State v. Cox

CourtCourt of Appeals of Kansas
DecidedFebruary 27, 2026
Docket127564
StatusUnpublished

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

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 127,564

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

STEPHEN WAYNE COX, Appellant.

MEMORANDUM OPINION

Appeal from Leavenworth District Court; GERALD R. KUCKELMAN, judge. Oral Argument held January 6, 2026. Opinion filed February 27, 2026. Affirmed in part, reversed in part, and remanded with directions.

Catherine A. Zigtema, of Zigtema Law Office LC, of Shawnee, for appellant.

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

Before WARNER, C.J., HURST and BOLTON FLEMING, JJ.

PER CURIAM: Stephen Wayne Cox pled guilty to aggravated battery and was sentenced to 162 months in prison. After a direct appeal, Cox filed a motion to correct illegal sentence, arguing the district court erred by including multiple prior convictions when calculating his criminal history score. The district court denied the motion to correct illegal sentence and Cox appeals.

1 On appeal, we first find that as to an attempted criminal threat conviction included in Cox's criminal history, the district court erred by failing to apply the legal precedent in effect at the time of Cox's sentencing, State v. Boettger, 310 Kan. 800, 450 P.3d 805 (2019). Under Boettger, if Cox's attempted criminal threat conviction was committed recklessly, it cannot be included in his criminal history. Since the documents attached to Cox's brief do not resolve this question, remand is appropriate for the district court to apply the correct legal precedent and make factual findings related to whether Cox's attempted criminal threat conviction was committed recklessly.

But as to Cox's remaining issues on appeal, we find the district court did not err by including the four misdemeanor convictions Cox challenges on appeal in the calculation of his criminal history score. Accordingly, we affirm in part, reverse in part, and remand for further proceedings.

FACTUAL AND PROCEDURAL BACKGROUND

Conviction and Sentencing

On March 11, 2019, Cox pled guilty to aggravated battery—a severity level 4 person felony. At the time of his plea, the district court ordered a presentence investigation report (PSI) to help determine Cox's criminal history score for sentencing. The PSI was completed and filed with the court. The PSI contained a criminal history worksheet with Cox's prior convictions.

Prior to his sentencing hearing, Cox filed a motion to withdraw his pleas in four misdemeanor cases included in his criminal history: the convictions contained in criminal history worksheet entries 38, 39, 43, and 44. Cox argued that the record in each of these cases reflected the plea was taken without a plea colloquy that included the waiver of his

2 jury trial rights. Cox's claims were considered and denied by a misdemeanor court assigned to the cases.

At his sentencing hearing in the present case, Cox objected to the scoring of entries 38, 39, 43, and 44 as part of his criminal history. The district court denied Cox's motion to exclude the four misdemeanors and found his criminal history score was A. Cox was sentenced to 162 months in prison.

Direct Appeal

Cox filed a direct appeal challenging his criminal history score along with several other unrelated issues. See State v. Cox, No. 123,587, 2021 WL 5500044 (Kan. App. 2021) (unpublished opinion). On direct appeal, Cox argued that his prior misdemeanor convictions in Leavenworth County Case No. 2014-CR-499 and 2014-CR-596 should not have been included in his criminal history. We see no case number entitled 2014-CR-596 included in Cox's criminal history worksheet; we conclude that his attorney was most likely referencing his convictions in 2014-CR-593. The State did not identify the convictions by case number in its appellate brief. The panel also did not identify the convictions by case number; rather, it identified them as convictions from 2014:

"Cox also challenged his criminal history score. He argued that his two misdemeanor convictions from 2014 should not be used to calculate his criminal history because the court in those cases neglected to advise him of his right to trial, the State's burden of proof at trial, his right not to testify, his right to confront witnesses, his right to use subpoena power, and the maximum penalty for the charges he faced." Cox, 2021 WL 5500044, at *1.

