State v. Hill

CourtCourt of Appeals of Kansas
DecidedJuly 17, 2026
Docket129113
StatusUnpublished

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

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 129,113

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v. KIRSTANNA MARIE HILL, Appellant.

MEMORANDUM OPINION

Appeal from Riley District Court; GRANT D. BANNISTER, judge. Submitted without oral argument. Opinion filed July 17, 2026. Vacated and remanded with directions.

Patrick H. Dunn, of Kansas Appellate Defender Office, for appellant.

David Lowden, deputy county attorney, Barry R. Wilkerson, county attorney, and Kris W. Kobach, attorney general, for appellee.

Before COBLE, P.J., HURST, J., and PAULA HOFAKER, District Judge, assigned.

PER CURIAM: Kirstanna Marie Hill was arrested and charged with criminal conduct and remained in custody for some period of time before eventually pleading guilty pursuant to a plea agreement. At sentencing, the district court awarded Hill jail time credit for some, but not all, of the time she spent incarcerated pending disposition of the charges in this case. Hill appeals the district court's jail time credit calculation, arguing she was entitled to credit for all the time she spent in custody pending the disposition of this case.

1 While the record on appeal is limited, it is sufficient to demonstrate that Hill was in custody for more time than the district court calculated when awarding jail time credit. Pursuant to applicable Kansas Supreme Court precedent, Hill is entitled to credit for all time in custody pending the disposition of this case. Accordingly, Hill's sentence is vacated as to the jail time credit calculation, and this matter is remanded to the district court for recalculation of her jail time credit award.

FACTUAL AND PROCEDURAL BACKGROUND

This case relates to a dispute about the number of days Hill received in jail credit, and thus the facts are limited to those related to her dates of incarceration. Hill was charged with one count of aggravated robbery and one count of aggravated assault on February 16, 2024. About a year later, pursuant to a plea agreement, on February 24, 2025, Hill pled guilty to one count of robbery and one count of aggravated assault. There are several documents indicating Hill was in custody for some time after her arrest and until she entered the guilty plea.

For example, the first appearance journal entry from August 16, 2024, indicates that Hill was in custody in Riley County Jail at the time of that occurrence. Then, again, the journal entry for a hearing about one month later indicates Hill was in custody; as does a journal entry for the preliminary hearing, which was held in November. Then the docket/activity sheet from December 5, 2024, also indicates Hill was in custody.

Evidence at the plea hearing indicates Hill was in custody at that time as well. After the district court accepted Hill's guilty plea, it granted Hill a four-day furlough from custody—from February 25, 2025, through March 1, 2025—for personal reasons. Then, at the sentencing hearing on March 31, 2025, counsel for Hill said, "She has been in custody since January 2nd of 2025," to which no one objected. The district court sentenced Hill to 49 months for the robbery conviction and 12 months for the aggravated

2 assault conviction, to be served concurrently. The court awarded Hill 108 days of jail credit. The journal entry of sentencing lists the dates of incarceration credit as between "1-2-25" and "3-31-25." An amended journal entry of sentencing identifies the same time range of incarceration credit and lists the award as 89 days of jail credit.

Hill appeals the calculation of her jail credit.

DISCUSSION

On appeal, Hill argues only that the district court erred in calculating her jail time credit. The State does not address the merits of Hill's claim. This means the State does not contend that the district court correctly calculated the jail time credit or that Hill's calculation is in error. The State only argues that because Hill raises this issue for the first time on appeal, the claim is not preserved, and this court should not consider it.

Preservation

It is undisputed that Hill failed to object to or raise any challenge to the district court's award of jail time credit at sentencing. Generally, issues not first raised before the district court are not considered on appeal. State v. Ervin, 320 Kan. 287, 306, 566 P.3d 481 (2025). However, there are several exceptions to that general prohibition, including: (1) the newly asserted theory involves only a question of law arising on proved or admitted facts and is finally determinative of the case; (2) consideration of the theory is necessary to serve the ends of justice or to prevent denial of fundamental rights; and (3) the district court was right for the wrong reason. State v. Allen, 314 Kan. 280, 283, 497 P.3d 566 (2021).

Hill first contends that she is entitled to this court's review because of recent decisions by the Kansas Supreme Court. See State v. Hopkins, 317 Kan. 652, 537 P.3d

3 845 (2023); Ervin, 320 Kan. at 306-07. Hill argues she should receive the benefit of these cases because they reflect a change in the law that occurred while her appeal was pending—which she alleges "supersedes preservation requirements." Even accepting her superseding argument, she is wrong for two reasons. First, Hopkins was decided prior to Hill's criminal conduct that resulted in her convictions in this case. Second, the Kansas Supreme Court has clarified that it does not consider Ervin to be a change in the law. See State v. Romey, 321 Kan. 400, 405, 419-20, 580 P.3d 1 (2025). Those arguments for review of her unpreserved claim are therefore unpersuasive.

Hill also contends that this court's review is appropriate because her appeal presents a question of law that can be decided on admitted facts—meeting an exception permitting review of unpreserved claims. See Allen, 314 Kan. at 283. However, in contrast to that contention, Hill contends that "it is unclear from the existing record exactly how many additional days of jail credit [she] is entitled to" and seeks a remand to the district court for a recalculation. This creates a problem because, "[w]hen an insufficient record prevents resolving an unpreserved issue, an appellate court abuses its discretion by invoking an exception" to preservation. State v. Unruh, 320 Kan. 260, 264- 65, 565 P.3d 825 (2025).

Hill also invokes another exception permitting review of her unpreserved claim, alleging that "'consideration of the claim is necessary to serve the ends of justice or to prevent the denial of a fundamental right.'" While Hill relies on a case where the Kansas Supreme Court said, "Subjecting a defendant to a longer sentence without a legal basis would be a miscarriage of justice," that case involved different issues than those here. State v. Williams, 311 Kan. 88, 94, 456 P.3d 540 (2020). In Williams, the defendant argued his sentence was illegal because the law changed while his appeal was pending, which is not the issue present here. However, there remains a concern that based on a calculation error Hill will serve more jail time than the law permitted, as discussed later.

4 The State argues that Hill has no fundamental interest in jail credit because the calculation and application of jail time credit is a product of statute. See State v. Babcock, 226 Kan. 356, 358, 597 P.2d 1117 (1979) (explaining that "[j]ail time credit is wholly a matter of statute").

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