State v. Buell

CourtCourt of Appeals of Kansas
DecidedMay 22, 2026
Docket127863
StatusUnpublished

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

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 127,863

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

AUSTIN BUELL, Appellant.

MEMORANDUM OPINION

Appeal from Wallace District Court; SCOTT SHOWALTER, judge. Submitted without oral argument. Opinion filed May 22, 2026. Affirmed.

Charles A. O'Hara, of O'Hara & O'Hara LLC, of Wichita, for appellant.

Natalie Chalmers, principal assistant solicitor general, and Kris W. Kobach, attorney general, for appellee.

Before HILL, P.J., PICKERING and BOLTON FLEMING, JJ.

PER CURIAM: A jury convicted Austin Buell of five counts of aggravated violation of the Kansas Offender Registration Act (KORA) and one count of violation of KORA.

On appeal, Buell raises three issues. First, Buell alleges the district court erred by denying his request for a jury instruction that included a culpable mental state for each crime. But Buell's requested instruction would not have been legally appropriate because

1 no culpable mental state is required for a violation or aggravated violation of KORA. Such violations are considered strict liability crimes.

Second, Buell argues that the district court made two errors related to how it responded to a jury question. It is true the district court violated K.S.A. 22-3420(d) by holding a discussion with the State's attorney on how to respond to a jury question outside Buell's presence, though the district court had consulted with Buell's attorney and received his approval. And the district court also violated K.S.A. 22-3420(d) when it instructed a court clerk to deliver an oral response to the jury question rather than the court delivering the response in writing or in open court. But we find these errors were harmless because the State has met its burden of proof to show that there was no reasonable possibility that the errors contributed to the verdict.

Finally, Buell alleges the court erred when it refused to instruct the court reporter to perform a readback of trial testimony requested by the jury. K.S.A. 22-3420(d) gives the trial court discretion in answering a jury's request for a readback of testimony. The district court did not abuse its discretion because it gave a meaningful response by explaining to the jury that such a request would be very difficult to fulfill, and that the jurors would need to use their recollection. Moreover, Buell waived this argument by failing to preserve it through an objection at trial. Accordingly, we affirm.

FACTUAL AND PROCEDURAL BACKGROUND

Austin Buell was required to register under KORA due to a 2015 conviction for indecent solicitation of a child. As part of his registration requirements, Buell was required to complete a registration form that asked for "'[a]ll email addresses; online identities; personal web pages; screen names; site affiliations; and designations.'"

2 To complete the registration, Buell was also required to review and sign an acknowledgment that stated, "'If I use the Internet, I am required to report to the registering law enforcement agency any and all: email addresses; online identifiers [sic]; information relating to membership in any and all personal web pages or online social networks; and internet screen names. See K.S.A. 22-4907(a)(19).'"

As time went on, law enforcement became concerned that Buell's online activity was not in compliance with his KORA registration requirements. Wallace County Sheriff's Deputy Ronnie Cloyd began investigating Buell's potential violations. Cloyd learned that Buell had TikTok and Snapchat accounts and verified Buell's usernames by viewing posts that included photos and videos of Buell, pictures of Buell's vehicles, and other identifiers. Cloyd concluded that Buell had failed to identify the TikTok and Snapchat accounts on any of his KORA registrations.

Buell's electronic devices were seized as the result of a search warrant. Forensic analysis revealed activity by Buell on Snapchat and TikTok at various times between December 6, 2019, and July 4, 2022. On December 18, 2023, Buell was convicted of five counts of aggravated violation of KORA and one count of violation of KORA. At sentencing, the district court ordered the sentence for each count to run concurrently for a controlling prison sentence of 72 months.

Buell timely appeals.

3 ANALYSIS

DID THE DISTRICT COURT ERR BY DENYING BUELL'S REQUEST FOR A JURY INSTRUCTION THAT INCLUDED A CULPABLE MENTAL STATE?

Buell's first argument on appeal is that the district court erred when it denied his request for a jury instruction that was based on PIK Crim. 4th 52.010 (2021 Supp.).

Standard of Review

"When analyzing jury instructions, appellate courts follow a three-step process: (1) determine whether the appellate court can or should review the issue, in other words, whether there is a lack of appellate jurisdiction or a failure to preserve the issue for appeal; (2) consider the merits of the claim to determine whether error occurred below; and (3) assess whether the error requires reversal—in other words, whether the error can be deemed harmless." State v. Hollins, 320 Kan. 240, 242, 564 P.3d 778 (2025).

Appellate courts consider whether the instruction was legally and factually appropriate using an unlimited standard of review of the entire record. Hollins, 320 Kan. at 242.

"Whether a party has preserved a jury instruction issue affects the appellate court's reversibility inquiry at the third step." State v. Peters, 319 Kan. 492, 515, 555 P.3d 1134 (2024). If a party fails to object to a jury instruction before the district court, an appellate court reviews the instruction to determine if it was clearly erroneous. K.S.A. 22-3414(3). If the challenging party preserved the issue below, an appellate court applies one of two harmless error tests. If the instructional error impacts a constitutional right, an appellate court assesses whether the error was harmless under the federal constitutional harmless error standard. State v. Holley, 313 Kan. 249, 254, 256-57, 485 P.3d 614 (2021). A court will declare a constitutional error harmless only when the party benefiting from the error persuades the court "beyond a reasonable doubt that the error complained of will not or

4 did not affect the outcome of the trial in light of the entire record, i.e., proves there is no reasonable possibility that the error affected the verdict." State v. Ward, 292 Kan. 541, 569, 256 P.3d 801 (2011) (citing Chapman v. California, 386 U.S. 18, 87 S. Ct. 824, 17 L. Ed. 2d 705, reh. denied 386 U.S. 987 [1967]), cert. denied 565 U.S. 1221 (2012). When no constitutional right is impacted, the court must determine if there is a reasonable probability that the error will or did affect the trial's outcome in light of the entire record. State v. Campbell, 317 Kan. 511, 518, 532 P.3d 425 (2023).

The district court did not err in denying Buell's requested jury instruction.

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