State v. Sands

CourtCourt of Appeals of Kansas
DecidedMay 15, 2026
Docket127903
StatusUnpublished

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

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 127,903

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

CARL THOMAS SANDS, Appellant.

MEMORANDUM OPINION

Appeal from Leavenworth District Court; CLINTON LEE, judge. Submitted without oral argument. Opinion filed May 15, 2026. Affirmed.

Merideth J. Hogan, of Kansas Appellate Defender Office, for appellant.

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

Before WARNER, C.J., ATCHESON and CLINE, JJ.

CLINE, J.: Carl Thomas Sands seeks a new trial after being convicted of alternative counts of fleeing or attempting to elude an officer. He claims the district court erred in denying his motion in limine and the prosecutor erred by making improper statements in closing. After reviewing the record, we find the district court did not abuse its discretion in denying Sands' motion because the evidence he sought to exclude was relevant and not unduly prejudicial. And even assuming the prosecutor's statements were erroneous, we find the errors harmless. We therefore affirm the district court's decision and Sands' convictions.

1 FACTUAL AND PROCEDURAL BACKGROUND

On August 26, 2022, Richard and Joshua DeMaranville reported to police that they discovered the workshop door of their recently deceased neighbor, Marcus "Mark" Spencer, was open and the lock had been broken. When Richard fixed the lock, he noticed tire tracks on the property and that several items were missing.

The next day, Richard saw strangers pull into Spencer's property in an SUV-type vehicle and a Chevrolet truck pulling an enclosed trailer. Richard called Joshua and told him that they needed to go see what was going on.

When confronted by the DeMaranvilles, the strangers claimed that Marcus Spencer was their uncle and they were coming to clean up the property. But the DeMaranvilles, who had known Spencer for at least 15 years, knew that he did not have any nephews. They also noted that no one ever called Spencer by the name Marcus—he went by his nickname, Mark. Around this time, Sands came from the shop and said, "'It's got a new lock on it already,'" or "'They changed the lock,'" which also made the DeMaranvilles suspicious. One of the strangers then pulled out a gun and pointed it at them, so Richard called 911 and told Joshua to do the same.

As the strangers began to leave, the DeMaranvilles saw Sands get into the truck and start to drive off the property. Although Richard was unsuccessful in his attempt to block the vehicles from leaving the property, Joshua managed to take a picture of the truck with the trailer.

Joshua then called a neighbor, Lynn Looney, for help. Joshua told Looney that the previous intruders had returned to Spencer's property and were shooting at him. So, Looney picked up Joshua and they gave chase.

2 When Looney tried to pull alongside the truck to see if they could read the license plate, the SUV driver began shooting at him. Looney backed off and returned fire but was unsure if he had hit anything. Looney and Joshua continued their chase while on the phone with the 911 dispatcher, informing the dispatcher of the directions that the truck and SUV were traveling.

At one point, Leavenworth County Sheriff's Deputy Adam Munoz spotted the vehicles, activated his lights, and began following the truck. The deputy saw the truck driver run stop signs and lights, speed over 100 miles per hour, and cross over into oncoming traffic. The deputy stopped the chase once the truck crossed into Missouri.

Sergeant Jason Slaughter of the Leavenworth County Sheriff's Office was assigned to investigate the case. He discovered gas station surveillance footage, which showed Sands in the truck roughly one and a half hours before the disturbance at Spencer's property. Using this footage, Slaughter created photos and gave them to other law enforcement contacts, which helped identify Sands through prior mugshots.

After identifying Sands, and about 10 days after the chase, Slaughter watched Sands at his home in Kansas City, Missouri. At one point, Slaughter saw Sands use a key fob to open what appeared to be the truck involved in the chase and drive away. Slaughter asked the Kansas City, Missouri Police Department to stop the truck, which had been reported stolen. When Slaughter recovered the vehicle, the back glass had been shot out.

Before trial, Sands moved to exclude evidence of the theft of the pickup truck, the attempted theft at Spencer's property and gunfire exchange, the gas station surveillance video, eyewitness identification of Sands on Spencer's property, and Sergeant Slaughter's testimony about Sands' later possession of the truck. He argued that this evidence was

3 unduly prejudicial and irrelevant because none of it was relevant to the elements of the crime of fleeing and eluding.

The district court granted the motion in part and denied it in part, finding that the State would be prohibited from introducing evidence that Sands stole the truck, but the State could present evidence that the truck was reported stolen. The court found the remaining evidence at issue was all admissible to the extent that the identity of the truck's driver during the chase was controverted. The district court explicitly found the evidence was relevant and not so prejudicial that it outweighed the probative value.

Sands went to trial and the jury ultimately found him guilty of fleeing or attempting to elude a police officer by driving the wrong way in traffic, and guilty of fleeing or attempting to elude a police officer by driving in a reckless manner. Since these convictions were considered alternative, the district court merged the two resulting in Sands being convicted of a severity level 7 person felony. Sands was ultimately sentenced to the aggravated sentence for that crime of 31 months in prison.

REVIEW OF SANDS' APPELLATE CHALLENGES

I. Did the district court err in denying Sands' motion in limine?

To begin, Sands renews his argument that the evidence he sought to exclude was irrelevant to the charged crimes and unduly prejudicial. The State counters that this evidence is material because Sands put his identity at issue, and the evidence tends to show that Sands was the person driving the truck while fleeing and eluding Deputy Munoz. It also alleges the evidence was not unduly prejudicial.

4 Sands failed to preserve his objection to evidence of the prior theft and gunfire.

K.S.A. 60-404, referred to as the contemporaneous objection rule, provides that an appellate court cannot review an evidentiary challenge absent a timely and specific objection on the record. Under this rule, any pretrial objection to the admission or exclusion of evidence must be preserved by contemporaneously objecting at trial. State v. Showalter, 318 Kan. 338, 345, 543 P.3d 508 (2024). "Kansas appellate courts have sometimes declined to strictly apply the contemporaneous objection rule in certain contexts, but only after finding the underlying purpose for the rule has been satisfied." 318 Kan. at 346.

The State asks us to find this issue partially unpreserved because Sands failed to renew his objections at trial to some of the evidence—namely, the prior theft at Spencer's property and the gunfire exchange between the DeMaranvilles and Sands' accomplices.

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