State v. Lipp

CourtCourt of Appeals of Kansas
DecidedJanuary 2, 2026
Docket128069
StatusUnpublished

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

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 128,069

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

ERIC DAVID LIPP, Appellant.

MEMORANDUM OPINION

Appeal from Riley District Court; JOHN BOSCH, judge. Submitted without oral argument. Opinion filed January 2, 2026. Affirmed.

Kristen B. Patty, of Wichita, for appellant.

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

Before ARNOLD-BURGER, P.J., MALONE and BOLTON FLEMING, JJ.

PER CURIAM: Lipp appeals the district court's denial of his motion to correct an illegal sentence. He contends that he was unlawfully sentenced under the more serious of two identical offenses, when the identical offense doctrine instructs that he may only be sentenced under the lesser penalty of two identical offenses.

1 FACTUAL AND PROCEDURAL HISTORY

In August 2014, the State charged Eric Lipp with five counts, which included as count one possession of methamphetamine with intent to distribute at least 3.5 grams of methamphetamine, a severity level 2 drug felony, and as count three possession of methamphetamine with intent to distribute at least 10 dosage units of methamphetamine, a severity level 3 drug felony. Important to this case is the fact that both crimes were charged under the same subsection of the same statute. The version in effect when Lipp committed these crimes, K.S.A. 2014 Supp. 21-5705(a)(1), stated:

"(a) It shall be unlawful for any person to distribute or possess with the intent to distribute any of the following controlled substances or controlled substance analogs thereof: (1) Opiates, opium or narcotic drugs, or any stimulant designated in subsection (d)(1), (d)(3) or (f)(1) of K.S.A. 65-4107, and amendments thereto."

The statute goes on to provide that the severity level of the offense is determined by the quantity and form of the drugs seized. A severity level 2 drug felony under K.S.A. 2014 Supp. 21-5705(a)(l), (d)(3)(C), which was the basis for count one of the complaint, requires at least 3.5 grams but less than 100 grams of the listed drug. A severity level 3 drug felony under K.S.A. 2014 Supp. 21-5705(a)(l), (d)(4)(B), which was the basis for count three of the complaint, requires a number of dosage units of at least 10 but less than 100.

At trial, the State presented two baggies containing crystalline substances weighing 28.54 grams and 3.14 grams that were found in Lipp's possession and tested positive for methamphetamine in support of count one. For count three the State presented evidence that ten of the thirty-seven tablets found in Lipp's possession tested positive for methamphetamine, indicating that the remaining tablets were also Schedule II controlled substances. 2 Lipp moved for acquittal after the State presented its evidence, arguing that his possession charges in counts one and three were multiplicitous. When addressing the motion, State's counsel stated that the issue might be accurate at a later stage but not at that point in the trial. State's counsel explained that count one alleged possession with intent to distribute between 3.5 grams and 100 grams of methamphetamine, while count three involved methamphetamine in pill form, which constituted a different element—10 or more dosage units but fewer than 100.

State's counsel noted that although both counts involved methamphetamine, the distinction was based on the form of the substance: dosage units in pill form for count three, and methamphetamine measured by weight in powder or crystal form for count one. The court denied the motion on count three, finding it was not multiplicitous because count one concerned methamphetamine in bulk form while count three concerned methamphetamine in dosage units—pills. Lipp was found guilty of all counts.

Before sentencing, Lipp filed a motion for a new trial and a motion for departure sentence requesting a dispositional and/or durational departure. Lipp also filed a motion to find convictions identical, arguing that counts one and three were identical and also renewing his objection that counts one and three were multiplicitous or identical. He requested that the court vacate count three and not impose a sentence for it.

During sentencing, the State agreed that counts one and three both involved methamphetamine. The State noted that although the counts involved different forms of the substance, it did not object to treating them as the same offense and dismissing count three for sentencing purposes. The district court agreed with the parties and set aside the severity level three drug felony in count three. The district court also denied the motion for a new trial and the motion for a departure sentence. The district court imposed a controlling prison sentence of 142 months.

3 Lipp timely filed his direct appeal. In that appeal, Lipp alleged two errors, the denial of his motion to suppress evidence and denial of his dispositional and/or durational departure motion at sentencing. This court affirmed the district court's ruling on the evidence issue and dismissed the sentencing issue for lack of jurisdiction. See State v. Lipp, No. 116,424, 2017 WL 3327101 (Kan. App. 2017) (unpublished opinion).

In 2018, Lipp filed a K.S.A. 60-1507 motion, which was summarily denied. The identical offense argument was not raised.

In October 2023, Lipp filed a pro se motion to correct illegal sentence, under K.S.A. 22-3504. He argued for the first time that he should have been sentenced to a severity level three sentence under count three, since count one and count three were deemed identical. The district court denied the motion, as relief was barred under res judicata and the identical offense doctrine did not apply because the convictions were multiplicitous, not identical.

Following the dismissal, Lipp filed a timely notice of appeal.

ANALYSIS

Lipp contends that the district court erred when it denied his motion to correct an illegal sentence under K.S.A. 22-3504. He claims he should have received the lower, severity level three drug sentence for count three because counts one and three were identical.

An illegal sentence issue "can be raised at any time regardless of whether the issue was presented to the district court." State v. Johnson, 309 Kan. 992, 995, 441 P.3d 1036 (2019). Whether a sentence is illegal is a question of law over which appellate courts exercise unlimited review. See State v. Daniels, 319 Kan. 340, 342, 554 P.3d 629 (2024).

4 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

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

Related

State v. Snellings
273 P.3d 739 (Supreme Court of Kansas, 2012)
State v. Harp
156 P.3d 1268 (Supreme Court of Kansas, 2007)
State v. Sandberg
235 P.3d 476 (Supreme Court of Kansas, 2010)
State v. Johnson
441 P.3d 1036 (Supreme Court of Kansas, 2019)
State v. Juiliano
504 P.3d 399 (Supreme Court of Kansas, 2022)
State v. Mitchell
505 P.3d 739 (Supreme Court of Kansas, 2022)
State v. Loganbill
518 P.3d 437 (Court of Appeals of Kansas, 2022)
State v. Daniels
554 P.3d 629 (Supreme Court of Kansas, 2024)

Cite This Page — Counsel Stack

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