State v. Diaz-Gonzalez

CourtCourt of Appeals of Kansas
DecidedJune 26, 2026
Docket129425
StatusUnpublished

This text of State v. Diaz-Gonzalez (State v. Diaz-Gonzalez) 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. Diaz-Gonzalez, (kanctapp 2026).

Opinion

NOT DESIGNATED FOR PUBLICATION

Nos. 129,425 129,426 129,427

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

MAURICIO ALEJANDRO DIAZ-GONZALEZ, Appellant.

MEMORANDUM OPINION

Appeal from Ford District Court; SIDNEY R. THOMAS, judge. Submitted without oral argument. Opinion filed June 26, 2026. Vacated in part and remanded with directions.

Peter Maharry, of Kansas Appellate Defender Office, for appellant.

Tyler W. Winslow, assistant solicitor general, and Kris W. Kobach, attorney general, for appellee.

Before WARNER, C.J., ISHERWOOD and HURST, JJ.

PER CURIAM: Mauricio Alejandro Diaz-Gonzalez appeals the district court's calculation and imposition of jail credit after being sentenced in three separate cases. While on felony bond, Diaz-Gonzalez picked up two additional criminal cases, each with multiple charges. The district court sentenced him to consecutive underlying prison sentences for the three cases but suspended those sentences and imposed a single probation term. After multiple opportunities on probation, the court revoked Diaz- Gonzalez' probation and imposed the underlying sentences. The court awarded him jail

1 credit for time spent in custody in the first case alone but awarded no jail time credit in the other two cases. Diaz-Gonzalez now challenges that jail credit award on appeal.

FACTUAL AND PROCEDURAL BACKGROUND

While the underlying facts of Diaz-Gonzalez' criminal conduct are not relevant, it is necessary to recount a timeline of events to assess his claim for jail credit. The State charged Diaz-Gonzalez in case 2023-CR-300088 (Case One) with possession of methamphetamine and three related counts and released him on bond. Shortly thereafter, while out on bond, he fled from an attempted traffic stop and was arrested. The State charged him in case 2024-CR-000002 (Case Two) with possession of methamphetamine, fleeing or attempting to elude, reckless driving, and related counts.

Again, Diaz-Gonzalez was released on bond, but he violated his bond conditions in January 2024 when he tested positive for controlled substances and admitted to illegal drug use. His bond was revoked, and he remained in custody for seven days.

In February 2024, Diaz-Gonzalez appeared for preliminary hearings in Cases One and Two where he plead no contest to some charges and the State dismissed the remaining charges. Then, while out on bond in Cases One and Two in April 2024, he fled on foot from an attempted traffic stop and was arrested a third time. The State charged him in case 2024-CR-000155 (Case Three) with possession of methamphetamine, interference with law enforcement, and related counts. In May 2024, he waived his preliminary hearing in Case Three and entered a no contest plea to interference with law enforcement, and the State dismissed the remaining counts.

In June 2024, the district court sentenced Diaz-Gonzalez in all three cases. In Case One, the court imposed an underlying 32-month prison term and placed him on 18 months of probation. In Case Two, it imposed an 11-month prison term consecutive to

2 Case One—because he committed those crimes while on felony bond in Case One—and again suspended the sentence to probation. In Case Three, the district court imposed a 13- month prison term consecutive to Cases One and Two for the same reason, once again suspending the sentence to probation. Therefore, the district court ordered the three underlying sentences to run consecutively. The district court credited all 25 days of jail time accrued before sentencing to Case One alone, meaning that Diaz-Gonzalez received 25 days of jail time credit total.

In September 2024, following probation violation proceedings in which Diaz- Gonzalez was found to have violated the terms and conditions of probation, he had accrued a total of 70 days of jail credit. The court allocated all the jail time credit to Case One as "the lead case," imposed a three-day jail sanction, and extended probation by 18 months, warning that any further violation would result in imposition of the full underlying sentence. Two weeks later, the State filed another revocation motion, and at a November 2024 hearing, the court gave Diaz-Gonzalez "one more chance" on probation.

In April 2025, Diaz-Gonzalez led officers on a high-speed chase, threw a firearm from his vehicle, and subsequently plead no contest to two felony charges in case 2025- CR-000178 (Case Four). As part of that plea agreement, he also admitted to violating his probation in Cases One, Two, and Three. Having found that Diaz-Gonzalez yet again violated his probation, in June 2025 the district court revoked his probation and imposed his underlying sentences in Cases One, Two, and Three.

The journal entry for Case One reflected 154 total days of jail time credit—25 awarded at the original sentencing plus 129 accrued during probation. The journal entries for Cases Two and Three each awarded zero days, noting only "All jail credit to [Case One]." Diaz-Gonzalez appeals the jail-credit decisions pertaining to Cases One, Two, and Three, and this court consolidated the cases for this decision.

3 DISCUSSION

Diaz-Gonzalez argues for the first time on appeal that the district court should have credited his sentences in Cases Two and Three—not just Case One—for the time he spent incarcerated while those cases were pending. In short, he requests 150 days of jail credit in Case Two and 142 days of jail credit in Case Three.

The State accurately notes that Diaz-Gonzalez failed to request this jail credit at the district court and failed to object to the district court's jail credit determination. As such, the State contends he should not be allowed to challenge his jail credit on appeal. Diaz-Gonzalez argues that although issues generally cannot be first raised on appeal and must be presented to the district court first, one of the well-recognized exceptions to that general prohibition applies here. See State v. Green, 315 Kan. 178, 182, 505 P.3d 377 (2022) ("In general, issues not raised before the district court may not be raised on appeal."). Specifically, he contends that this is merely a question of law on admitted facts that this court and the Kansas Supreme Court have addressed for the first time on appeal. See State v. Rhoiney, 314 Kan. 497, 500, 501 P.3d 368 (2021) (identifying exceptions to the preservation requirement); State v. Ervin, 320 Kan. 287, 306, 566 P.3d 481 (2025) (addressing jail credit for the first time on appeal); State v. Brown, 65 Kan. App. 2d 663, 672-73, 570 P.3d 1278 (2025) (addressing a jail credit issue for the first time on appeal).

The State argues that Diaz-Gonzalez should not be allowed to challenge his jail credit award for the first time on appeal because the recent Kansas Supreme Court cases supporting his argument are inapplicable to his case. See Ervin, 320 Kan. at 306 (opinion related to jail time credit filed April 11, 2025); State v. Hopkins, 317 Kan. 652, 655-59, 537 P.3d 845 (2023) (opinion related to jail time credit filed October 20, 2023); see also State v. Romey, 321 Kan. 400, 419, 580 P.3d 1 (2025) (With regard to jail time credit, "the change in the law was [Hopkins] not Ervin."). Indeed, the decision that he relies on is Hopkins—decided in October 2023—predated Diaz-Gonzalez' crimes in Case One

4 which were committed in December 2023.

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Related

State v. Overton
112 P.3d 244 (Supreme Court of Kansas, 2005)
State v. Rhoiney
501 P.3d 368 (Supreme Court of Kansas, 2021)
State v. Patton
503 P.3d 1022 (Supreme Court of Kansas, 2022)
State v. Juiliano
504 P.3d 399 (Supreme Court of Kansas, 2022)
State v. Hopkins
537 P.3d 845 (Supreme Court of Kansas, 2023)
State v. Daniels
554 P.3d 629 (Supreme Court of Kansas, 2024)
State v. Ervin
566 P.3d 481 (Supreme Court of Kansas, 2025)

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State v. Diaz-Gonzalez, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-diaz-gonzalez-kanctapp-2026.