State v. Coleman
Annotate this Case
In this consolidated appeal challenging sentences imposed for crimes occurring both before and after statutory amendments in 2015 to the revised Kansas Sentencing Guidelines Act (KSGA), Kan. Stat. Ann. 21-6801, the Supreme Court affirmed the district court's decision scoring a prior 1992 Kansas involuntary manslaughter conviction as a person felony for criminal history purposes.
Defendant's direct appeal concerned two 2015 thefts committed after changes to the revised KSGA. Defendant's probation revocation appeals concerned sentences imposed thefts that occurred before 2015. The Supreme Court held that, as to the direct appeal, this Court adopts the identical-or-narrower test from State v. Wetrich, 412 P.3d 984 (2018), which should also be used for Kansas crimes committed before the sentencing guidelines used the person or nonperson designations. Using the Wetrich test, the Court held that the district court correctly classified a 1992 Kansas involuntary manslaughter conviction as a person felony in the sentencings for the 2015 thefts. As to the probation revocation appeals, the Supreme Court could held that no relief was available.
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.