State v. Williams
Annotate this CaseDefendant entered an Alford plea pleading guilty to one count of first-degree felony murder and two counts of arson. The district court calculated Defendant’s criminal history score by classifying a prior Ohio conviction as a person crime instead of a nonperson crime, which elevated Defendant’s overall score and led to a sentence that was increased in severity. The Supreme Court affirmed, holding that the district court (1) correctly determined that Defendant’s prior out-of-state conviction was comparable to aggravated burglary, a person offense, under Kan. Stat. Ann. 21-3716; and (2) therefore properly classified Defendant’s Ohio conviction as a person crime.
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