State v. Kolbek

CourtCourt of Appeals of Kansas
DecidedDecember 12, 2025
Docket127313
StatusUnpublished

This text of State v. Kolbek (State v. Kolbek) 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. Kolbek, (kanctapp 2025).

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 127,313

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

MATTHEW J. KOLBEK JR., Appellant.

MEMORANDUM OPINION

Appeal from Shawnee District Court; CHERYL A. RIOS, judge. Submitted without oral argument. Opinion filed December 12, 2025. Affirmed.

Wendie C. Miller, of Kechi, for appellant.

Carolyn A. Smith, assistant district attorney, Michael F. Kagay, district attorney, and Kris W. Kobach, attorney general, for appellee.

Before HURST, P.J., GARDNER and BOLTON FLEMING, JJ.

PER CURIAM: Matthew J. Kolbek Jr. appeals the Shawnee County District Court's denial of his motion to correct an illegal sentence. He argues his prior criminal threat conviction was improperly included in his criminal history score, resulting in an illegal sentence. But because our review shows that Kolbek has failed to meet his burden of proof on this matter, we affirm.

1 FACTUAL AND PROCEDURAL BACKGROUND

In May 2021, Kolbek pleaded guilty to aggravated burglary and aggravated assault with a deadly weapon in case 19 CR 1810 and possession with the intent to distribute cocaine in case 18 CR 2851. As part of the plea agreement, the State agreed not to refile charges in a third dismissed case, and Kolbek indicated that he expected his criminal history score to be B.

Kolbek's presentence investigation (PSI) report included a 2016 conviction for criminal threat that was scored as a person felony. This conviction, which the PSI report generally described as a "Criminal Threat" under K.S.A. 21-5415(a)(1), gives rise to this appeal.

Kolbek's two cases were consolidated for sentencing under 19 CR 1810. At sentencing, the district court found Kolbek's criminal history score to be B because of the two person felonies on his PSI report. Kolbek did not object. In July 2021, the district court sentenced him to a term of 168 months in prison in the two cases. Kolbek did not appeal.

Two years later, Kolbek moved to correct an illegal sentence. He argued that his prior criminal threat conviction was for reckless conduct so it should not have been included in his criminal history, based on State v. Boettger, 310 Kan. 800, 450 P.3d 805 (2019). Boettger held that "the reckless disregard provision encompasses more than true threats and thus potentially punishes constitutionally protected speech. The reckless disregard provision is thus overbroad and unconstitutional." State v. Johnson, 310 Kan. 835, 842, 450 P.3d 790 (2019). Kolbek argued that the factual basis given at the plea hearing for his criminal threat conviction did not show he had made an intentional criminal threat, but only a reckless one.

2 The State responded that although the Kansas Supreme Court had not overruled Boettger, the United States Supreme Court had effectively done so in Counterman v. Colorado, 600 U.S. 66, 81-82, 143 S. Ct. 2106, 216 L. Ed. 2d 775 (2023). Counterman held that the First Amendment to the United States Constitution requires proof of a defendant's subjective understanding of the threatening nature of a statement to be punished as a crime, but a mental state of recklessness is sufficient to establish a true threat, contrary to Boettger. And we are duty bound to follow controlling United States Supreme Court precedent. See State v. Davidson, 314 Kan. 88, 91, 495 P.3d 9 (2021); State v. Kornelson, 311 Kan. 711, 715, 466 P.3d 892 (2020); State v. Lawson, 296 Kan. 1084, Syl. ¶ 1, 297 P.3d 1164 (2013) ("The United States Supreme Court's interpretation of the United States Constitution is controlling upon and must be followed by state courts."). So, under Counterman, the State argued that Kolbek's prior criminal threat conviction was properly scored as a person felony.

