State v. Fosnight

CourtCourt of Appeals of Kansas
DecidedFebruary 13, 2026
Docket126812
StatusUnpublished

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

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 126,812

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee

v.

RODNEY FOSNIGHT, Appellant.

MEMORANDUM OPINION

Appeal from Labette District Court; STEVEN A. STOCKARD, judge. Submitted without oral argument. Opinion filed February 13, 2026. Affirmed in part, vacated in part, and remanded with directions.

Michelle A. Davis, of Kansas Appellate Defender Office, for appellant.

Alan Brereton, deputy county attorney, and Kris W. Kobach, attorney general, for appellant.

Before BRUNS, P.J., HILL and ATCHESON, JJ.

PER CURIAM: A jury sitting in Labette County District Court convicted Rodney Fosnight of multiple sex crimes against a pair of 16-year-old girls he picked up and plied with alcohol. On appeal, Fosnight asserts the district court erred in finding the highly inculpatory statements he made to a Labette County Sheriff's detective were voluntary and thus admissible in the trial. He also asserts the district court improperly relied on a juvenile adjudication of his for rape to enhance his sentence for the rape conviction in this case. Fosnight fails on his first point, but his sentencing challenge has merit. We,

1 therefore, affirm his convictions, vacate his sentence for rape, and remand to the district court with directions for resentencing.

FACTUAL AND PROCEDURAL HISTORY

Because Fosnight has not challenged the sufficiency of the evidence supporting the convictions, we offer a highly condensed account of the underlying facts, recognizing that the parties are familiar with the trial record. In April 2022, T.K. and K.Z. approached a Parsons police officer and told him that the day before, Fosnight invited them to ride around with him in his truck. According to the girls, Fosnight drove to a liquor store and bought beer and other alcoholic beverages. The three then drove to a secluded area. Fosnight directed the girls to engage in sexual conduct with each other. They complied. He then joined them in the backseat of the truck and engaged in sex acts with each of them.

Based on their account, another Parsons police officer stopped and arrested Fosnight. The officer smelled alcohol on Fosnight's breath and found a still-cold six-pack of beer in his truck with two cans missing. Because the encounter T.K. and K.Z. described occurred outside the city limits of Parsons, the officers handed off the case to Sheriff's Detective Shannon Vail. Vail conducted videotaped interviews of T.K. and K.Z. He then questioned Fosnight. Fosnight acknowledged engaging in sexual activity with the girls but suggested they had consented. T.K. and K.Z. were adamant they had not agreed to any sexual contact with Fosnight.

The jury heard evidence over three days in January 2023. T.K., K.Z., and Det. Vail, among others, testified as State's witnesses. The State also introduced the videotaped statements from the girls and Fosnight's videotaped interrogation. Fosnight neither testified in his own defense nor called any other witnesses. The jury convicted Fosnight of two counts each of aggravated human trafficking and furnishing alcoholic

2 beverages to a minor for illicit purposes and one count each of rape, aggravated criminal sodomy, and aggravated sexual battery of K.Z. The jury found him not guilty of the rape and aggravated sexual battery of T.K.

At a later sentencing hearing, the district court designated the conviction for the rape of K.Z. as the primary crime of conviction. Given Fosnight's undisputed criminal history score of B, the conviction, as a severity level 1 person felony, carried a presumptive guidelines sentence of between 554 and 618 months in prison. The district court relied on Fosnight's 1974 juvenile adjudication for rape to double his presumptive sentence as a persistent sex offender under K.S.A. 21-6804(j). The district court ordered Fosnight to serve 1,236 months in prison on the rape conviction. And it imposed aggregate terms of 509 months on the other convictions to be served concurrently with each other and with the sentence for the rape conviction. Fosnight has duly appealed.

LEGAL ANALYSIS

On appeal, Fosnight has raised two issues. First, he challenges the district court's ruling allowing Det. Vail's interrogation of him to be presented to the jury. Second, he disputes the legal propriety of the district court using his juvenile adjudication to double his controlling sentence for rape. We take those points up in that order and add factual and procedural background for each, as necessary.

