State v. Peterson

CourtSupreme Court of Kansas
DecidedAugust 22, 2025
Docket127997
StatusPublished

This text of State v. Peterson (State v. Peterson) is published on Counsel Stack Legal Research, covering Supreme Court 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. Peterson, (kan 2025).

Opinion

IN THE SUPREME COURT OF THE STATE OF KANSAS

No. 127,997

STATE OF KANSAS, Appellee,

v.

MICHAEL A. PETERSON, Appellant.

SYLLABUS BY THE COURT

A specific sentence pronouncement is evaluated in the context of the entire sentencing hearing.

Appeal from Ford District Court; ANDREW M. STEIN, judge. Submitted without oral argument May 15, 2025. Opinion filed August 22, 2025. Affirmed in part, vacated in part, and remanded with directions.

Debra J. Wilson, of Capital Appeals and Conflicts Office, was on the brief for appellant.

Tyler W. Winslow, assistant solicitor general, and Kris W. Kobach, attorney general, were on the brief for appellee.

The opinion of the court was delivered by

STEGALL, J.: On June 15, 2022, Michael Peterson murdered his 32-year-old girlfriend, K.V., and 4-year-old daughter, A.V., in their family home in Spearville. Later that night Peterson dumped K.V.'s body in a ditch next to a county road approximately 20 miles southeast from their home. Law enforcement determined that K.V. had been

1 brutally stabbed multiple times. Separately, Peterson discarded A.V.'s body in a dumpster in Kinsley, approximately 20 miles northeast of their home. Law enforcement determined that A.V.'s skull had been disconnected from her spine.

After dumping the bodies, Peterson attempted to clean up the home with carpet cleaner and peroxide and then called the police to report K.V. and A.V. missing. Peterson initially told officers that he had come home to find an intruder in the house.

Peterson was initially charged with capital murder, though he denied any involvement with their deaths. He later entered into a plea agreement with the State, pleading guilty to two counts each of felony murder and aggravated kidnapping. According to the plea, the parties agreed to allow argument at sentencing, to allow the consideration of evidence of aggravation, and to allow the court to hear victim impact statements. The agreement specifically acknowledged that the district court would ultimately decide whether to order concurrent or consecutive sentences.

Peterson requested that his hard 25 sentences run concurrent. The State requested that the district court order them to run consecutive. After hearing additional testimony, the district court imposed consecutive hard 25 sentences for the felony murders and ran the sentences for aggravated kidnapping concurrent. The district court then assessed "the fees that are mandatory" and stated an intention to "waive any fees that are not mandatory."

On appeal, Peterson argues the district court abused its discretion by ordering the consecutive hard 25 sentences. He also argues that the district court improperly included a domestic violence special program fee and a DNA database fee in the sentencing journal entry, in direct opposition to the court's stated intent to impose only mandatory fees.

2 DISCUSSION

The district court did not abuse its discretion by ordering consecutive hard 25 sentences.

We have recently discussed the applicable standard of review in State v. Goens, 317 Kan. 616, 535 P.3d 1116 (2023). There we said:

"In most cases, '"it is within the trial court's sound discretion to determine whether a sentence should run concurrent with or consecutive to another sentence."' State v. Baker, 297 Kan. 482, 484, 301 P.3d 706 (2013). 'In fact, this principle of a judge's discretion is so entrenched that the legislature determined a defendant cannot raise the issue of whether imposing consecutive sentences is an abuse of discretion if the sentence is imposed under the Kansas Sentencing Guidelines Act (KSGA), K.S.A. 21-4701 et seq.' State v. Mosher, 299 Kan. 1, 2-3, 319 P.3d 1253 (2014). However, appellate courts can review consecutive sentences if one of the sentences is for an off-grid crime because the resulting controlling sentence is not entirely a presumptive sentence. State v. Young, 313 Kan. 724, 731-32, 490 P.3d 1183 (2021). '"[A] life sentence for an off-grid crime is not considered a 'presumptive sentence' under the KSGA."' Baker, 297 Kan. at 484. Because [a defendant's] sentence for felony murder is classified as an off-grid crime, the KSGA does not preclude our review. See State v. Brune, 307 Kan. 370, 371, 409 P.3d 862 (2018).

"The standard for determining whether a district court abused its discretion is whether

'judicial action (1) is arbitrary, fanciful, or unreasonable, i.e., if no reasonable person would have taken the view adopted by the trial court; (2) is based on an error of law, i.e., if the discretion is guided by an erroneous legal conclusion; or (3) is based on an error of fact, i.e., if substantial competent evidence does not support a factual finding on which a prerequisite conclusion of law or the exercise of discretion is based.' Baker, 297 Kan. at 484.

3 "[A defendant] has the burden to prove the trial court abused its discretion. To sustain his burden, he must show that no reasonable person would have taken the trial court's view.

"Neither our statutes nor our caselaw set definitive criteria for when a district court should order sentences to be served concurrently or consecutively. See State v. Darrah, 309 Kan. 1222, 1227, 442 P.3d 1049 (2019)." Goens, 317 Kan. at 619-20.

Because Peterson's felony murder convictions are off-grid crimes, we must ask whether the district court abused its discretion in ordering consecutive sentences. Framed another way, because Peterson does not allege an error of fact or law, our inquiry is limited to whether any reasonable person would have ordered Peterson to serve consecutive sentences.

At sentencing, the district court heard statements from the State's witnesses, including an investigator from the coroner's office and two special agents from the Kansas Bureau of Investigation, viewed exhibits displaying how the bodies had been dumped, heard victim impact statements and statements made by Peterson's family, and considered a report regarding Peterson's risk of future prison violence, and Peterson exercised his right to allocution. The judge acknowledged that all of this testimony had "provided [the court] much needed information and guidance in making this decision." Peterson acknowledged that the district court could consider this additional information and that the district court had the authority to order consecutive sentences.

After taking all of that into consideration, the district court stated that since the case had been pending for approximately two years, he had "plenty of time to think about it." The judge then discussed how the laws enacted by the Legislature reflect the views and morality of society and how those views frame the goals of a hard 25 sentence. The judge acknowledged the goals of sentencing as incapacitation, deterrence, retribution, and

4 rehabilitation and stated that he had considered those goals. The court then pronounced the hard 25 sentences as consecutive, resulting in a minimum sentence of 50 years without the possibility of parole.

We hold the judge's decision was reasonable. Though the facts in Peterson's plea agreement are bare, the additional testimony and exhibits at sentencing revealed several aggravating factors. Peterson brutally murdered his girlfriend, who was the mother of his child.

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State v. Peterson, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-peterson-kan-2025.