The district court denied Kolbek's motion. It noted that Kolbek was claiming that "his prior conviction for criminal threat was based on reckless behavior despite a lack of clear findings" in that case. It then focused, as the parties did, on the legal arguments. It observed that Boettger had been decided before Kolbek was sentenced, so Boettger would usually apply to Kolbek's sentencing claim. But the district court found that at the time Boettger was decided, the United States Supreme Court had not decided "whether someone who utters a threat of violence in reckless disregard of causing fear has uttered a true threat." The district court also noted that between the time Kolbek filed his motion and the State responded, a panel of this court decided State v. Phipps, 63 Kan. App. 2d 698, 539 P.3d 227 (2023), appeal dismissed 320 Kan. 616, 624, 570 P.3d 1240 (2025), reh. granted October 17, 2025. The Phipps panel opined that "perhaps the holding in Counterman is what the Kansas Supreme Court calls a 'subsequent development[ ] in the law,' rather than a true change in the law, that shows that an earlier determination—the holding in Boettger—was wrong on the merits." 63 Kan. App. 2d at 710.

3 The district court found this reasoning persuasive and concluded that Counterman and Phipps were subsequent developments in the law that applied to Kolbek, so Boettger did not apply. The district court thus held that Kolbek's sentence was legal:

"To summarize, [Kolbek] would benefit from the ruling in Boettger because it was decided before he was sentenced. In contrast, Counterman and Phipps both occurred after the finality of [Kolbek's] sentence, which occurred after the 14-day appeal period expired. Normally, the rulings in Counterman and Phipps would not have applicability to this analysis. However, based on the discussion in Murdock, the Court finds the rulings in Counterman and Phipps are 'subsequent developments' in the law, which impact the Court's reliance on Boettger. This Court must follow United States Supreme Court precedent on constitutional issues, meaning Boettger is no longer good law based on the ruling in Counterman. "At the time [Kolbek] was sentenced, the statute making reckless criminal threats a crime was considered unconstitutional based on the ruling in Boettger, which we now recognize as an incorrect interpretation of the law. As a result, the Defendant's sentence was legal at the time it was pronounced."

Kolbek now timely appeals the district court's denial of his motion to correct an illegal sentence. We note, however, that the Kansas Supreme Court recently granted motions for rehearing and modification by both parties in Phipps, 320 Kan. 616, so we do not rely on that case.

ANALYSIS

Did the district court err by denying Kolbek's motion to correct an illegal sentence?

Kolbek argues that his sentence is illegal because his prior reckless criminal threat conviction was erroneously scored as a person felony, resulting in an incorrect criminal history score. He contends that had the reckless criminal threat conviction not been included in his criminal history. That exclusion would have reduced his criminal history

4 score from a B to a D.In response, the State argues that Counterman, 600 U.S. 66

Free access — add to your briefcase to read the full text and ask questions with AI

Related

State v. Hoge
150 P.3d 905 (Supreme Court of Kansas, 2007)
State v. Overman
348 P.3d 516 (Supreme Court of Kansas, 2015)
State v. Obregon
444 P.3d 331 (Supreme Court of Kansas, 2019)
State v. Johnson
450 P.3d 790 (Supreme Court of Kansas, 2019)
State v. Boettger
450 P.3d 805 (Supreme Court of Kansas, 2019)
State v. Kornelson
466 P.3d 892 (Supreme Court of Kansas, 2020)
State v. Lindemuth
470 P.3d 1279 (Supreme Court of Kansas, 2020)
State v. Davidson
495 P.3d 9 (Supreme Court of Kansas, 2021)
In the Interest of B.D.-Y.
187 P.3d 594 (Supreme Court of Kansas, 2008)
State v. Lawson
297 P.3d 1164 (Supreme Court of Kansas, 2013)
State v. Dickey
350 P.3d 1054 (Supreme Court of Kansas, 2015)
Counterman v. Colorado
600 U.S. 66 (Supreme Court, 2023)
Mariani v. Driver License Division
2024 UT 44 (Utah Supreme Court, 2024)
State v. Smith
563 P.3d 697 (Supreme Court of Kansas, 2025)
State v. Daniels
554 P.3d 629 (Supreme Court of Kansas, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
State v. Kolbek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-kolbek-kanctapp-2025.