State v. Dewey

CourtCourt of Appeals of Kansas
DecidedMay 8, 2026
Docket127243
StatusUnpublished

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

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 127,243

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

ROMAN LEE DEWEY, Appellant.

MEMORANDUM OPINION

Appeal Labette District Court; FRED W. JOHNSON JR., judge. Submitted without oral argument. Opinion filed May 8, 2026. Reversed in part, sentence vacated, and case remanded with directions.

Kai Tate Mann, of Kansas Appellate Defender Office, for appellant.

Mandy Johnson, county attorney, and Kris W. Kobach, attorney general, for appellee.

Before ISHERWOOD, P.J., CLINE, J., and COURTNEY D. CRAVER, District Judge, assigned.

ISHERWOOD, J.: Roman Lee Dewey appeals his sentence because of his criminal history score. He argues that the district court erred by giving him a criminal history score of B based on a conviction for reckless criminal threat, an unconstitutional conviction. He also contests the requirement to register under the Kansas Offender Registration Act (KORA).

1 FACTUAL AND PROCEDURAL BACKGROUND

Dewey pleaded no contest to abuse of a child, in violation of K.S.A. 2017 Supp. 21-5602(a)(2). Under the plea agreement, Dewey acknowledged that he may be required to register as a violent offender for at least 15 years. At the plea hearing, the district court asked if Dewey would be expected to register before directing the State to prepare a registration notice. Defense counsel specified that Dewey would likely be required to register as a violent offender by agreement of the parties. The district court found Dewey guilty upon a plea of no contest but failed to make any finding that he was an offender under KORA.

A presentence investigation (PSI) report showed Dewey's criminal history score was B, including a 2009 conviction for the person felony of criminal threat. Dewey objected, arguing that our Supreme Court declared reckless criminal threat unconstitutional and such convictions cannot be included in a criminal history score.

An amended PSI report excluded the criminal threat from its calculus, leading to a criminal history score of D.

At the next hearing, Dewey asked the district court to pronounce sentence that day, asserting that he had completed the sentence he would serve if sentenced to a level 5 person felony with a criminal history score of D. The State objected to the amended PSI report, requesting time to file a written objection.

The State's written objection acknowledged that our Supreme Court found that reckless criminal threat convictions were constitutionally overbroad in State v. Boettger, 310 Kan. 800, 450 P.3d 805 (2019). But the State argued that the United States Supreme Court overruled Boettger when it determined that a mental state of recklessness was sufficient for a conviction in Counterman v. Colorado, 600 U.S. 66, 143 S. Ct. 2106, 216

2 L. Ed. 2d 775 (2023). The State also argued that when there are multiple versions of a crime, a district court should use a modified categorical approach to review the prior conviction beyond the statutory elements by looking to documents in the record which show the elements forming the basis of the prior conviction.

After the district court obtained a transcript of the criminal threat plea hearing from 2009, Dewey supplemented his response to the State's objection to the amended PSI report. Dewey argued that the factual basis in the transcript of that 2009 plea hearing did not establish that the criminal threat was made intentionally rather than recklessly.

The district court found that the factual basis from the 2009 plea hearing showed that Dewey made a criminal threat both intentionally and recklessly. The district court found that Dewey's correct criminal history score was B. At sentencing, the district court ordered Dewey to serve 128 months (10 years, 8 months) in prison, also ordering offender registration for 15 years.

Dewey timely appeals.

LEGAL ANALYSIS

I. Did the evidence show that Dewey's 2009 conviction was for intentional criminal threat?

Dewey argues that the district court incorrectly calculated his criminal history score because the State failed to prove that his prior conviction for criminal threat was constitutionally valid. The State responds that reckless criminal threat can be included in a criminal history score and, alternatively, that Dewey's conviction was for intentional criminal threat anyway.

3 Standard of Review

Whether a sentence is illegal is a question of law over which appellate courts exercise unlimited review. State v. Daniels, 319 Kan. 340, 342, 554 P.3d 629 (2024).

An illegal sentence is a sentence: (1) imposed by a court without jurisdiction; (2) that does not conform to the applicable statutory provisions, either in character or the term of punishment; or (3) that is ambiguous about the time and manner in which it is to be served. K.S.A. 22-3504(c)(1); State v. Mitchell, 315 Kan. 156, 158, 505 P.3d 739 (2022).

A court may correct an illegal sentence at any time while the defendant is serving the sentence. K.S.A. 22-3504(a). An illegal sentence may be corrected for the first time on appeal or sua sponte. State v. Gomez, 320 Kan. 3, 22, 561 P.3d 908 (2025); State v. Zongker, 319 Kan. 411, 437, 555 P.3d 698 (2024).

Under K.S.A. 21-6814(a), an offender may admit to criminal history in open court or the sentencing court will determine criminal history by a preponderance of the evidence at the sentencing hearing. See State v. Corby, 314 Kan. 794, 797, 502 P.3d 111 (2022). A defendant's admission to criminal history serves as an admission to the existence and classification of prior convictions, relieving the State of its burden of presenting additional evidence. 314 Kan. at 797-98.

When a defendant exercises the statutory right to challenge the accuracy of the convictions contained in the criminal history worksheet at the time of sentencing, the State bears the burden to prove by a preponderance of the evidence that the defendant committed the crime. K.S.A. 21-6814(c); Daniels, 319 Kan. at 347 (stating that opportunity to challenge accuracy of conviction in criminal history worksheet "is procedurally specific and time sensitive").

4 All prior convictions must be counted in determining a defendant's criminal history score unless the convictions constitute an element of the present crime, enhance the severity level, or elevate the classification from a misdemeanor to a felony. K.S.A. 21-6810(d)(10); State v. Fowler, 311 Kan. 136, 142, 457 P.3d 927 (2020). Convictions which have been declared unconstitutional are also excluded from a defendant's criminal history score. State v. Smith, 320 Kan. 62, 91, 563 P.3d 697 (2025).

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State v. Boettger
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State v. Fowler
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State v. Lindemuth
470 P.3d 1279 (Supreme Court of Kansas, 2020)
State v. Juarez
470 P.3d 1271 (Supreme Court of Kansas, 2020)
State v. Gales
476 P.3d 412 (Supreme Court of Kansas, 2020)
State v. Rhoiney
501 P.3d 368 (Supreme Court of Kansas, 2021)
State v. Corby
502 P.3d 111 (Supreme Court of Kansas, 2022)
State v. Mitchell
505 P.3d 739 (Supreme Court of Kansas, 2022)
State v. Trotter
295 P.3d 1039 (Supreme Court of Kansas, 2013)
State v. Dickey
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Counterman v. Colorado
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State v. Zongker
555 P.3d 698 (Supreme Court of Kansas, 2024)

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