State v. Temaat

CourtCourt of Appeals of Kansas
DecidedFebruary 20, 2026
Docket129104
StatusUnpublished

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

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 129,104

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

TYLER MICHAEL TEMAAT, Appellant.

MEMORANDUM OPINION

Appeal from Sedgwick District Court; SETH L. RUNDLE, judge. Opinion filed February 20, 2026. Affirmed.

Submitted by the parties for summary disposition under K.S.A. 21-6820(g) and (h).

Before WARNER, C.J., HURST and BOLTON FLEMING, JJ.

PER CURIAM: Tyler M. Temaat appeals the district court's revocation of his probation and imposition of a modified, 200-month prison sentence. Temaat contends the district court's decision was unreasonable and thus an abuse of discretion. Apparently recognizing the legal authority disfavoring his claim, Temaat requested resolution through a motion for summary disposition under Supreme Court Rule 7.041A (2025 Kan. S. Ct. R. at 48), which this court granted.

Given that the district court initially granted Temaat's probation through a dispositional departure and his subsequent admitted probation violations, this court finds no error of law or fact in the district court's decision and cannot say that no reasonable court would have reached the same result. Thus, Temaat failed to demonstrate that the 1 district court abused its discretion by revoking his probation and imposing a modified prison term.

FACTUAL AND PROCEDURAL BACKGROUND

On August 25, 2023, Temaat pled guilty to aggravated robbery in violation of K.S.A. 21-5420(b)(2), pursuant to a plea agreement in which the parties agreed to recommend a sentence that included a dispositional departure to probation. As part of the plea agreement, the parties agreed to ask the district court to order Temaat to "comply with his mental health treatment, including but not limited to continuing to attend therapy and remaining compliant with his prescribed medication." The district court found an adequate factual basis for the plea and that Temaat entered the plea "knowingly, voluntarily, and intelligently with the assistance of competent counsel," and it thus convicted Temaat.

Before sentencing, Temaat filed a motion for dispositional departure to probation based on substantial and compelling factors, including: Temaat's acceptance of full responsibility through his guilty plea; the availability of programs to help with Temaat's mental health issues and decrease his risk of recidivism; Temaat's engagement in these programs during his time on bond in the case; and Temaat's mental health issues leading to the charges. Temaat also argued the case featured less-than-typical harm because no weapon was used in the commission of the offense, the property in question was immediately returned to the victim, and the harm to the victim was minor. The plea agreement had identified substantial and compelling factors supporting the dispositional departure as "the role mental health played in the offense" and Temaat's "continuing actions taken to address his mental health issues, including continuing therapy and complying with his prescribed medication."

2 The district court found Temaat's criminal history score was B and the statutory guidelines carried a presumptive prison sentence of up to 228 months. Accordingly, the district court sentenced Temaat to a 228-month prison term with postrelease supervision for 36 months. However, the district court granted Temaat's dispositional departure to probation "[b]ased on the reasons set forth in the plea agreement, including the State's recommendation to depart from the presumption of imprisonment." The district court explained the suspension to probation was "conditioned on compliance with probation for the next 36 months."

The district court explained the requirements of Temaat for the 36 months of probation which included that he remain law abiding; pay required fees; obtain drug, alcohol, and mental health treatment and follow all treatment recommendations; sign all necessary releases to permit access to his treatment records; maintain employment; refrain from alcohol and drug consumption; and submit to random drug and alcohol screening. On December 31, 2024, the district court modified the conditions of Temaat's probation to include the requirement that Temaat successfully enter and complete the Sedgwick County Adult Residential Program.

On April 15, 2025, Temaat's probation officer alleged Temaat committed 17 violations of the terms and conditions of his probation including submitting drug screens positive for illegal drugs, admitting to consuming illegal drugs, and failing to take his mental health medication as prescribed. On April 30, 2025, the district court held a probation violation hearing where, after being advised of his rights, Temaat admitted the violations. The State recommended the district court revoke Temaat's probation and impose his underlying sentence based on the recommendations of the probation officer and because Temaat was ineligible to return to the residential program or participate in a drug court program. Temaat's counsel asked the court to continue Temaat's probation because it was his first court sanction and Temaat had relapsed. Counsel described Temaat's mental health disorders and his efforts to comply with his requirements,

3 including his completion of inpatient treatment the previous July; participation in aftercare treatment at COMCARE; and completion of group meetings related to addiction. Counsel argued Temaat's prison sentence was high given that he was 28 years old and asked the court "because of the mental health and the drug addiction, to give him another opportunity to work that program," or sober living, "or something short of imposing the entire sentence."

The district court revoked Temaat's probation, explaining that Temaat's drug use resulted in "tons of property and person crimes going on over and over again," and then considered Temaat's efforts and modified the underlying sentence to 200 months. After the district court announced its ruling, Temaat requested to speak; he took responsibility for his actions and pleaded for mercy, citing his youth and his children's needs. The district court was not moved to alter its decision. After the hearing, the district court filed a journal entry reflecting its judgment—the court revoked Temaat's probation based on the violations in the warrant and ordered Temaat to serve a modified sentence of 200 months.

Temaat appealed.

DISCUSSION

Probation violation proceedings have two stages. First, the district court determines whether the defendant committed a violation, and if a violation is established, the court then conducts a disposition hearing and imposes an appropriate sanction. State v. Skolaut, 286 Kan. 219, 229, 182 P.3d 1231 (2008). That sanction could include revocation of the probation and imposition of the underlying sentence or any lesser sentence. K.S.A. 22-3716.

4 This court reviews a district court's revocation of probation for 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).

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Related

State v. Skolaut
182 P.3d 1231 (Supreme Court of Kansas, 2008)
State v. Tafolla
508 P.3d 351 (Supreme Court of Kansas, 2022)
State v. Peters
555 P.3d 1134 (Supreme Court of Kansas, 2024)

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State v. Temaat, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-temaat-kanctapp-2026.