State v. Marlar

Court of Appeals of Kansas·Decided August 21, 2026·No. 129045·Unpublished

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 129,045

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS,

Appellee,

v.

ANDREW PAUL MARLAR,

Appellant.

MEMORANDUM OPINION

Appeal from Leavenworth District Court; GERALD R. KUCKELMAN, judge. Submitted without oral argument. Opinion filed August 21, 2026. Affirmed.

Andrew J. McGowan, of Kansas Appellate Defender Office, for appellant.

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

Before ARNOLD-BURGER, P.J., MALONE and PICKERING, JJ.

PER CURIAM: Andrew Paul Marlar pled guilty to a felony count of criminal damage to property and a misdemeanor count of aggravated assault on a law enforcement officer, then he moved to withdraw his plea before sentencing. Marlar appeals the district court's decision to deny his motion. Finding no error, we affirm.

FACTUAL AND PROCEDURAL HISTORY

In January 2024, the State charged Marlar with felony criminal damage to property, misdemeanor assault on a law enforcement officer, and misdemeanor

interference with law enforcement. The charges stemmed from an incident in which Marlar allegedly fled from officers trying to serve outstanding warrants, resisted being placed in handcuffs, and attempted to bite an officer's knee. In addition, he damaged the interior of the patrol vehicle while being transported. At the time of his arrest, the district court set a $10,000 cash/surety bond. About a week later, the court appointed Anthony Russo to represent Marlar.

Over the next three months, Russo represented Marlar through the waiver of his right to a preliminary hearing and entry of a not guilty plea. During this time, the district court set a trial date for June 2024 with corresponding deadlines for pretrial motions and pretrial hearings in the month leading up to the trial date. District Judge Gerald Kuckelman presided over these hearings.

In early May 2024, Marlar sent a letter to the district court articulating that he was dissatisfied with Russo's representation in this case as well as another one. Marlar claimed Russo had not visited him in jail, had not provided access to any discovery, and was working with the prosecution against Marlar's interests. The court forwarded the letter to Russo.

Around this time, the State also filed several timely pretrial motions, including a notice of proposed exhibits, a notice of proposed witnesses, a motion to endorse witnesses, and a joint order of reciprocal discovery signed by the prosecutor and Russo.

At a hearing in mid-May 2024 set to address Marlar's request for replacement counsel and the State's pretrial motions, Judge Kuckelman began by noting the parties appeared to have reached a resolution and asked Marlar if he still wanted a new attorney. Marlar responded that he was "just trying to get this done with, to be honest," adding that he resolved his "complications . . . getting in touch with [Russo]." Marlar confirmed that he wanted to proceed with Russo representing him.

Russo explained that Marlar had agreed to plead guilty to the charges of criminal damage to property and assault on a law enforcement officer, while the State would dismiss the interference with law enforcement charge. As for sentencing, the parties only agreed that Marlar would not object to the amount of the State's restitution request. The State explained that the restitution would likely be more than $4,000 and that "[e]verything else is open for . . . argument at sentencing." Marlar likewise confirmed that was his understanding of the agreement.

The district court then reviewed the plea agreement, which Marlar had both signed and initialed in the form of a motion to accept plea, indicating his acknowledgment of the terms. Marlar verbally confirmed that he read and understood it and that Russo had explained the terms to him. The court asked Marlar if he understood that the criminal damage to property charge was "a level 9 nonperson felony, which carries from 5 months up to 17 months with the Department of Corrections, depending upon criminal history" and that the assault on a law enforcement officer charge was "a class A misdemeanor, which carries up to one year in the county jail and up to a $2500 fine." Marlar agreed that he understood the possible penalties.

The district court judge next asked Marlar if he had "discuss[ed] all the possible consequences with [Russo]," to which Marlar said, "Some of them, I'm not su—I don't think completely all of them, no. I just—I'm not sure exactly all the punishments. It's— it's just left as an open sentence, so I don't—I don't know what exactly all the punishments could require, no." The following exchange then occurred:

"THE COURT: All right. Well, maybe we should take a moment and have your attorney explain it to you. We need to make sure you understand what you're getting into before you enter this plea.

"THE DEFENDANT: I just—like I said, I just understand that it's an open sentence. I don't know if that—that just means like it—it could be anything; right?

"THE COURT: Well, it has—

"MR. RUSSO: Well, it's— "THE COURT: —to be within the range that I just described. "THE DEFENDANT: Okay. Within the—within the sentencing grid. "THE COURT: Yes. "THE DEFENDANT: Okay, yeah. Then I understand that, yeah."

Satisfied with Marlar's responses, the district court asked Marlar how he would like to plead, to which Marlar said he would plead guilty to the charges of criminal damage to property and assault on a law enforcement officer. The court then asked Marlar a series of questions to confirm that he was entering the plea knowingly, voluntarily, and intelligently, including that Marlar understood he was waiving his constitutional rights, had not been threatened or coerced into entering the plea, had not used any substances that affected his ability to understand the proceedings, that there was a sufficient factual basis for the charges, and that he had adequate time to confer with Russo before going forward with the plea. Satisfied with Marlar's responses, the court accepted Marlar's guilty plea and set the matter for sentencing.

The initial presentence investigation (PSI) report reflected that Marlar had a B criminal history score based on six prior person misdemeanors that were converted to two person felonies. Russo filed an objection to the PSI on Marlar's behalf, challenging the person classification for a 2023 misdemeanor conviction for third degree assault in Colorado, arguing that it should be a nonperson misdemeanor because the Colorado statutory elements were broader than the comparable Kansas offense. With that change, Marlar should have a D criminal history score. Because Russo filed the objection just before the sentencing was set to occur, Judge Kuckelman reset sentencing to occur two weeks later.

A few days before the hearing, Marlar sent a second letter to the district court articulating his dissatisfaction with Russo's representation and requesting appointment of new counsel in both this case and another unrelated case. In addition to reiterating his

previous claims about inadequate communication, Marlar now asserted that Russo had "threatened me into taking a plea deal that was not explained or understood."

District Judge Clinton W. Lee—who was presiding in the unrelated case—took up Marlar's request at a subsequent hearing. Although Russo disputed Marlar's reasoning, he did not object to the request for replacement counsel. So, Judge Lee granted Marlar's request and appointed Joel Rook to represent Marlar going forward, resetting the sentencing for the next month.

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