State v. Aguilera

CourtCourt of Appeals of Kansas
DecidedApril 24, 2026
Docket127982
StatusUnpublished

This text of State v. Aguilera (State v. Aguilera) 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
State v. Aguilera, (kanctapp 2026).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 127,982

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

JUAN MARTIN AGUILERA, Appellant.

MEMORANDUM OPINION

Appeal from Sedgwick District Court; BRUCE BROWN, judge. Submitted without oral argument. Opinion filed April 24, 2026. Conviction affirmed, sentence vacated, and case remanded with directions.

Grace E. Tran, of Kansas Appellate Defender Office, for appellant.

Julie A. Koon, assistant district attorney, Marc Bennett, district attorney, and Kris W. Kobach, attorney general, for appellee.

Before GARDNER, P.J., ARNOLD-BURGER and SCHROEDER, JJ.

PER CURIAM: Juan Martin Aguilera appeals his conviction for aggravated indecent liberties with a child, an off-grid felony. He argues that the prosecutor erred by vouching for the victim's credibility during closing arguments and that the district court erred in sentencing him after departing to a grid-based sentence. After careful review, we affirm his conviction but vacate his sentence and remand the case for resentencing.

1 FACTUAL AND PROCEDURAL BACKGROUND

On August 12, 2023, J.T., who was 13 years old at the time, was home alone when her brother-in-law, Aguilera, came over. Aguilera lived next door with J.T.'s older sister (his wife). He had come to the house to use a medical cream to treat an injury on his leg. J.T. let Aguilera in the house and he went to her parents' bedroom to apply the cream while J.T. stayed in the living room. From this point, J.T.'s and Aguilera's accounts differ.

According to J.T.'s trial testimony, Aguilera had been in the bedroom for a while, so she went to check on him. She found him still looking for the cream. Aguilera started to leave the bedroom but then grabbed J.T. by the waist, picked her up, and threw her on the bed. Aguilera then tried to kiss her, but she turned her face away. Still, Aguilera bit her breast and nipple over her clothes and then lifted her shirt and bit her stomach, leaving marks. Aguilera told her during this encounter that she had big breasts for her age. J.T. was wearing a jacket, shirt, bra, and shorts.

J.T. then tried to push Aguilera off, but he told her she was too weak. J.T. told him to get off her, and he replied that he was not going to do anything to her because she was still a minor. Aguilera then got off J.T. As he was doing so, she punched him in the arm, and he threw her back on the bed before leaving the house.

Aguilera's account of the incident to law enforcement differed. During his interview with law enforcement, which was played for the jury, he told officers that he went into the bedroom to get the medical cream. While he was doing so, J.T. entered the bedroom and tried to stick some athletic tape that he was using on his face, apparently to be playful. She had recently been playful with him by pretending like she was going to punch him. So when she tried to stick the tape on his face, he tried to push her away toward the bed, but she grabbed a hold of him so they both rolled onto the bed.

2 Aguilera told officers that he then got off the bed, but J.T. again acted like she would throw a punch at him, so he grabbed her by the stomach and threw her toward the bed again before leaving the house. He denied touching her breast or trying to kiss her.

The State charged Aguilera with one count of aggravated indecent liberties with a child, an off-grid person felony, under K.S.A. 21-5506(b)(3)(A) and (c)(3). The jury found Aguilera guilty of aggravated indecent liberties with a child.

Before sentencing, Aguilera moved for a departure to a grid-based sentence. At sentencing, Aguilera's presentence investigation report listed his criminal history score as I, and neither party objected to that finding. The district court granted his motion, departing from the presumptive off-grid hard 25 sentence to a grid-based sentence. The district court sentenced Aguilera to 165 months' imprisonment. The district court judge explained that he departed to a grid-based sentence because the degree and nature of the touching was less than "typical" for a conviction for aggravated indecent liberties with a child. The district court also sentenced Aguilera to lifetime parole with electronic monitoring.

Aguilera timely appeals.

ANALYSIS

Aguilera raises three arguments. First, he argues that the prosecutor erred during closing argument by improperly vouching for J.T.'s credibility. Second, he argues his sentence is illegal because the district court sentenced him in the 1-I grid box instead of the 3-I grid box. Third, Aguilera argues the district court erred by ordering him to serve lifetime parole with electronic monitoring instead of postrelease supervision. We address each issue in turn.

3 I. DID THE STATE COMMIT PROSECUTORIAL ERROR IN ITS CLOSING ARGUMENT?

Aguilera first argues that the prosecutor erred during closing argument by improperly commenting on J.T.'s credibility, which deprived him of a fair trial. He asks us to reverse his conviction and remand for a new trial. The State responds that when the challenged comments are viewed in context, they are not improper.

Preservation

Aguilera did not object to these comments during the State's closing argument. Even so, we will review a prosecutorial error claim based on a prosecutor's comments made during closing argument even without a timely objection, but we may figure the presence or absence of an objection into our analysis of the alleged error. State v. Bodine, 313 Kan. 378, 406, 486 P.3d 551 (2021).

Standard of Review

In considering a claim of prosecutorial error during closing argument we apply a two-step standard of review.

"First, considering a prosecutor's statements in context, appellate courts ask whether the prosecutor stepped outside the wide latitude afforded prosecutors 'to conduct the State's case in a manner that does not offend the defendant's constitutional right to a fair trial.' State v. Brown, 316 Kan. 154, 164, 513 P.3d 1207 (2022); State v. Blevins, 313 Kan. 413, 428, 485 P.3d 1175 (2021). This wide latitude extends to allow prosecutors to highlight evidence and discuss inferences reasonably drawn from that evidence. State v. Timley, 311 Kan. 944, 949-50, 469 P.3d 54 (2020). But a prosecutor may not misstate the law applicable to the evidence, comment on witness credibility, or shift the burden of proof to the defendant. State v. Hilt, 307 Kan. 112, 124, 406 P.3d 905 (2017); see State v. Sherman, 305 Kan. 88, Syl. ¶ 5, 108-09, 378 P.3d 1060 (2016).

4 "If an error is found, appellate courts move to the second step of review to determine whether to reverse the defendant's convictions because of the prosecutor's error. In that review, appellate courts apply the traditional constitutional harmlessness test stated in Chapman v. California, 386 U.S. 18, 24, 87 S. Ct. 824, 17 L. Ed. 2d 705 (1967). See Sherman, 305 Kan. at 109. Under that test, 'prosecutorial error is harmless if the State can demonstrate "beyond a reasonable doubt that the error complained of will not or did not affect the outcome of the trial in light of the entire record, i.e., where there is no reasonable possibility that the error contributed to the verdict."' 305 Kan.

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State v. Aguilera, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-aguilera-kanctapp-2026.