State v. Coman
Annotate this CaseJoshua Coman pled guilty to misdemeanor criminal sodomy, as defined in Kan. Stat. Ann. 21-3505(a)(1), based upon an incident with a dog. The Kansas Offender Registration Act (KORA) requires registration for those who commit felony criminal sodomy but omits the misdemeanor criminal sodomy for which Coman was convicted. Nevertheless, in addition to specifically named crimes, the list includes a catch-all provision under Kan. Stat. Ann. 22-4902(c)(14), which requires registration for those committing sexually motivated acts. The district court found that Coman was required to register under KORA because the act giving rise to his conviction for the unlisted version of criminal sodomy was sexually motivated. A divided court of appeals panel affirmed. The Supreme Court reversed the order requiring Coman to register after construing the statute as a whole, holding that the legislature did not intend to include the acts constituting the sex crime defined in section 21-3505(a)(1) to be included within the catch-all provisions of section 22-4902(c)(14).
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.