State v. Parra

CourtCourt of Appeals of Kansas
DecidedMarch 13, 2026
Docket128621
StatusUnpublished

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

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 128,621

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

ISAAC A. PARRA, Appellant.

MEMORANDUM OPINION

Appeal from Sedgwick District Court; BRUCE BROWN, judge. Submitted without oral argument. Opinion filed March 13, 2026. Affirmed.

Mark T. Schoenhofer, of Wichita, for appellant.

Kristi D. Allen, assistant district attorney, Marc Bennett, district attorney, and Kris W. Kobach, attorney general, for appellee.

Before WARNER, C.J., MALONE and HILL, JJ.

HILL, J.: One of the surest ways to have your probation revoked is to admit to your sentencing court that you have committed new drug crimes while on probation for committing drug crimes. Here, Isaac A. Parra admitted at a probation revocation hearing that he had committed several new crimes. Some of those new crimes were drug related.

After acknowledging Parra's admissions, the judge summed up the circumstances as he saw them, offering observations of Parra's struggle with drugs, and then revoked his probation. The court sent him to prison to serve his 161-month sentence.

1 Parra appeals that revocation, claiming that some confusing, conflicting comments by the judge show that he has been deprived of due process. Those comments show, in Parra's view, that the district court sent him to prison because it did not understand that it could exercise its discretion and not send him to prison. Indeed, our cases show that a court's failure to exercise discretion simply because it does not understand that it could exercise discretion can be ruled as an abuse of discretion; we will review the leading case shortly. Here, Parra claims such an abuse of discretion and asks us to reverse the district court's revocation order.

We have examined the court's comments and cannot agree with Parra's view of them. When read in context, we conclude that the judge knew what he was doing and sent Parra to prison because he committed those new crimes. This is a valid exercise of the court's discretion. Thus, we affirm.

A term of probation follows a guilty plea.

In September 2023, Parra pled guilty to one count of possession of marijuana with the intent to distribute within 1,000 feet of a school, and one count of possession of proceeds derived from violations of drug laws. The court, in November 2023, granted Parra's motion for a dispositional departure and placed him on probation after suspending his 161-month prison sentence.

About a year later, in November 2024, Parra returned to court to answer allegations that he had violated the conditions of his probation by committing new crimes, such as driving while his license was suspended and possession of marijuana and opiates. He waived his right to an evidentiary hearing on those allegations and admitted to the violations. He asked to be returned to probation.

2 The district court revoked Parra's probation and sent him to prison.

The rules we must follow here are well established.

Once a probation violation is proved, a district court has discretion to revoke probation and impose the original sentence unless the court is otherwise limited by statute. We review a district court's decision to revoke an offender's probation for an abuse of discretion. The offender bears the burden of establishing such an abuse of discretion. State v. Tafolla, 315 Kan. 324, 328, 508 P.3d 351 (2022). A district court abuses its discretion when its action is based on an error of law or fact or is arbitrary, fanciful, or unreasonable. State v. Bilbrey, 317 Kan. 57, 63, 523 P.3d 1078 (2023). Interpretation of a sentencing statute is a question of law, and our standard of review of that interpretation is unlimited. See State v. Moore, 309 Kan. 825, 828, 441 P.3d 22 (2019).

Because Parra received a dispositional departure sentence—probation instead of prison—we need not concern ourselves with the lack of any intermediate sanctions imposed on Parra. The law permits a district court to revoke probation without imposing a prior intermediate sanction when "the probation . . . was originally granted as the result of a dispositional departure granted by the sentencing court pursuant to K.S.A. 21-6815, and amendments thereto." K.S.A. 22-3716(c)(7)(B). The law also permits a district court to revoke probation without imposing a prior intermediate sanction when "the offender commits a new felony or misdemeanor while the offender is on probation." K.S.A. 22- 3716(c)(7)(C). These sections permit a court to revoke probation, but they do not require it.

Parra's argument makes it especially pertinent here to understand the rules on abuse of discretion. "'One way in which a defendant can demonstrate the existence of an abuse of discretion is to show that the district court failed to exercise its discretion, either

3 because it refused to do so or because it failed to discern that it was being called upon to exercise discretion.'" Tafolla, 315 Kan. at 332. In other words, if the district court operated under a mistaken belief that it lacked discretionary authority and automatically revoked probation without considering available alternatives, this could constitute an error of law that amounts to an abuse of discretion. Some comments made by the judge are the basis of Parra's claims on this point.

Did the court realize that it was not mandatory to send Parra to prison?

Some context is important here, and we offer extensive quotations of the district court's comments. Parra's counsel argued for reinstatement of Parra's probation so he could return to a residential treatment program. Counsel asked the court to recognize Parra's young age, his children, the length of his underlying sentence, and his struggle with addiction. Parra also spoke on his own behalf. He told the court his opiate use began after he witnessed the death of his younger brother due to the use of fentanyl. After his brother's death, Parra said he acted selfishly and began using drugs and doing what he wanted. Once charged with the probation violations, however, he realized he wanted to change his life for the better.

After hearing these serious arguments and the sobering statements about the lethality of drug use, the court began to explain its decision. The court reminded Parra that he had already received an opportunity to change:

"Well, you need to be in Narcotics—I mean, we have this discussion before sentencing, you need to be in Narcotics Anonymous meetings, working the 12 steps and have a sponsor that, you know, has got solid 10, 15 years sobriety with the same substances, and call them every week, follow the recommendations, and you need to do it for your kids."

4 The court expressed concerns for children exposed to parental drug addiction:

"I mean, what the studies show and what I see happening here in the courtroom, having done this, you know, for coming up on 26 years, with my municipal court 10 years, this gets passed along parent-to-child at a high rate, like not a hundred percent but at a high rate. And it's horrible and traumatic because here you have these kids."

The court noted that a father's drug use carried more severe costs than that of a young person without children to care for:

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Related

State v. Moore
441 P.3d 22 (Supreme Court of Kansas, 2019)
State v. Tafolla
508 P.3d 351 (Supreme Court of Kansas, 2022)

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