State v. Trotter

CourtCourt of Appeals of Kansas
DecidedApril 17, 2026
Docket128774
StatusUnpublished

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

Opinion

NOT DESIGNATED FOR PUBLICATION

No. 128,774

IN THE COURT OF APPEALS OF THE STATE OF KANSAS

STATE OF KANSAS, Appellee,

v.

COLTON S. TROTTER, Appellant.

MEMORANDUM OPINION

Appeal from Sedgwick District Court; RODGER L. WOODS, judge. Submitted without oral argument. Opinion filed April 17, 2026. Reversed and remanded with directions.

Sean P. Randall, of Kansas Appellate Defender Office, for appellant.

Julie A. Koon, assistant district attorney, Marc Bennett, district attorney, and Kris W. Kobach, attorney general, for appellee.

Before MALONE, P.J., BRUNS and HURST, JJ.

PER CURIAM: Colton S. Trotter appeals the district court's decision revoking his probation and imposing the original sentence. Trotter claims the district court erred by revoking his probation solely because he had absconded when there was insufficient evidence to support the absconder violation. The State concedes there was insufficient evidence to support the district court's finding that Trotter had absconded but claims the issue is moot. After thoroughly reviewing the record, we reverse the district court's order revoking Trotter's probation and remand for a new disposition hearing.

1 Factual background

On May 9, 2022, Trotter pled guilty to one count of arson. On September 20, 2022, the district court sentenced Trotter to 19 months' imprisonment but granted probation for 24 months to be supervised by community corrections.

On March 28, 2023, the district court issued a warrant alleging that Trotter had violated the conditions of his probation by testing positive for methamphetamine, admitting to using methamphetamine, failing to report to his intensive supervision officer (ISO) as directed, and failing to pay court costs and restitution. Trotter admitted the violations and the district court imposed a 3-day jail sanction, ordered Trotter to attend outpatient drug treatment, and extended the probation by 24 months.

On August 9, 2023, the district court issued a warrant alleging that Trotter had violated the conditions of his probation by twice testing positive for methamphetamine. Trotter again admitted the violations and the district court imposed another 3-day jail sanction, ordered Trotter to attend an inpatient drug treatment program with aftercare, and extended the probation by 24 months. Trotter later agreed to enter the Sedgwick County Veterans Treatment Court program.

On May 17, 2024, the district court issued an amended warrant alleging that Trotter had violated the conditions of his probation by failing to attend drug and alcohol treatment as directed, failing to report to his ISO as directed, failing to report for a court ordered drug and alcohol test, failing to submit a drug and alcohol test, failing to submit proof of his "completed sober event" as ordered, and failing to appear in court. On January 17, 2025, the district court issued an additional warrant alleging that Trotter had violated his probation by traveling to Nashville, Tennessee, without written permission from his ISO, that Trotter had absconded from the Veterans Treatment Court program, and that he had also traveled to El Paso, Texas, without written permission from his ISO.

2 The district court held a probation violation hearing on January 29, 2025. Trotter admitted all of the allegations in the May 17, 2024 amended warrant. As for the January 17, 2025 warrant, Trotter admitted that he was in Nashville, Tennessee, on or about June 24, 2024; that he was in El Paso, Texas, on January 7, 2025; and that he was absent from the Veterans Treatment Court program from May 10, 2024, to January 7, 2025. Trotter did not admit that his actions met the legal definition of "abscond."

While arguing about the appropriate disposition, Trotter's counsel explained that Trotter temporarily left the Veterans Treatment Court program after pressure from facing new charges for domestic battery and school finals. Trotter's counsel argued that Trotter had reached a turning point in El Paso and had intended to return to Kansas, but that law enforcement intercepted him and arrested him in El Paso before he could do so. Trotter spoke on his own behalf and explained that after he left Kansas he eventually was "on my way back here to turn myself in when I got picked up. And I was, like, hoping to, like, turn myself in on my own terms." After hearing the arguments, the district judge found:

"I will start with finding that Mr. Trotter was, in fact, arrested in El Paso, Texas, requiring—did not waive extradition and incurred a cost of $1,417. .... "Based on the violations specific to being in—in Nashville, Tennessee, El Paso, Texas, the Court would make a finding that he had absconded from supervision. He'd been—for a period from May of 2024 until his return in 2025. "Review of—of Mr. Trotter's—going back before entry into the Veterans Treatment Court program and reviewing the Court's own file, it does appear that there were bench warrants filed for failure to appear back in June of 2021, March of 2022, and probation violation warrant issued for failure to report in March of 2023. "There was testimony presented that Mr. Trotter had engaged, at some points, with VA treatment while he was absent from—from Sedgwick County. But the fact remains that he was absconded, was on warrant status, was not engaged in—in the treatment program here.

3 "And based on that, the Court would find that Mr. Trotter is not amenable to—to probation, and—and will revoke probation, order that Mr. Trotter serve the underlying sentence in this case." (Emphasis added.)

The journal entry of the probation violation hearing found that Trotter had violated his probation on all the grounds listed in the May 17, 2024 amended warrant and all the grounds listed in the January 17, 2025 warrant. The journal entry stated the district court revoked Trotter's probation because he had "absconded." A separate comment box stated the district court found that Trotter was arrested in El Paso, Texas; he was in Nashville and El Paso and absconded from May 2024 until his return in 2025; he had prior bench warrants outstanding; he engaged in the Veterans Treatment Court program but ultimately absconded and did not engage in treatment; and that he was not amenable to probation. Trotter timely appealed the district court's judgment.

Analysis

Trotter claims there was insufficient evidence to support the district court's finding that he absconded from probation because he did not have the conscious intent to evade the legal process. He asserts the record is clear that the district court relied solely on the absconder finding to revoke his probation. He claims we must reverse the district court's order revoking his probation and remand for a new disposition hearing. The State agrees there was insufficient evidence to support the district court's finding that Trotter had absconded but claims the issue is moot because Trotter has been released from prison.

The procedure for revoking a defendant's probation is governed by K.S.A. 22- 3716. Generally, once a probation violation is established, a district court has discretion to revoke probation and impose the original sentence unless otherwise limited by statute. State v. Tafolla, 315 Kan. 324, 328, 508 P.3d 351 (2022). An appellate court reviews a district court's revocation of probation for an abuse of discretion. 315 Kan. at 328. "A district court abuses its discretion if no reasonable person could agree with its decision or 4 if its exercise of discretion is founded on a factual or legal error." State v. Butler, 315 Kan.

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