A panel of our court found Cox's claim had no merit, holding:

"The State contends that the holdings in Custis v. United States, 511 U.S. 485, 114 S. Ct. 1732, 128 L. Ed. 2d 517 (1994), and State v. Delacruz, 258 Kan. 129, 899 P.2d

3 1042 (1995), direct the resolution of this issue. We agree. In Custis, the defendant argued that the district court should not have used two of his prior convictions to enhance his sentence because his counsel in those cases rendered deficient representation. Custis relied on Burgett v. Texas, 389 U.S. 109, 88 S. Ct. 258, 19 L. Ed. 2d 319 (1967), for relief because the Burgett Court held that prior uncounseled convictions could not be used to enhance a defendant's criminal history score. 389 U.S. at 114. But the Custis Court declined to extend the Burgett rule and held that courts may use prior convictions to enhance criminal penalties, even if the prior convictions were legally flawed, so long as the defendant was represented by counsel. 511 U.S. at 496. In Delacruz, 258 Kan. at 137, the Kansas Supreme Court adopted the Custis rule when Delacruz similarly argued that certain of his prior convictions should be excluded from his criminal history because his pleas were made involuntarily. The court wrote that Delacruz' proposed rule would 'require sentencing courts . . . to rummage through frequently nonexistent or difficult to obtain state court transcripts or records that may date from another era.' 258 Kan. at 138- 39. The court also found that adopting Delacruz' argument would blunt the finality of a court's judgments. 258 Kan. at 139." Cox, 2021 WL 5500044, at *3.

The panel went on to find that "[t]he issue raised by Cox, challenging the efficacy of the court's guidance at his earlier plea hearings, essentially invites us to examine the transcripts from those past hearings. But this is the very thing Delacruz warned against. Application of Custis and Delacruz is appropriate here." 2021 WL 5500044, at *4. The panel affirmed the district court's inclusion of the convictions in Cox's criminal history.

Motion to Correct Illegal Sentence

Cox next filed a motion to correct an illegal sentence that is the subject of this appeal. He again challenged entries 39, 43, and 44. In his motion, he added a challenge to entry 23, an attempted criminal threat conviction, and entry 48, a misdemeanor child endangerment conviction from Leavenworth Municipal Court.

As to the attempted criminal threat conviction, Cox argued that "defendant's criminal history score was erroneously calculated because it included an unconstitutional 4 conviction for Attempted Criminal Threat under the recklessness provision. State v. Boettger, 310 Kan. 800 (2019)."

As to the misdemeanor convictions in entries 39, 43, and 44, Cox claimed that "multiple misdemeanor convictions were obtained in violation of the defendant's Sixth Amendment rights. Convictions obtained in violation of a defendant's Sixth Amendment rights cannot be included in a criminal history score. State v. Youngblood, 288 Kan.

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Related

Burgett v. Texas
389 U.S. 109 (Supreme Court, 1967)
Custis v. United States
511 U.S. 485 (Supreme Court, 1994)
Spencer v. State
954 P.2d 1088 (Supreme Court of Kansas, 1998)
State v. Delacruz
899 P.2d 1042 (Supreme Court of Kansas, 1995)
State v. Shannon
905 P.2d 649 (Supreme Court of Kansas, 1995)
Spencer v. State
942 P.2d 646 (Court of Appeals of Kansas, 1997)
State v. Nelson
243 P.3d 343 (Supreme Court of Kansas, 2010)
State v. Neal
258 P.3d 365 (Supreme Court of Kansas, 2011)
McPherson v. State
163 P.3d 1257 (Court of Appeals of Kansas, 2007)
State v. Thomas
199 P.3d 1265 (Supreme Court of Kansas, 2009)
State v. Youngblood
206 P.3d 518 (Supreme Court of Kansas, 2009)
State v. Murdock
439 P.3d 307 (Supreme Court of Kansas, 2019)
State v. Boettger
450 P.3d 805 (Supreme Court of Kansas, 2019)
State v. Baker
475 P.3d 24 (Court of Appeals of Kansas, 2020)
State v. Gallegos
485 P.3d 622 (Supreme Court of Kansas, 2021)
State v. Mora
509 P.3d 1201 (Supreme Court of Kansas, 2022)
State v. Keys
510 P.3d 706 (Supreme Court of Kansas, 2022)
State v. Trotter
295 P.3d 1039 (Supreme Court of Kansas, 2013)
Counterman v. Colorado
600 U.S. 66 (Supreme Court, 2023)
State v. Daniels
554 P.3d 629 (Supreme Court of Kansas, 2024)

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Bluebook (online)
State v. Cox, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cox-kanctapp-2026.