Piatt v. State

CourtCourt of Appeals of Kansas
DecidedApril 28, 2017
Docket116342
StatusUnpublished

This text of Piatt v. State (Piatt v. State) is published on Counsel Stack Legal Research, covering Court of Appeals of Kansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Piatt v. State, (kanctapp 2017).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 116,342

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

NICHOLAS B. PIATT, Appellant,

v.

STATE OF KANSAS, Appellee.

MEMORANDUM OPINION

Appeal from Harper District Court; LARRY T. SOLOMON, judge. Opinion filed April 28, 2017. Affirmed.

Jess W. Hoeme, of Joseph, Hollander & Craft LLC, of Wichita, for appellant.

Janis I. Knox, county attorney, and Derek Schmidt, attorney general, for appellee.

Before ARNOLD-BURGER, C.J., GREEN and MCANANY, JJ.

Per Curiam: "[A]ny person in this state who is detained, confined or restrained of liberty on any pretense whatsoever" may file a petition for writ of habeas corpus. K.S.A. 2016 Supp. 60-1501. The petition must allege "shocking and intolerable conduct or continuing mistreatment of a constitutional stature." Johnson v. State, 289 Kan. 642, 648, 215 P.3d 575 (2009). In 2008, Nicholas B. Piatt pled guilty to theft. Now, he is a police officer and alleges that he cannot advance in his career due to the fact that he was convicted of a crime of dishonesty. Piatt filed a K.S.A. 2016 Supp. 60-1501 petition in which he asked the district court to allow him to withdraw his guilty plea. His basis for withdrawing the plea is that his attorney was ineffective for failing to warn Piatt of the

1 collateral consequences of his plea. The district court held that it was without jurisdiction to consider Piatt's claim because Piatt was not detained, confined, or restrained of liberty as envisioned by K.S.A. 2016 Supp. 60-1501. Because the district court's analysis was correct, we affirm its decision dismissing Piatt's claim.

FACTUAL AND PROCEDURAL HISTORY

In 2006, Piatt and Dustin Stansbury drove onto the Anthony Golf Club course, causing property damage, and stole two animal traps. Piatt and Stansbury were both charged with criminal damage to property, obstruction of official duty, criminal trespass, and theft. The criminal trespass and theft counts were charged as misdemeanors for both men. The criminal damage to property and obstruction of official duty counts were charged as misdemeanors against Stansbury and as felonies against Piatt. Piatt pled guilty to all four counts, and in exchange the State agreed to amend the two felony counts to misdemeanors. The district court placed Piatt on probation for 2 years, ordered Piatt to pay certain costs and restitution, and ordered Piatt to serve 10 days in jail. Piatt's probation was terminated approximately 10 months later, as Piatt had satisfied the terms of the probation. Now, Piatt is a police officer with the Colwich Police Department. Piatt believes his theft conviction has obstructed his professional advancement.

Prosecutors have a duty to disclose impeachment evidence to the defense under Giglio v. United States, 405 U.S. 150, 92 S. Ct. 763, 31 L. Ed. 2d 104 (1972), and Brady v. Maryland, 373 U.S. 83, 83 S. Ct. 1194, 10 L. Ed. 2d 215 (1963). Impeachment evidence includes evidence that a witness has been convicted of a crime of dishonesty, such as theft. Piatt alleges that he was denied a position at the Sedgwick County Sheriff's Department because it has a "de facto policy" of not hiring anyone on what it terms the Brady/Giglio list. This list was apparently established in 2014 by the Sedgwick County District Attorney's Office to comply with its discovery requirements under state and federal law. Although the policy indicates that the office takes no position on job

2 assignments or discipline of law enforcement officers who have impeachment information in their past (i.e., crimes involving dishonesty), the office will not commence prosecution or request a warrant or summons based on an affidavit completed by anyone with such an impeachment history. Piatt does not address whether this is a common practice around the state or country or whether it is unique to Sedgwick County. Piatt also alleges that the Colwich Police Chief recently advised him that his conviction would result in termination from the Colwich Police Department.

Piatt filed a K.S.A. 2016 Supp. 60-1501 petition for writ of habeas corpus in which he requested that the district court permit him to withdraw his plea for the theft conviction. Piatt claims that his "plea was given without a clear understanding of the consequences of the plea or an explanation of the continuing effect that such a conviction for theft has caused." Piatt argued that allowing him to withdraw his plea was "the only potential means at law by which Piatt can be relieved of the shocking and intolerable continued restrained of his liberty imposed upon him by a plea and conviction to a crime of dishonesty when he was never so advised."

The district court summarily dismissed Piatt's K.S.A. 2016 Supp. 60-1501 petition. The court held that Piatt's request to withdraw his plea was untimely. The court also held that it was a condition precedent to both a K.S.A. 2016 Supp. 60-1501 petition and K.S.A. 2016 Supp. 60-1507 motion that the defendant be in custody and Piatt did not provide "concrete authority for his position that the facts of his case amount to legal detention, confinement, or restraint of liberty."

Piatt appealed.

3 ANALYSIS

Piatt argues that the district court erred by summarily dismissing his petition on the basis that Piatt was not in custody.

An appellate court exercises unlimited review of a summary dismissal of a K.S.A. 2016 Supp. 60-1501 petition. Johnson, 289 Kan. at 649. A K.S.A. 2016 Supp. 60-1501 petition must allege "shocking and intolerable conduct or continuing mistreatment of a constitutional stature." 289 Kan. at 648. Summary dismissal is proper "if, on the face of the petition, it can be established that petitioner is not entitled to relief, or if, from undisputed facts, or from uncontrovertible facts, such as those recited in a court record, it appears, as a matter of law, no cause for granting a writ exists." 289 Kan. at 648-49.

K.S.A. 2016 Supp. 60-1501(a) provides in part that any person who is physically present in this state and "detained, confined or restrained of liberty on any pretense whatsoever . . . may prosecute a writ of habeas corpus in the supreme court, court of appeals or the district court of the county in which such restraint is taking place." Piatt's argument is that he is restrained of liberty because he cannot advance in his career as a law enforcement officer due to his theft conviction. This argument is not supported by the caselaw or Kansas' habeas corpus statutes.

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Related

Brady v. Maryland
373 U.S. 83 (Supreme Court, 1963)
Giglio v. United States
405 U.S. 150 (Supreme Court, 1972)
In Re Jones
612 P.2d 1211 (Supreme Court of Kansas, 1980)
State v. McCoin
101 P.3d 1204 (Supreme Court of Kansas, 2004)
In Re Application of Horst
14 P.3d 1162 (Supreme Court of Kansas, 2000)
Williams v. DesLauriers
172 P.3d 42 (Court of Appeals of Kansas, 2007)
Johnson v. State
215 P.3d 575 (Supreme Court of Kansas, 2009)

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Piatt v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/piatt-v-state-kanctapp-2017.