Admission of Interrogation

Before trial, Fosnight filed a motion for a Jackson v. Denno hearing to determine the voluntariness of his statements to Det. Vail. The district court denied the motion. Fosnight lodged an objection at trial, preserving the issue for appellate review.

3 An involuntary statement is one that is not the product of the defendant's free will. Townsend v. Sain, 372 U.S. 293, 308, 83 S. Ct. 745, 9 L. Ed. 2d 770 (1963), overruled on other grounds by Keeney v. Tamayo-Reyes, 504 U.S. 1, 5, 112 S. Ct. 1715, 118 L. Ed. 2d 318 (1992); State v. Fernandez-Torres, 50 Kan. App. 2d 1069, 1075-76, 337 P.3d 691 (2014). A defendant's involuntary statements made to government agents may not be admitted as evidence at trial because their involuntariness renders them inherently unreliable. Kansas v. Ventris, 556 U.S. 586, 590, 129 S. Ct. 1841, 173 L. Ed. 2d 801 (2009); Jackson v. Denno, 378 U.S. 368, 376, 84 S. Ct. 1774, 12 L. Ed. 2d 908 (1964). To do otherwise would contravene a defendant's rights against self-incrimination and due process protected in the Fifth and Fourteenth Amendments to the United States Constitution. Ventris, 556 U.S. at 590; Dickerson v. United States, 530 U.S. 428, 433, 120 S. Ct. 2326, 147 L. Ed. 2d 405 (2000); State v. Schultz, 289 Kan. 334, 342-43, 212 P.3d 150 (2009).

The voluntariness of a defendant's statement to law enforcement officers depends upon the totality of the circumstances, although the appellate courts have developed a nonexclusive set of factors to be considered. We have set out the governing principles this way:

"The ultimate issue is whether the statements reflect the product of a free and independent will, i.e., did the individual act voluntarily? See State v. Gilliland, 294 Kan. 519, Syl. ¶¶ 3, 4, 276 P.3d 165 (2012); State v. Stone, 291 Kan. 13, 21, 237 P.3d 1229 (2010); State v. Shumway, 30 Kan. App. 2d 836, 841-42, 50 P.3d 89, rev. denied 274 Kan. 1117 (2002). In short, the district court must examine the totality of the circumstances surrounding the making of the statements.

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Related

Townsend v. Sain
372 U.S. 293 (Supreme Court, 1963)
Jackson v. Denno
378 U.S. 368 (Supreme Court, 1964)
Hutto v. Ross
429 U.S. 28 (Supreme Court, 1976)
Keeney v. Tamayo-Reyes
504 U.S. 1 (Supreme Court, 1992)
Dickerson v. United States
530 U.S. 428 (Supreme Court, 2000)
Kansas v. Ventris
556 U.S. 586 (Supreme Court, 2009)
State v. Gilliland
276 P.3d 165 (Supreme Court of Kansas, 2012)
State v. Brown
182 P.3d 1205 (Supreme Court of Kansas, 2008)
State v. Shumway
50 P.3d 89 (Court of Appeals of Kansas, 2002)
State v. Schultz
212 P.3d 150 (Supreme Court of Kansas, 2009)
State v. Woolverton
159 P.3d 985 (Supreme Court of Kansas, 2007)
State v. Boyer
209 P.3d 705 (Supreme Court of Kansas, 2009)
State v. Stone
237 P.3d 1229 (Supreme Court of Kansas, 2010)
State v. Fernandez-Torres – (
337 P.3d 691 (Court of Appeals of Kansas, 2014)
State v. Patterson
371 P.3d 893 (Supreme Court of Kansas, 2016)
State v. Warren
412 P.3d 993 (Supreme Court of Kansas, 2018)
State v. Mejia
466 P.3d 1217 (Court of Appeals of Kansas, 2020)
State v. Randolph
301 P.3d 300 (Supreme Court of Kansas, 2013)

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