These facts raise serious structural and constitutional concerns regarding enforcement priorities and due process.

One presiding judge ultimately recused after repeated motions. Subsequent judges continued enforcing void orders, denying hearings, and refusing to address jurisdiction. The harm to my children is ongoing.

All of these events are preserved as part of my federal civil-rights actions under 42 U.S.C. § 1983 and § 1985. The record reflects enforcement of void orders, denial of hearings, ex parte concerns, clerk interference, and failure to protect children.

The continued enforcement of orders without adjudicated paternity, combined with the denial of hearings and refusal to investigate abuse, constitutes a deprivation of constitutional rights under color of state law.